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.