On July 8, Connecticut Attorney General William Tong announced a settlement with TicketNetwork, Inc. for alleged violations of the Connecticut Data Privacy Act (CTDPA). The settlement is the first publicly announced enforcement action under the state's comprehensive privacy statute, which went into effect on July 1, 2023.
This settlement highlights that enforcement is gaining steam in states whose comprehensive privacy statutes became effective in the past couple of years. Connecticut's settlement also serves as a reminder for businesses to review their privacy notices and the functionality of their consumer rights mechanisms.
Connecticut's action against TicketNetwork focuses on the CTDPA's transparency and opt-out requirements. According to the Attorney General's press release, the AG's Office sent a "cure notice" to TicketNetwork in November 2023 asserting that the company's privacy notice was deficient because it "was largely unreadable, missing key data rights, and contained rights mechanisms that were misconfigured or inoperable." The cure notice gave TicketNetwork 60 days to remedy these deficiencies. According to the AG's Office, TicketNetwork represented it had resolved the deficiencies "when they had not done so," and did not timely respond to the AG's follow-up correspondence.
Under the settlement, TicketNetwork has reportedly agreed to pay $85,000, comply with the requirements of the CTDPA, maintain metrics for consumer rights requests received under the CTDPA, and report these metrics to AG Tong.
To date, the Connecticut AG has issued over two dozen "cure notices," each aimed at addressing potential privacy notice violations. In the announcement of the action against TicketNetwork, AG Tong warned that the CTDPA "has now been in effect for two years. There is no excuse for continued non-compliance, and we are prepared to use the full weight of our enforcement authority to protect consumer privacy."
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