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CPPA Fines Infillion $54K, Data Group $46K for Delete Act Violations

PayDae, Inc. (Infillion) and The Data Group, LLCDecember 19, 2024California Privacy Protection Agency

Summary

The California Privacy Protection Agency (CPPA) settled with two data brokers, PayDae, Inc. (Infillion) and The Data Group, LLC, for failing to register as required by Senate Bill 362 (the Delete Act). Infillion paid $54,200 and The Data Group paid $46,600, and both agreed to injunctive terms to ensure future compliance with registration requirements.

Remedy

Both companies must pay the specified fines and comply with data broker registration requirements, including disclosing practice-specific information and paying the annual fee by the deadline.

Monetary PenaltyInjunction

Contract Impact

In-house legal teams should review vendor, customer, and data processing agreements, particularly those involving data sharing or brokerage activities. Focus on clauses mandating compliance with specific privacy laws (e.g., CCPA, Delete Act), audit rights, indemnification for regulatory fines, and certification requirements. Changes may be needed to explicitly obligate counterparties to register as data brokers under SB 362, pay associated annual fees, disclose practice-specific information to the CPPA, and provide timely compliance certifications. Agreements should also address injunctive relief obligations and allocate responsibility for registration failures.

Contract Search Terms

data broker registrationannual feeSB 362Delete Act complianceCPPA registrationinjunctive termspractice-specific disclosureregistration deadlinedata broker definitionprivacy compliance certification

Laws Cited

California Consumer Privacy Act (CCPA)Senate Bill 362 (Delete Act)

Violation Types

Entity Details

Entity

PayDae, Inc. (Infillion) and The Data Group, LLC

Also known as: Infillion and Data Group

Industry

Data Broker

Official Sources

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