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CalPrivacy First CCPA/Delete Act Action Against Data Broker LocateSmarter LLC

LocateSmarter LLCAugust 11, 2026California Privacy Protection Agency

Penalty Amount

$116,490

Summary

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.

Remedy

LocateSmarter must pay a $116,490 fine and change its practices, including timely registration as a data broker and removing unnecessary data requirements from its opt-out process.

Monetary PenaltyInjunctionConsent DecreeCompliance Program

Contract Impact

In-house teams should review data licensing agreements and vendor contracts under which personal information is acquired or made available to customers, ensuring data sourcing and sharing arrangements account for data broker registration obligations under the Delete Act and CCPA. Consumer-facing flows embedded in vendor or platform integrations should be checked to ensure opt-out requests do not require unnecessary data (e.g., partial SSNs) — the CCPA's data minimization rules apply to consumer request processes. Contracts with data brokers should include representations of registration status, compliance with Delete Act/DROP obligations, and indemnification for unauthorized sharing of unregistered broker data.

Contract Search Terms

data broker registrationopt-out mechanismdata minimizationSocial Security number collectionlicensing agreementpersonal information sharingDelete Act complianceconsumer opt-out request

Laws Cited

CCPADelete Act

Violation Types

Entity Details

Entity

LocateSmarter LLC

Industry

Data Broker

Official Sources

Source Evidence

Entity Name
"requiring LocateSmarter LLC, an Iowa data broker, to pay $116,490 and change its practices"
Fine Amount
"to pay $116,490 and change its practices after the company failed to register timely as a data broker"
Laws Cited
"the first against a data broker under the California Consumer Privacy Act (CCPA), and the first to arise under both the CCPA and the Delete Act"
Violation Types
"unlawfully required Californians to provide partial Social Security numbers before they could exercise their opt-out rights"
Violation Types
"made this information available to its customers without timely registration as a data broker"

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.

CPPA

SalesIntel Research, Inc.

$36K

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.

$52K

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

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.

CPPA

General Motors

$12.8M

CalPrivacy and the California Attorney General secured a $12.75 million settlement from General Motors for data sharing practices from connected vehicles. The settlement includes injunctive terms to change business practices.