California Ramps Up Enforcement of Consumer Privacy Opt-Out Rights in 2026

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The California Privacy Protection Agency (“CPPA”) and the Office of the California Attorney General (“CA AG”) have recently concluded several high profile settlements following investigations of alleged consumer difficulties in fully exercising opt-out rights that exist under the California Consumer Privacy Act (“CCPA”).1 These settlements underscore the importance that California regulators attach to consumers being able to exercise their privacy rights, and in particular the right to opt out of the sale and sharing of personal information. They also provide a useful road map as to the minimum requirements that businesses need to satisfy in managing the consumer exercise of rights to opt out of the sale and sharing of their personal information to avoid regulatory enforcement.

I. Final Judgment and Permanent Injunction with Disney stream services

In the first case, the CA AG entered into a February 2026 stipulated Final Judgment (without admission of liability) with Disney DTC, LL and ABC Enterprises Inc. resolving alleged violations of consumer opt out rights. The judgment imposed a $2.75 million civil penalty and injunctive requirements to implement opt-out methods that prevent Disney from selling or sharing consumers’ personal information. The CA AG concluded following an investigation that even when a consumer was logged in to Disney’s streaming service account and using Disney’s webform, opt out requests would only be applied to the specific streaming service the user was watching, or to the specific device the consumer was using (e.g. either a tablet, smart phone or computer, but not all). Similarly, for opt-out requests made using the Global Privacy Control (GPC), Disney limited the request to the specific device the consumer was using, even when logged into their account.

The CA AG concluded that use of the Disney opt-out toggle would “not stop selling or sharing from other devices or services connected to the consumer’s…

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