Opt-out friction, asymmetric UI, authorized agents, vendor contracts
Honda required consumers to verify their identity and provide excessive personal information before exercising opt-out and right-to-limit rights, deployed an asymmetric privacy management tool (opting in was easier than opting out), made it difficult for consumers to use authorized agents to exercise rights on their behalf, and shared personal information with ad tech companies without contracts containing the required privacy protections. The order quantifies the number of affected consumers and applies fines on a per-violation basis, establishing that the per-violation fine structure is operative.
Honda must consult a UX designer to evaluate its privacy request submission methods, certify compliance, and train employees. The Ford enforcement (March 2026) arose from the same connected vehicle manufacturer review program.