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CA AG Investigates Surveillance Pricing by Retail, Grocery, Hotel Businesses

businesses with significant online presence in the retail, grocery, and hotel sectorsJanuary 27, 2026California Attorney General

Summary

California Attorney General Rob Bonta announced an investigative sweep targeting businesses that use surveillance pricing, which involves setting individualized prices based on consumer data. The Department of Justice is sending information request letters to companies in the retail, grocery, and hotel sectors to assess compliance with the CCPA's purpose limitation principle. This action seeks to ensure that consumers are not charged different prices without proper disclosure and that businesses adhere to privacy laws.

Contract Impact

In-house legal teams should review vendor, customer, and data processing agreements with entities in the retail, grocery, and hotel sectors. Focus on clauses governing data usage restrictions, purpose limitation, disclosure requirements for price differentiation based on personal data, and consumer consent mechanisms. Specific attention should be given to whether contracts permit or restrict using consumer data (e.g., browsing history, location, demographics) to set individualized prices. Updates may be needed to explicitly prohibit undisclosed surveillance pricing, enhance transparency in privacy policies and contracts, and ensure robust opt-out rights aligned with CCPA's purpose limitation principle.

Contract Search Terms

surveillance pricingpurpose limitation principlepersonal information use disclosureprice discrimination clauseconsumer data consentopt-out mechanismdata processing purposesindividualized pricing disclosuredata sharing agreement

Laws Cited

CCPA

Violation Types

Entity Details

Entity

businesses with significant online presence in the retail, grocery, and hotel sectors

Also known as: Retail, Grocery, and Hotel Businesses

Industry

Retail

Official Sources

Source Evidence

Entity Name
"businesses with significant online presence in the retail, grocery, and hotel sectors"
Laws Cited
"California Consumer Privacy Act (CCPA)"
Violation Types
"Surveillance pricing is the use of a consumer’s personal information to set targeted, individualized prices for a product or service."
Violation Types
"algorithmic pricing"

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