Challenges in Opt-Out Design and Children’s Privacy Highlighted by Sling TV’s Settlement With California AG

The California AG’s recent settlement with Sling TV reinforces that regulators are focused on opt-out processes and children’s data. Sling TV was fined $530,000 by the enforcer, and required to implement expanded compliance measures, for violating the CCPA by failing to offer customers an easy method to stop the sale of their personal data and not providing sufficient privacy protections for children. The investigation into Sling TV’s privacy operations stemmed from the California DOJ’s investigative sweep of streaming services and connected TVs, which was announced in January 2024. This article analyzes Sling TV’s alleged violations and the terms of the voluntary settlement, with practical takeaways from partners at Finnegan and Frankfurt Kurnit. See our two-part series on TV privacy: “Can Old Remotes Handle New Consent Requirements?” (May 18, 2022), and “Will the TV Industry Agree to Standardize Consent on Screen?” (May 25, 2022).

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