On October 30, 2025, California Attorney General Bonta announced a $530,000 settlement related to allegations that Sling TV, an internet-based live TV service, violated the California Consumer Privacy Act (“CCPA”) and the California Unfair Competition Law. This is the first enforcement action arising from the California Department of Justice’s (“DOJ”) investigative sweep of streaming services and connected TVs, which was announced in January 2024.

The AG alleges Sling TV committed the following violations:

• Failed to Provide Easy-to-Execute Methods for Opt-Outs. The AG alleges that Sling TV’s opt-out methods on its website, on mobile, and on various devices using the app were difficult for consumers to effectuate their right to opt-out. For instance, the complaint alleges that Sling TV posted a “Your Privacy Choices” link, which directed consumers to cookie preferences, but did not provide an easy-to-execute method to exercise the opt-out right. The AG alleges that the steps to opt-out were hard to find with links embedded in text or unlabeled. When consumers located the link, the complaint alleges that consumers continued to face a burdensome process that required multiple steps to log-in and redundant information requests. Consumers using the Sling TV app had to use an additional device separate from the app to effectuate the opt-out. The complaint also alleges Sling TV failed to consider the methods by which it primarily interacts with consumers on app-based devices.
• Failed to Provide Adequate Privacy Protections for Minors Under 16. Where a business has actual knowledge that a consumer is under 16 years old, the CCPA prohibits the business from selling or sharing that minor’s personal information without the teen’s consent or a parent’s consent for users under the age of 13. A business that willfully disregards the consumer’s age is deemed to have actual knowledge of the minor’s age. Nothing in the complaint alleges that Sling TV had actual knowledge that any specific viewer was a minor under the age of 16. Rather, the complaint alleges that Sling TV knew generally that minors under 16 years old were likely using the service and that Sling TV did not age screen users or create an option for parents to designate a profile as a “kid’s profile.” Notably, nothing in the statute requires age assurance and the California Age-Appropriate Design Code Act, which would require age assurance or that businesses by default treat users as minors, is currently enjoined.

Under the terms of the voluntary settlement, which is binding on Sling TV, the company agrees to the following:

• Inform consumers if they collect personal information about consumers from third parties, whether they sell or share such information, and that they conduct cross-context behavioral advertising based on this third-party information;
• Provide consumers with an obvious “Do Not Sell or Share My Personal Information” or similar link on its homepages that does not use dark patterns;
• Provide consumers with an easy-to-find and simple to execute link for opting out;
• Stop requiring logged-in customers to fill out a webform with information already available to the business;
• Provide an opt-out mechanism that is acceptable from within the Sling TV app used on a television, such as an on-screen toggle or if not technically feasible, a QR code that links to an opt-out on a smart phone;
• Apply choices made for logged-in users across their account for all devices and browsers;
• Allow parents to designate a “kid’s profile” that defaults off the sale and sharing of personal information or cross-context behavioral advertising;
• Maintain a system for programmers to designate channels as made for children or minors, which must not display advertising that is based on or inferred from consumers’ personal information;
• Assess at least annually, and as new channels are added, whether additional channels should be designated and classified as made for children or minors;
• Delete personal information collected from or regarding users who Sling TV has actual knowledge are children or minors;
• Implement and maintain a compliance program for at least three years to assess and monitor the effectiveness of Sling TV’s opt-out methods and actions to protect children and minor privacy; and
• Pay $530,000 in civil penalties.

This is the California AG’s fifth action against entities alleged to have violated the CCPA. We summarized several past AG’s prior actions in blog posts here, here, and here. The settlement demonstrates that the AG continues to scrutinize online advertising practices and children’s privacy violations under the CCPA.