Compliance Framework · Stage 4 of 5

Disclose: Customer Explanations Derived from the Rule That Set the Price

Write the customer explanation from the rule that set the price.

Last verified Oct 6, 2026 · Not legal advice

The explanation a customer sees should describe the logic that actually produced the price. Because the segment rule set the price, the same record can produce a short disclosure or the full basis.

How Detailed Does a Price Disclosure Need to Be?

At the point of pricing“Member price, based on your purchase history with us.”
More detail“This offer applies to customers with at least six purchases in the previous 12 months who recently used a coupon. Only purchase history on this account was used.”
On requestThe full rule, data sources, treatment, effective dates and version, with ways to correct data, request human review or opt out of profiling

Why Do Specific Reasons Work Better for Customers?

Generic labels barely improved consumer understanding in lab tests. A segment rule supplies the FTC’s “basis” element in one specific, verifiable sentence, and tells the customer what would change it.

Can AI Write Our Disclosure Wording?

Language models write fluent explanations that can drift from the real logic. Checking drafted wording against the structured segment record is a simple control.

Whether any wording satisfies a legal requirement is a question for counsel.

Which Laws Apply to Stage 4: Disclose?

  • FTC Proposed Policy StatementFederal (FTC)

    FTC File No. P034101 · FTC Act § 5

    The FTC’s proposed policy statement, issued August 19, 2026, says businesses that use personal data to set an individual’s price should clearly disclose that the price is personalized, the basis for it and the types of data used, where consumers reasonably expect a common price.

    PendingAug 19, 2026
  • NY Algorithmic Pricing Disclosure ActNew York

    N.Y. Gen. Bus. Law § 349-a

    Since November 10, 2025, businesses that set prices with an algorithm using a New York consumer’s personal data must show, next to the price: “THIS PRICE WAS SET BY AN ALGORITHM USING YOUR PERSONAL DATA.” The Attorney General enforces it, with penalties up to $1,000 per violation.

    In ForceNov 10, 2025
  • NY One Fair Price ActNew York

    S8623B / A9349B

    New York’s One Fair Price Act would ban surveillance pricing, meaning prices set wholly or partly by an algorithm that uses personal data to charge different customers different prices.

    PendingDec 31, 2026
  • Connecticut P.A. 26-64Connecticut

    SB 4 · Public Act 26-64, § 11

    Since October 1, 2026, Connecticut bars retail sellers and third-party delivery services from surveillance pricing: setting a customized price for a consumer based on personal data collected through technology.

    In ForceOct 1, 2026
  • New Jersey Fair Price Protection ActNew Jersey

    S3612 / A4085

    From August 1, 2027, New Jersey bans surveillance pricing for groceries and household goods under its Consumer Fraud Act.

    EnactedAug 1, 2027