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CPPA Settles with Data Brokers Growbots and UpLead for Delete Act Violations

Growbots, Inc. and UpLead LLCNovember 8, 2024California Privacy Protection Agency

Penalty Amount

$69,800

Summary

The California Privacy Protection Agency (CPPA) settled with data brokers Growbots, Inc. and UpLead LLC for failing to register and pay annual fees under the California Delete Act. Growbots paid $35,400 and UpLead paid $34,400, and both agreed to injunctive terms including payment of attorney fees for non-compliance. This action enforces the Delete Act's requirements for data broker transparency and consumer privacy.

Remedy

The companies must pay the specified fines and comply with injunctive terms that require adherence to the Delete Act and payment of the Enforcement Division's attorney fees if future non-compliance occurs.

Monetary PenaltyInjunction

Contract Impact

In-house legal teams should review all vendor, customer, and data processing agreements with entities classified as data brokers under California law. Specifically scrutinize clauses addressing: (1) registration and fee payment obligations under the California Delete Act; (2) compliance with statutory deadlines and reporting requirements; (3) injunctive relief and attorney fee shifting provisions for non-compliance; and (4) obligations related to consumer deletion requests via the Data Broker Requests and Opt-Out Platform (DROP). Agreements may need amendments to explicitly mandate Delete Act registration, annual fee responsibility, and cooperation with DROP, while also allocating costs for enforcement actions and attorney fees.

Contract Search Terms

data broker registrationannual fee paymentDelete Act complianceinjunctive relief termsattorney fees provisionconsumer deletion request mechanismData Broker Requests and Opt-Out Platform (DROP)registration deadlinenon-compliance penaltiesCalifornia Data Broker Registry

Laws Cited

California Delete Act (SB 362)

Violation Types

Entity Details

Entity

Growbots, Inc. and UpLead LLC

Also known as: Growbots and UpLead

Industry

Data Broker

Official Sources

Related Enforcement Actions

CPPA

Data brokers (unspecified - advisory applies to all businesses registered with California's data broker registry)

CalPrivacy (the California Privacy Protection Agency) issued Enforcement Advisory 2026-01 warning data brokers that providing incorrect information in their annual registration with California's data broker registry carries liability of a $200 fine per day. The advisory observes that the Enforcement Division has already brought multiple enforcement actions over reporting errors, and emphasizes that accurate registry disclosures are what make the newly launched Delete Request and Opt-Out Platform (DROP) work for Californians. No specific company was named and no penalty was imposed by the advisory itself; it functions as forward-looking guidance.

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SalesIntel Research, Inc.

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The California Privacy Protection Agency Board issued a Decision and Final Stipulated Order requiring Virginia-based data broker SalesIntel Research, Inc. to pay a $36,400 fine for operating as a data broker without registering by the 2025 deadline under the Delete Act. SalesIntel sells consumer personal information, including more than 200 million professional contacts and de-anonymized website traffic data, for targeted advertising. In addition to the fine, the company must post privacy rights metrics on its website, integrate with CalPrivacy's Delete Request and Opt-out Platform (DROP), and process future deletion requests through that system.

CPPA

Data brokers registered on California's DROP platform (654)

The California Privacy Protection Agency announced that more than 500,000 Californians have registered for the Delete Request and Opt-out Platform (DROP) since its January 1, 2026 launch. After the August 1, 2026 deadline for brokers to begin processing requests, 654 data brokers are in the system and approximately 25% have reported processing deletion requests, with tens of millions of records already deleted. No enforcement action has been announced yet; the agency warned that brokers who fail to delete eligible personal information face significant fines.

CPPA

Cybba, Inc.

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The California Privacy Protection Agency Board issued an Order of Decision and Stipulated Final Order requiring Boston-based data broker Cybba, Inc. to pay a $52,400 fine for failing to register with the Agency's Data Broker Registry by the 2025 deadline, as required by the Delete Act. The order also requires Cybba to post metrics about privacy rights on its website, access the Agency's Delete Request and Opt-Out Platform (DROP), and process future deletion requests through that system. This is CalPrivacy's second data broker enforcement action announced in less than a week, following its action against LocateSmarter.

CPPA

LocateSmarter LLC

$116K

The California Privacy Protection Agency Board issued a decision and stipulated order requiring Iowa data broker LocateSmarter LLC to pay $116,490 and change its practices. The company failed to timely register as a data broker and unlawfully required Californians to provide the last four digits of their Social Security numbers before exercising opt-out rights, violating the CCPA's data minimization requirements. This is the first action against a data broker under both the CCPA and the Delete Act.

CPPA

California Privacy Protection Agency

The California Privacy Protection Agency announced that over 300,000 Californians have signed up for the Delete Request and Opt-out Platform (DROP) since its launch five months ago. The Data Broker Registry now includes 581 registered data brokers, the highest number since the registry was established in 2020. Beginning August 1, 2026, all data brokers will be required to access DROP and process deletion requests.