California Attorney General Announces First CCPA Enforcement Action

On August 24, 2022, the California Attorney announced a settlement with Sephora, Inc. that included a fine of $1.2 million for alleged violations of the California Consumer Privacy Act (CCPA). The settlement is important because it makes clear that the use of analytics, advertising cookies, and other automatic data collection technologies are a "sale" under the CCPA. Businesses that are subject to the CCPA (and the upcoming CPRA) should immediately review their CCPA compliance to minimize being a potential target of further enforcement actions.