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CA AG Settles with Sephora for $1.2M Over CCPA Opt-Out Failures

Sephora, Inc.August 24, 2022California Attorney General

Penalty Amount

$1,200,000

Summary

California Attorney General Rob Bonta announced a settlement with Sephora, Inc. resolving allegations that the company violated the California Consumer Privacy Act (CCPA) by failing to disclose it was selling consumers' personal information and failing to process opt-out requests via user-enabled Global Privacy Controls. Sephora agreed to pay $1.2 million in penalties and implement injunctive measures including updating privacy disclosures, enabling opt-out via GPC, conforming service provider agreements to CCPA, and reporting to the AG. The settlement is part of ongoing CCPA enforcement efforts, with the AG also issuing cure notices to other businesses failing to honor GPC opt-out signals.

Remedy

Sephora must pay $1.2 million in civil penalties. It must update its privacy policy and online disclosures to affirmatively disclose that it sells consumer personal information, implement mechanisms to allow consumers to opt out of data sales including via the Global Privacy Control (GPC), update all service provider agreements to comply with CCPA requirements, and submit regular reports to the California Attorney General regarding its data sale practices, service provider relationships, and GPC compliance efforts.

Monetary PenaltyInjunctionReporting Requirements

Contract Impact

In-house legal teams should review all service provider, vendor, and partner agreements to ensure they include explicit CCPA-compliant terms requiring downstream parties to honor consumer opt-out requests transmitted via user-enabled Global Privacy Controls (GPC) and manual "Do Not Sell My Personal Information" links equivalently. Customer-facing privacy policies and online disclosures must be audited to include clear, affirmative disclosures of any sale of consumer personal information, with accessible opt-out mechanisms that process both GPC signals and manual requests. Vendor agreements should also be updated to conform to CCPA requirements, including clauses governing data sale practices, service provider obligations, and reporting to the company to enable compliance with regulatory reporting requirements. Additionally, companies should implement internal processes to track and respond to opt-out requests across all platforms, including automated GPC signals, to avoid similar CCPA violations.

Contract Search Terms

Global Privacy Controlopt-out mechanismdata sale disclosureservice provider agreementCCPA complianceprivacy policy disclosureGPC signalopt-out request processing

Laws Cited

California Consumer Privacy ActCCPA

Violation Types

Entity Details

Entity

Sephora, Inc.

Also known as: Sephora

Industry

Retail

Official Sources

Source Evidence

Entity Name
"Sephora, Inc."
Event Date
"Wednesday, August 24, 2022"
Fine Amount
"$1.2 million"
Laws Cited
"California Consumer Privacy Act (CCPA)"
Violation Types
"failed to disclose to consumers that it was selling their personal information, that it failed to process user requests to opt out of sale via user-enabled global privacy controls in violation of the CCPA"
Remedy Types
"pay $1.2 million in penalties and comply with important injunctive terms"

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