01. Marketing co-op data sharing as 'sale'
Sharing customer information with marketing cooperatives in exchange for advertising leads constituted a sale under CCPA.
DoorDash: $375K California privacy settlement
California's $375,000 DoorDash settlement targeted the sale of customer information through marketing data cooperatives — and DoorDash's failure to provide the right opt-out path or service-provider contracts.
- CCPA
- California
Last updated
Enforcement snapshot
- Amount
- $375K
- Regulator
- California Attorney General
- Sector
- Food delivery
- Published
- February 2024
Technical failure modes
What failed
02. No opt-out for cooperative sharing
Customers had no clear way to opt out of marketing-cooperative data exchanges.
03. Missing service-provider terms
Contracts with cooperative members lacked the use-restriction language CCPA requires to convert a sale into a service-provider relationship.
04. Disclosure inadequate
Privacy notices did not name the cooperative practice or its purpose with the specificity CCPA expects.
Remediation path
What Ketch would help validate
More enforcement analysis
Other settlements with the same failure modes
Next step
Do not wait for a demand letter to find the gap
DoorDash is the marketing-cooperative case. Sharing customer data with cooperatives in exchange for advertising value counts as a 'sale' under CCPA. Without the right contracts and opt-out plumbing, even routine martech moves expose brands to enforcement.
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