CCPA Enforcement Signals Rising Expectations for Mobile App Compliance

In an article by Nancy Libin, David L. Rice, and Apurva Dharia of Davis Wright Tremaine, the authors examine a November 21, 2025, settlement between the California Office of the Attorney General and Jam City Inc. that underscores heightened enforcement under the California Consumer Privacy Act (CCPA). The $1.4 million settlement addresses alleged failures to provide compliant opt-out mechanisms and improper sales or sharing of minors’ personal information, offering a practical compliance roadmap for digital businesses.

According to the authors, Jam City operates free-to-play mobile games supported by advertising that collect and disclose personal information, such as device identifiers, IP addresses, and gameplay data. The Attorney General alleged that most of Jam City’s apps lacked a clear and conspicuous opt-out mechanism for the sale or sharing of personal information. Even where a privacy control existed, it did not reference the CCPA or clearly explain its effect. The CA OAG further alleged that directing users to email the company was insufficient under the statute and constituted an additional violation of California’s Unfair Competition Law.

The settlement also focused on protections for minors. As described by Libin, Rice, and Dharia, Jam City used age gates and child-directed versions of its apps, but the CA OAG alleged that misconfigured age gates in several games resulted in the sale or sharing of data from users aged 13 to 15 without the required affirmative consent. These failures triggered both CCPA and unfair competition claims.

In resolving the matter, Jam City agreed to implement streamlined opt-out processes across its apps and website, ensure opt-outs apply enterprise-wide, redesign age-screening tools, require deletion of improperly collected minors’ data, and maintain a documented compliance monitoring program for three years. 

For compliance teams, the takeaway is clear: under the CCPA, regulators expect opt-out rights and age-based protections to function reliably in practice, not merely exist on paper.