The CHEQ-Up Volume 4 | More fines. More signals. Less room for error.
Jamie Vinkle
|Privacy & Compliance | December 16, 2025
Last year proved that regulators could move faster. This year is proving something sharper:
- Enforcement is no longer concentrated at the top of the market. It is broadening. Deepening. Normalizing.
- Not just Big Tech. Retail chains. Health publishers. Mobile gaming networks. Ticketing platforms used every day.
- And with every new case the same theme keeps returning. You cannot defend what you cannot see. You cannot prove compliance without records to support it.
Below we break down five recent penalties and what they tell us about where privacy is heading.
Healthline | CCPA | $1.55M
Case summary:
One of the largest CCPA settlements yet, centered around sensitive health-related browsing data and consent mechanics.
What investigators focused on:
• How user health data was captured and used
• Whether consent was explicit, informed and trackable
• Proof of opt-out enforcement beyond policy language
Why it matters:
• Written policy alone wasn’t enough
• Regulators requested evidence of real-world tracking behaviour
Signal to industry:
Consent logs and event-level proof are now the expectation, not a courtesy.
Tractor Supply | CCPA | $1.35M
Case summary:
Retail brand penalized for improper data sharing tied to digital advertising activity.
What investigators focused on:
• Sharing of user data for marketing and retargeting
• Transparency and availability of opt-out choices
• How signals moved across advertising partners
Why it matters:
• Enforcement has clearly expanded beyond digital-native tech companies
• Any brand operating personalization or paid media is now in scope
Signal to industry:
Compliance is no longer a category issue. It is operational everywhere.
JamCity | CCPA Settlement
Case summary:
Mobile game developer investigated for data handling and user rights execution across ad-driven environments.
What investigators focused on:
• Use of device identifiers and behavioural tracking
• Clarity of privacy controls inside the game experience
• Accessibility of rights requests for players
Why it matters:
• Entertainment and gaming run on scale and volume
• This ruling places direct scrutiny on growth-driven engagement models
Signal to industry:
Speed and monetization do not replace accountability. Proof still wins.
TicketCity | CTDPA Settlement
Case summary:
Connecticut privacy enforcement that signals the next phase of state-level regulatory maturity.
What investigators focused on:
• Transparency around data use and transfers
• Rights request processes under the CTDPA standard
• Alignment (or lack thereof) with similar CCPA-style controls
Why it matters:
• Enforcement is no longer California-centric
• Multi-state privacy now requires unified visibility, not disconnected policy binders
Signal to industry:
If you collect data in 3+ jurisdictions, compliance must scale beyond legal text.
Shein |GDPR | €150M
Case summary:
CNIL found unauthorized cookie placement and insufficient consent mechanisms.
What investigators focused on:
• Premature tracking before consent was valid
• Ability to withhold or withdraw consent meaningfully
• Compliance with GDPR baseline principles
Why it matters:
• No advanced breach or niche scenario
• Just missing consent at the most fundamental layer
Signal to industry:
Foundational consent remains the highest-risk failure point.
Shared Lessons Across All Five Cases
Across retail, gaming, eCommerce and everyday online brands, the same three themes continue to surface.
Evidence is the real defense
Regulators want more than intentions. They want proof. Consent records, tag behaviour, opt-out history. When those records exist, audits move quickly. When they don’t, reconstruction becomes costly and uncertain.
Investigators are more sophisticated
They no longer evaluate privacy from policy outward. They evaluate from event-data inward. What fired. When. Under what consent state. Historical records are now as important as the policy itself.
Visibility is the dividing line
Organizations with observability answer inquiries confidently. Those without it scramble. The gap between those two outcomes is widening and will continue to widen as enforcement matures.
Privacy today is less about what you intended to do and more about what you can prove happened.
Why this matters moving forward
Enforcement is expanding across sectors, across states and across company sizes. Each new case reinforces that compliance expectations are not contained to California or Europe. They are spreading horizontally through the market and vertically down into organizations that once assumed they were too small or too peripheral to draw attention.
The companies at risk are no longer just global platforms. They are businesses that look like yours. They sell, they track, they personalize, they measure conversion. And regulators understand those mechanics more fluently with every investigation.
The question going forward isn’t whether a privacy policy exists, but whether proof exists behind it. If a regulator asked what happened on a single user session weeks ago, could your team surface that within hours? Could you show consent state, tracking behaviour, third-party calls and signal flow without recreating the past from memory?
For many, that answer is still no.
For some, it is becoming yes. And those companies will move with confidence while others hesitate.
Compliance is evolving from a legal checkbox to an operational capability. Evidence, visibility and governance are no longer just safeguards. They are a competitive strength.
Want to see how CHEQ can be a perfect partner for you and your privacy program? Book a conversation with us today.
Listen to the podcast
Privacy enforcement isn’t targeting just the giants anymore. Retailers, gaming studios, publishers and everyday online brands are now seeing real fines for gaps in consent, tracking, and proof of compliance. In this episode, we break down the latest cases and the signals they send about what regulators expect — and why evidence, visibility and governance now define whether your team can move with confidence or scramble under pressure.
