France: National Commission on Informatics and Liberty adopted guidance on application of right to data portability in loyalty programs

On 14 October 2025, the French National Commission on Informatics and Liberty (CNIL) adopted guidance regarding the application of the right to data portability to loyalty programs, following inquiries from the distribution sector. The CNIL specified that Global Trade Item Number (GTIN) barcodes of purchased products, when linked to customer identification information, constitute portable data that must be transmitted upon request. Similarly, the financial amount of promotions obtained through a loyalty program, if attributable to the beneficiary customer, is also considered portable. Conversely, the methodology used to calculate and generate targeted promotions is not classified as portable data.