On November 21, 2025, California Attorney General Rob Bonta announced a $1.4 million settlement with Jam City, Inc. (“Jam City”), a mobile app gaming company, for alleged violations of the California Consumer Privacy Act (“CCPA”) and Unfair Competition Law (“UCL”). The Jam City settlement marks Attorney General Bonta’s sixth settlement obtained under the CCPA and reflects a continued focus on how businesses present opt-out rights mechanisms to California consumers, including minors.

The Attorney General’s complaint outlines two alleged violations of the CCPA by Jam City:

  • Lack of CCPA-Compliant Opt-Out Process.  The complaint alleged that Jam City sold or shared consumers’ personal information without providing a CCPA-compliant opt-out mechanism. The complaint alleged that 20 of Jam City’s 21 mobile apps lacked any control or setting that would allow a consumer to opt-out of the sale or sharing of their personal information. Although one app provided a “Data Privacy” control, the control did not reference the CCPA, and the complaint alleged that it was unclear whether enabling the control would halt the sale or sharing of a consumer’s personal information. Additionally, the Attorney General’s complaint alleged that Jam City’s website failed to contain an opt-out link or CCPA-compliant opt-out method.
  • Inadequate Consent from Minors Under 16.  For many of its apps, the Attorney General alleged that Jam City used an age gate to verify consumers’ ages, but Jam City failed to properly maintain the age gate for several of its games and only provided child versions for consumers who declared their age was below 13. The Attorney General alleged that, as a result, Jam City sold or shared personal information of consumers between 13 and 16 years of age without first obtaining those minors’ “affirmative authorization.”

The complaint also alleged that the acts violating the CCPA similarly violated the UCL as unlawful, unfair, or fraudulent practices constituting unfair competition. In addition to the $1.4 million fine, Jam City agreed to several remedial measures as part of the settlement. Among other topics, the settlement requires that Jam City apps that contain an age screening mechanism (1) use a neutral age-screening mechanism that does not default to an age above 16 or suggest that certain functionality will not be available to consumers under the age of 16, (2) direct all consumers who submit an age of less than 13 years old to a child version of the app that does not sell or share personal information, and (3) for consumers who identify themselves as at least 13 but under 16, Jam City must either direct them to the child version or, alternatively, obtain affirmative, opt-in consent to sell or share personal information before directing them to the non-child version. Jam City must also implement a three-year compliance program to monitor whether its opt-out procedures are effective and whether it is adequately complying with its obligations, including those related to consumers under the age of 16. The company must review its compliance program and submit a report to the Attorney General’s office on an annual basis for the next three years.

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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 Jenna Zhang Jenna Zhang

Jenna Zhang advises clients across industries on data privacy, cybersecurity, and emerging technologies. 

Jenna partners with clients to ensure their compliance with the rapidly evolving federal and state privacy and cybersecurity laws. She supports clients in designing new products and services, drafting privacy…

Jenna Zhang advises clients across industries on data privacy, cybersecurity, and emerging technologies. 

Jenna partners with clients to ensure their compliance with the rapidly evolving federal and state privacy and cybersecurity laws. She supports clients in designing new products and services, drafting privacy notices and terms of use, responding to cyber and data security incidents, and evaluating privacy and cybersecurity risks in corporate transactions. In particular, she advises clients on substantive requirements relating to children’s and student privacy, including COPPA, FERPA, age-appropriate design code laws, and social media laws.

As part of her practice, Jenna regularly represents clients in data privacy investigations and enforcement actions brought by the Federal Trade Commission and state attorneys general. She also supports clients in proactive engagement with regulators and policymakers to ensure their perspectives are heard.

Jenna also maintains an active pro bono practice with a focus on supporting families in adoptions, guardianships, and immigration matters.

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.