On February 27, 2026, CalPrivacy and PlayOn settled a CCPA claim for $1.1 million. PlayOn is a digital ticketing platform used by schools and other organizations for ticketing, streaming, fundraising, concessions, merchandise sales, and website management. The settlement resolves allegations that PlayOn unlawfully “sold” and “shared” users’ personal information without providing sufficient opt-outs and notice, in violation of the CCPA. This marks the agency’s first enforcement action involving students’ data privacy.

CalPrivacy alleged that PlayOn’s cookie banner was not a sufficient opt-out mechanism since there was no way to close it without clicking “agree,” and on mobile devices, the cookie banner required users to click “agree” in order to use site functionality. Relatedly, CalPrivacy alleged that directing users to opt out of tracking technologies directly via the Network Advertising Initiative and the Digital Advertising Alliance was insufficient. Finally, CalPrivacy alleged that PlayOn failed to recognize and honor opt-out preference signals.

CalPrivacy also alleged that PlayOn’s privacy notice was deficient. For example, CalPrivacy alleged that PlayOn’s privacy notice had not been updated for more than a year, failed to inform consumers of their right to opt out of “sharing,” and incorrectly stated that PlayOn did not “sell” personal information. The privacy notice also failed to set out how to exercise the right to opt out of “selling” and “sharing,” including through the use of an opt-out preference signal. CalPrivacy noted that its allegations only applied to PlayOn before PlayOn engaged in a series of updates to its privacy practices, including updating its website to recognize opt-out preference signals and revising its cookie banner to provide users with an accept and reject button.

In addition to paying the fine, the settlement requires that PlayOn, to the extent it has not already done so, implement proper data sharing opt-out features, conduct regular scans to take an inventory of tracking technologies, engage in periodic risk assessments, and publish certain data metrics. It also requires PlayOn to comply with California’s privacy law prohibiting the “selling” or “sharing” of personal information of consumers between the ages of 13 and 16 without their affirmative opt-in consent.

Photo of Lindsey Tonsager Lindsey Tonsager

Lindsey Tonsager is a recognized leader in representing companies before federal and state regulators, and is renowned for advising on minor protection, AI, and state comprehensive privacy laws.

Lindsey chairs the firm’s global Data Privacy and Cybersecurity practice. She advises clients in their…

Lindsey Tonsager is a recognized leader in representing companies before federal and state regulators, and is renowned for advising on minor protection, AI, and state comprehensive privacy laws.

Lindsey chairs the firm’s global Data Privacy and Cybersecurity practice. She advises clients in their strategic and proactive engagement with the Federal Trade Commission, the U.S. Congress, the California Privacy Protection Agency, and State Attorneys General on proposed changes to data protection laws, and regularly represents clients in responding to investigations and enforcement actions involving their privacy and information security practices.

Lindsey’s practice focuses on helping clients launch new products and services that implicate the laws governing the use of artificial intelligence; data processing for robotics, autonomous vehicles, and other connected devices; biometrics; online advertising; the collection of personal information from children, teens, and students online; e-mail marketing; disclosures of video viewing information; and new technologies.

Lindsey also assesses privacy and data security risks in complex corporate transactions where personal data is a critical asset or data processing risks are otherwise material. In light of a dynamic regulatory environment where new state, federal, and international data protection laws are always on the horizon and enforcement priorities are shifting, she focuses on designing risk-based global privacy programs for clients that can keep pace with evolving legal requirements and efficiently leverage the clients’ existing privacy policies and practices. She conducts data protection assessments to benchmark against legal requirements and industry trends and proposes practical risk mitigation measures.

Photo of Libbie Canter Libbie Canter

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws.

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws. She routinely supports clients on their efforts to launch new products and services involving emerging technologies, and she has assisted dozens of clients with their efforts to prepare for and comply with federal and state laws, including the California Consumer Privacy Act, the Colorado AI Act, and other state laws. As part of her practice, she also regularly represents clients in strategic transactions involving personal data, cybersecurity, and artificial intelligence risk and represents clients in enforcement and litigation postures.

Libbie represents clients across industries, but she also has deep expertise in advising clients in highly-regulated sectors, including financial services and digital health companies. She counsels these companies — and their technology and advertising partners — on how to address legacy regulatory issues and the cutting edge issues that have emerged with industry innovations and data collaborations.

