In the third CCPA enforcement action so far in 2025, California Attorney General Rob Bonta announced a large settlement with Healthline Media, publisher of the popular health information website Healthline.com. The media company has agreed to pay $1,550,000 for alleged violations of the California Consumer Privacy Act and the state’s unfair competition law.

The result of an investigation going back as far as late 2023, the state’s allegations center around Healthline’s advertising practices, with specific attention paid to opt-outs. Notably, it is the first such case involving an ad publisher.

Here’s what we learned from the California AG’s case against Healthline Media.

Three Ways to Opt-Out, But None of Them Worked

Healthline.com is a popular website that publishes articles on medical, health, and wellness topics. It uses ad tech vendors to display ads to its visitors and also shares information with ad networks about the pages that consumers visited. These practices amounted to selling and/or sharing consumers’ personal information, triggering consumers’ right to opt-out.

Accordingly, Healthline included a “Do Not Sell or Share My Personal Information” link in its website footer, configured its site to detect the Global Privacy Control signal, and offered an opt-out cookie banner where users could disallow advertising and targeting cookies. Despite all this, the AG’s investigation found that even with all three opt-outs active, the website continued to send personal information to send information to ad networks, where it was later used to serve ads to the investigator’s devices.

Healthline appears to have been depending on the U.S. Privacy String to effectuate its opt-outs. This is a standard  (now deprecated and replaced by the Global Privacy Protocol) developed by the Interactive Advertising Bureau that communicates the consumer’s opt-out to downstream recipients and instructs them to process the data as service providers. The problem is that Healthline assumed that all of its ad vendors had signed on to respect this system, but in reality many of them had not.

This should serve as a big wake-up call for businesses to make sure that their opt-outs actually work, or they may be held responsible. If they rely exclusively on the U.S. Privacy String or Global Privacy Protocol for their opt-outs, they must confirm that all of their ad vendors have agreed in writing to respect that signal. These agreements could be either a direct contract with the business or via industry frameworks such that offered by the IAB. Businesses should also consider blocking ad trackers altogether when they receive an opt-out request.

Web Pages Revealing Medical Diagnoses

Healthline has various articles with titles like “Newly Diagnosed with [a disease], Now What?”, and the fact that a consumer has visited one of these pages strongly suggests that they may have been diagnosed with whichever disease they were reading about. These page titles were shared with advertising vendors, and the state’s investigator reported receiving advertisements related to a specific disease not long after reading an article about it on Healthline.com.

The Attorney General’s Office alleged that using this personal information for advertising purposes violated the CCPA’s “purpose limitation principle.” This principle states that businesses may only use personal information for disclosed purposes that are compatible with the context in which they were collected.

Healthline’s privacy policy did disclose that it used consumers’ browsing behavior for the purpose of targeted advertising. Owing to the potentially sensitive nature of this data, however, the state determined that the disclosure was not enough, and Healthline must cease this practice.

The proposed settlement states that if, in the future, Healthline uses consumers’ sensitive personal information for advertising purposes, it must offer them a way to request to limit the use and disclosure of that data. Presumably such limitation would mean no longer using the sensitive personal information for advertising.

Contracts Matter

The California Privacy Rights Act introduced a new contract requirement to the CCPA when it went into effect in 2023. Under section 1798.100(d) of the CCPA, businesses may only disclose data to service providers, contractors, and any third parties to whom they sell or share personal information if they have a written agreement that contains the following provisions:

1. Specifying that the personal information is sold or disclosed by the business only for limited and specified purposes.
2. Obligating the third party, service provider, or contractor to comply with applicable obligations under the CCPA and obligates them to provide the same level of privacy protection as is required by the CCPA.
3. Granting the business rights to take reasonable and appropriate steps to help ensure that the third party, service provider, or contractor uses the personal information transferred in a manner consistent with the business’ CCPA obligations.
4. Requiring the third party, service provider, or contractor to notify the business if it makes a determination that it can no longer meet its CCPA obligations.
5. Granting the business the right to take reasonable and appropriate steps to stop and remediate unauthorized use of personal information.

The 100(d) contract requirements have not received much attention, but it’s clear from this case and the CPPA’s recent settlement with Honda that regulators are taking it seriously.

How TrueVault Can Help

After years of ramping up, CCPA enforcement is in full swing and the days when businesses could say “Meh, they’re not really enforcing it” are over. We should all expect to see a steady supply of these cases going forward.

California regulators aren’t giving a lot of second chances, either, and as the Healthline case demonstrates, even businesses that have made an effort to be compliant can still be hit with huge fines. The time to get compliant is now.

TrueVault offers the tools to help businesses avoid the expense and reputational damage of being targeted for privacy enforcement. These tools include:

• Attorney-designed compliance workflows.
• Tracker blocking via our consent management platform
• Research on 1000s of vendors including privacy documentation
• Regular Updates, including new state privacy laws, at no additional cost

Contact our team to see how TrueVault can help your business get compliant quickly and affordably.

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