On January 8, 2026, the California Privacy Protection Agency (“CalPrivacy”) announced an enforcement action against Rickenbacher Data LLC (d/b/a “Datamasters”), an information reseller, for failing to register as a data broker under the California Delete Act.  Datamasters agreed to pay a $45,000 administrative fine, among other remedial measures.  In November, CalPrivacy launched a Data Broker Enforcement Strike Force within its enforcement division to investigate violations of the law in the data broker industry, which builds upon a 2024 investigative sweep into data broker compliance.

Datamasters Enforcement Action

CalPrivacy alleged that Datamasters bought and resold personal information for targeted advertising based on characteristics such as health conditions, ethnicity, age, and purchasing behaviors without registering as a data broker.  Although the order states that Datamasters told CalPrivacy it did not do business or take orders in California, CalPrivacy “perceiv[ed] an inconsistency” between these statements and representations on the company’s website.  Additionally, Datamasters represented to CalPrivacy that it received personal information of Californians but asserted that it rejected requests from customers to purchase California-specific personal information.  However, Datamasters allowed customers to purchase nationwide lists, and efforts to screen those lists for California consumers were “imperfect.”  CalPrivacy alleged that Datamasters lacked sufficient written policies and procedures to ensure compliance with the California Delete Act. In addition to paying a $45,000 administrative fine, Datamasters agreed to further remedial measures, such as permanent deletion of previously purchased personal information of California residents and the adoption and maintenance of written policies and procedures for a period of five years.  Datamasters also agreed to include clear disclosures on its website and contact forms stating that it does not buy or sell Californians’ data and to maintain records of certain transactions involving Californians’ data for five years, making those records available to CalPrivacy upon request.

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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 Kyle Falkner Kyle Falkner

Kyle Falkner is an associate in the firm’s Washington, DC office. He is a member of the Data Privacy and Cybersecurity Practice Group and the Health Care Practice Group.

Kyle advises clients on a wide range of data privacy, technology, and health care…

Kyle Falkner is an associate in the firm’s Washington, DC office. He is a member of the Data Privacy and Cybersecurity Practice Group and the Health Care Practice Group.

Kyle advises clients on a wide range of data privacy, technology, and health care issues. He assists clients in complying with U.S. state and federal privacy laws as well as federal health care laws and regulations.

Kyle also maintains an active pro bono practice focused on supporting international human rights initiatives and assisting small businesses and non-profits with data privacy compliance.