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Document Type

Article

Language

English (en)

Publication Date

2025

Publication Title

Proceedings of the 2025 CHI Conference on Human Factors in Computing Systems

Abstract

To protect consumer privacy, the California Consumer Privacy Act (CCPA) mandates that businesses provide consumers with a straightforward way to opt out of the sale and sharing of their personal information. However, the control that businesses enjoy over the opt-out process allows them to impose hurdles on consumers aiming to opt out, including by employing dark patterns. Motivated by the enactment of the California Privacy Rights Act (CPRA), which strengthens the CCPA and explicitly forbids certain dark patterns in the opt-out process, we investigate how dark patterns are used in opt-out processes and assess their compliance with CCPA regulations. Our research reveals that websites employ a variety of dark patterns. Some of these patterns are explicitly prohibited under the CCPA; others evidently take advantage of legal loopholes. Despite the initial efforts to restrict dark patterns by policymakers, there is more work to be done.

Keywords

CCPA, California Consumer Privacy Act, Opt-Out, Dark Patterns, Privacy Law, Consumer Protection

Publication Citation

Van Hong Tran, Aarushi Mehrotra, Ranya Sharma, Marshini Chetty, Nick Feamster, Jens Frankenreiter, & Lior Strahilevitz, Dark Patterns in the Opt-Out Process and Compliance with the California Consumer Privacy Act (CCPA), Proc. 2025 CHI Conf. Hum. Factors Computing Sys. (2025)

Comments

The full text is also available online at https://dl.acm.org/doi/10.1145/3706598.3714138#

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