Chambers USA 2025 ranks Libbie in Band 3 Nationwide for both Privacy & Data Security: Privacy and Privacy & Data Security: Healthcare. Chambers USA notes, Libbie is “incredibly sharp and really thorough. She can do the nitty-gritty, in-the-weeds legal work incredibly well but she also can think of a bigger-picture business context and help to think through practical solutions.”

Photo of Jayne Ponder Jayne Ponder

Jayne Ponder provides strategic advice to national and multinational companies across industries on existing and emerging data privacy, cybersecurity, and artificial intelligence laws and regulations.

Jayne’s practice focuses on helping clients launch and improve products and services that involve laws governing data privacy…

Jayne Ponder provides strategic advice to national and multinational companies across industries on existing and emerging data privacy, cybersecurity, and artificial intelligence laws and regulations.

Jayne’s practice focuses on helping clients launch and improve products and services that involve laws governing data privacy, artificial intelligence, sensitive data and biometrics, marketing and online advertising, connected devices, and social media. For example, Jayne regularly advises clients on the California Consumer Privacy Act, Colorado AI Act, and the developing patchwork of U.S. state data privacy and artificial intelligence laws. She advises clients on drafting consumer notices, designing consent flows and consumer choices, drafting and negotiating commercial terms, building consumer rights processes, and undertaking data protection impact assessments. In addition, she routinely partners with clients on the development of risk-based privacy and artificial intelligence governance programs that reflect the dynamic regulatory environment and incorporate practical mitigation measures.

Jayne routinely represents clients in enforcement actions brought by the Federal Trade Commission and state attorneys general, particularly in areas related to data privacy, artificial intelligence, advertising, and cybersecurity. Additionally, she helps clients to advance advocacy in rulemaking processes led by federal and state regulators on data privacy, cybersecurity, and artificial intelligence topics.

As part of her practice, Jayne also advises companies on cybersecurity incident preparedness and response, including by drafting, revising, and testing incident response plans, conducting cybersecurity gap assessments, engaging vendors, and analyzing obligations under breach notification laws following an incident.

Jayne maintains an active pro bono practice, including assisting small and nonprofit entities with data privacy topics and elder estate planning.

Photo of Ariel Dukes Ariel Dukes

Ariel Dukes is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity Practice Group.

Ariel counsels clients on data privacy, cybersecurity, and artificial intelligence. Her practice includes partnering with clients on compliance with comprehensive privacy…

Ariel Dukes is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity Practice Group.

Ariel counsels clients on data privacy, cybersecurity, and artificial intelligence. Her practice includes partnering with clients on compliance with comprehensive privacy laws, FTC and consumer protection laws and guidance, and laws governing the handling of health-related data. Additionally, Ariel routinely counsels clients on drafting and negotiating privacy terms with vendors and third parties, developing privacy notices and consent forms, and responding to regulatory inquiries regarding privacy and cybersecurity topics. Ariel also advises clients on trends in artificial intelligence regulations and helps design governance programs for the development and deployment of artificial intelligence technologies across a number of industries.

Photo of Natalie Maas Natalie Maas

Natalie is an associate in the firm’s San Francisco office, where she is a member of the Food, Drug, and Device, and Data Privacy and Cybersecurity Practice Groups. She advises pharmaceutical, biotechnology, medical device, and food companies on a broad range of regulatory…

Natalie is an associate in the firm’s San Francisco office, where she is a member of the Food, Drug, and Device, and Data Privacy and Cybersecurity Practice Groups. She advises pharmaceutical, biotechnology, medical device, and food companies on a broad range of regulatory and compliance issues.

Natalie also maintains an active pro bono practice, with a particular focus on health care and reproductive rights.

Photo of Rosie Moss Rosie Moss

Rosie Moss is an associate in the firm’s Washington, DC office. She is a member of the Data Privacy and Cybersecurity Practice Group and the Technology and Communications Regulation Practice Group.

Rosie advises clients on a wide range of data privacy and technology…

Rosie Moss is an associate in the firm’s Washington, DC office. She is a member of the Data Privacy and Cybersecurity Practice Group and the Technology and Communications Regulation Practice Group.

Rosie advises clients on a wide range of data privacy and technology regulatory issues, including emerging artificial intelligence compliance matters. She assists clients in complying with federal and state privacy laws and Federal Communications Commission (FCC) regulations. Rosie also maintains an active pro bono practice.