American Honda

American Honda’s $632,500 CPPA fine: when opting out is harder than opting in (2025)

Regulator: CalPrivacy (CPPA)Last updated

At a glance

Brought by
Regulator: CalPrivacy (CPPA)Regulator
Company
American Honda
Sector
Automotive
Law
CCPA (California)
Amount
$632,500
Date
Settled Mar 12, 2025
Status
Settled

Summary

In March 2025, CalPrivacy (the California Privacy Protection Agency) fined American Honda $632,500 for making opt-out harder than opt-in, over-verifying privacy requests, and sharing data without the contract terms the CCPA requires.

What happened

Over-verifying meant Honda asked for more personal information than the law permits before it would process a privacy request. The data it shared without the required contract terms went to ad-tech vendors.

The mechanism

The core issue was the choice architecture of the cookie and privacy tool. According to the order, consumers could accept all cookies with one click, but opting out of the cookies required at least two clicks. Rights that should need little or no identity check were gated behind excessive verification.

A fair banner gives Accept all and Reject all equal weight. A dark pattern hides Reject behind extra steps.

Why it was preventable

The number of steps to opt out versus opt in is something you can measure directly by walking both paths. So is whether a tool demands more than it should.

In the regulator’s words

Michael Macko, Head of the CPPA’s Enforcement Division, said: “The remedy should fit the problem behavior.”

Timeline

  1. Mar 12, 2025settled.

Source

privacy.ca.gov.

privacy.ca.gov

Questions

Who fined American Honda?

CalPrivacy, the California Privacy Protection Agency (CPPA), in March 2025. The CPPA is a separate body from the California Attorney General.

What did Honda do wrong?

It made opting out of data sharing take more steps than opting in, which breaks the CCPA’s symmetry-in-choice rule, asked for more personal information than needed to process a request, and shared data without required contract terms.

How is “symmetry in choice” tested?

By walking both paths and counting the steps. If opting out takes more effort than opting in, the choice is not symmetrical.

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