Garland Service Company: Critical Legal Risks in Privacy Policy & How to Fix Them | Erayaha

## When Privacy Policies Create Million-Dollar Risks: Garland Service Company Case Study

Imagine a scenario where a single ambiguous clause in your privacy policy exposes your business to regulatory fines of up to €20 million or 4% of annual revenue under GDPR. Our analysis of Garland Service Company’s (GSC) Privacy Policy reveals several such high-stakes risks—each with the potential to trigger costly litigation, regulatory penalties, or reputational damage.

1. Ambiguous Data Collection Purposes: A GDPR/CCPA Compliance Gap GSC’s policy states: “We may collect and process the following types of personal information…” but fails to specify the exact purposes for collection and use. Under GDPR (Art. 5), personal data must be collected for specified, explicit, and legitimate purposes. Vague language here can result in non-compliance, risking multi-million dollar fines and class action lawsuits in California under CCPA.

Legal Analysis

high Risk

Removed

Added

We may collect and process the following types of personal information: solely for the specific purposes outlined in this policy, in accordance with applicable privacy laws including GDPR and CCPA, and only with appropriate legal basis such as consent or legitimate business interest. The categories and purposes of data collection are detailed below.

Legal Explanation

The original clause is overly broad and fails to meet privacy law requirements for specific, lawful purposes. The revision provides clear limitations, regulatory compliance, and establishes proper legal basis for data processing.

2. Insufficient Cookie & Tracking Disclosure: Regulatory Exposure The policy says, “We may use cookies and similar tracking technologies…” but does not detail what types, their purposes, or how users can meaningfully opt out. Both GDPR and CCPA require clear, granular disclosures and opt-out mechanisms for cookies and tracking. Failure to comply can lead to regulatory investigations and fines up to $7,500 per violation under CCPA.

Legal Analysis

high Risk

Removed

Added

We may use specific types of cookies and similar tracking technologies to collectas described in this policy. Users are provided with clear information about your browsing activities on our Websiteeach type, its purpose, and a simple mechanism to opt in or out, in compliance with GDPR and CCPA requirements. You can manage your cookie preferences by adjusting your browser settings.

Legal Explanation

The original clause lacks specificity and does not provide users with meaningful choice or transparency, as required by law. The revision ensures compliance and reduces risk of regulatory fines.

3. Weak Data Security Commitments: Legal & Financial Liability GSC’s statement that it takes “reasonable steps to protect your personal information” is vague and unenforceable. Modern data protection laws (GDPR Art. 32, CCPA §1798.150) require demonstrable technical and organizational measures. Without specificity, GSC risks liability for data breaches, which can cost $4.45 million on average (IBM Cost of a Data Breach Report 2023).

Legal Analysis

high Risk

Removed

Added

We take reasonable stepsimplement appropriate technical and organizational measures, such as encryption, access controls, and regular security assessments, to protect your personal information from unauthorized access, disclosure, alteration, or destructionas required by GDPR Article 32 and CCPA. However, please be aware thatWhile no method of internet transmission is entirely secure, and we cannot guarantee the absoluteregularly review and update our security of your dataprotocols to address emerging threats.

Legal Explanation

The original clause is vague and does not specify the security measures required by law. The revision provides concrete examples and references legal standards, improving enforceability and reducing liability.

4. Unclear User Rights & Procedures: Litigation and Complaint Risk While GSC acknowledges user rights, the policy does not specify how users can exercise these rights, response timeframes, or appeal mechanisms. GDPR (Arts. 12-23) and CCPA mandate clear, actionable instructions and deadlines. Ambiguity here can lead to regulatory complaints, lawsuits, and reputational damage.

Legal Analysis

medium Risk

Removed

Added

You have certain rights regarding your personal information, including the right to access, correct, or delete your data. If you would like to exercise any of these rights, please contact us using the contactor restrict processing of your personal information, and to object to certain uses as provided aboveby GDPR and CCPA. Requests will be acknowledged within 10 days and fulfilled within 30 days, with instructions for appeal if dissatisfied with our response.

Legal Explanation

The original clause does not specify response timeframes or procedures, as required by law. The revision adds actionable steps, deadlines, and appeal mechanisms, reducing risk of complaints and litigation.

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Conclusion: Proactive Legal Protection is Non-Negotiable Our examination shows that even well-intentioned privacy policies can expose companies to massive financial and legal risks if not precisely drafted. Garland Service Company’s policy would benefit from targeted improvements to ensure compliance, reduce liability, and build user trust.

Ambiguous or incomplete clauses can cost millions in fines or settlements
Clear, specific language is essential for enforceability and compliance
Proactive legal review is a critical investment for any business handling personal data

Are your privacy and data security policies robust enough to withstand regulatory scrutiny?
How much risk are you willing to accept from vague or outdated legal language?
What is the cost of inaction compared to a strategic legal upgrade?

This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai’s terms of service for liability limitations.