FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / data-mapping-review-memo.docx
data-mapping-review-memo.docx · 1038-00010

Parties

Harkness LLP
Fieldhaven Consulting Group LLC
Cascade Retail Holdings Inc
Peakview Analytics Inc
Cascade Digital Marketplace LLC
Cascade Rewards Corp
Engagement Fieldhaven Consulting Group LLC
OnPoint Data Solutions Inc

Dates

July 14, 2025
May 19, 2025
June 6, 2025
August 15, 2025
September 30, 2025
December 15, 2025
June 2, 2025
June 16, 2025
June 4, 2025
August 4, 2025

Amounts

$3,150,000
$945,000
$3.87
$1,102,500
$18.4

Obligations

Each external recipient of Peakview-generated audience segments, targeting data, or other outputs containing or derived from consumer personal information must be subject to an appropriate contractual arrangement (service-provider, contractor, or sale/sharing agreement with opt-out pass-through)
140(ag) and (j), disclosures to these partners cannot qualify as service-provider or contractor processing and must be classified as sales or sharing
The Thornbridge data-sharing agreement must be restructured as a matter of the highest priority
The legal relationship between CDM and its third-party sellers must be clearly defined
125(b)(2), a business offering a financial incentive must notify consumers of the financial incentive and its material terms before the consumer opts in
This is a compliance gap that must be addressed in the omnibus privacy-policy drafting workstream (target: September 12, 2025)