Settled case summary #21 — A loyalty program

An individual complained that a loyalty program shared his children's names and addresses with partner credit card companies, resulting in marketing materials being sent to the minors. The loyalty program stated it does not market to minors or share their information with partners. However, due to telephone account openings where birth dates were not mandatory, the children were not identified as minors in their profiles. This led to their information being shared for marketing purposes. The program acknowledged an overly long delay in correcting the issue, partly due to marketing lists being generated weeks in advance. The loyalty program sent an apology letter, and the mailings to the children ceased. The complaint was considered settled.