In this article published by The Drum, Senior Legal Director Marci Rozen comments on the first enforcement action of the California Consumer Privacy Act (CCPA), noting that “the alleged CCPA violations are somewhat technical in nature,” and that Sephora “engaged in completely ordinary data sharing activities like using pixels and cookies for online behavioral advertising,” practices that the company disclosed effectively in its privacy policy. The allegations instead stem from Sephora’s failure to properly disclose that these activities constitute a ‘sale’ in the way that the term is defined under the CCPA, she explains.
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