Loyal to a Fault? Customer Loyalty Programs in the Age of Comprehensive Privacy Laws

While providing numerous consumer benefits, loyalty programs also create potential privacy risks because of their heavy reliance on customer personal information. U.S. state comprehensive privacy laws include a number of explicit requirements applicable to customer loyalty programs. In this guest article, Holland & Knight senior counsel Kevin Angle and associate Ashley Fisher review those rules, including notice and consent obligations and “sale” of personal data restrictions, and provide practical advice on approaches to compliance. See “Measures for Complying With 19 (and Counting) State Privacy Laws” (Jun. 26, 2024).

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