{"page":"/blog/loyalty-data-advertising-consent","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Use","US (California as the strictest common case)","EU","UK"],"rows":[["1. Own marketing, owned channels","Notice; incentive opt-in if data earns rewards; email and SMS rules","Legitimate interest possible (Recital 47) with Art. 21 objection; Art. 13(2) soft opt-in for email","Art. 6(11)(a) example of legitimate interest; PECR reg. 22 soft opt-in"],["2. Onsite ads for other brands","Notice; opt-out of targeted advertising where the state grants it","Lawful basis with balancing or consent; Art. 5(3) consent if device data is read","Same structure as EU; PECR reg. 6 for device data"],["3. Offsite audiences","Usually \"sale\" or \"sharing\": notice, opt-out, honour opt-out signals; opt-in for sensitive data","Consent is the common basis in practice; Art. 5(3) consent for device IDs","Consent common in practice; PECR reg. 6"],["4. Clean room collaboration","Depends on whether row-level data reaches the brand; contracts","Controller roles and Art. 26 if joint; aggregate outputs","Same as EU"],["Sensitive or health inferences","Opt-in in most states; MHMDA consent and authorization in Washington","Art. 9 explicit consent or exclusion","Art. 9 UK GDPR"]],"sourceUrls":[[],[],[],[],[]]}