HackingRetail & ConsumerRetailStolen CredentialsCapture Stored DataData ExfiltratedCustomer Data InvolvedPIIIdentity (basic)Financial accountLowContained

Totally Promotional

bd_619415059fc740b8 · schema v1 · pii pii-v1

Severity

Low

Discovered

Jul 10, 2024

Filed

Oct 16, 2024

To disclose

14 weeks

Affected · nationwide

5461 in this filing

Linked

11 filings

Confidence

64%

Full breach record for Totally Promotional →4 incidents on file

Supplemental notice from Totally Promotional regarding a data event affecting Washington residents. Unauthorized code placed on the website's payment platform captured customer payment card information between Nov 20, 2023 and Oct 20, 2024. This notice covers 1 additional resident notified on Nov 25, 2024. Total affected previously reported as 545.

J jump to incidentP pin to compareR raw source

Washington clock✗ WA AG >90d14 weeks discovery → filing

⚠ unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Incident timeline

undetected · 233 days

discovery → filing · 14 weeks / 98 days

Nov 20, 2023

Begins

Jul 10, 2024

Discovered

Oct 16, 2024

Filed

vs. sector median

+6 wks slower

This filing is one of 11 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (10) · sorted by filing gap

New Hampshire State AGbd_0863f54abe165fa02024-10-16Verified
California State AGbd_1c60e5c2cd51bcd72024-10-16Verified
Vermont State AGbd_2fda4f5e88961d5a2024-10-16Verified
Maine State AGbd_6a6e40a14b5a3f792024-10-16Candidate

Show 6 more filings ↓up to 40d gap

Oregon State AGbd_7ee71c6bd4ebf5872024-10-16Verified
Montana State AGbd_815acf1458eb700c2024-10-16Verified
Indiana State AGbd_8eead9e4b3730fb02024-10-16Verified
Massachusetts State AGbd_e25bb90ff2c3fdaf2024-10-16Verified
South Carolina State AGbd_3e6dc4f6f09659bf2024-10-17 · +1dVerified
California State AGbd_8ddbfbb06d2cdce52024-11-25 · +40dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: Totally Promotional
norm: totally promotional
Industry: Retail & Consumerllm

Discovered: Jul 10, 2024
Breach occurred: Nov 20, 2023 – Oct 20, 2024
Undetected for: 233 daysoccurrence → discovery
Materiality determined: —
Notification sent: Nov 25, 2024
Affected individuals: 546state + nationwide
Data types: PIIIdentity (basic)Financial account
Attack vector: Unauthorized Access
MITRE ATT&CK: T1190 Exploit Public-Facing ApplicationT1056 Input CaptureT1074 Data Staged
Threat actor: ExternalFinancial
Regulator citations: providing written notice of this incident to relevant state regulators
Initial access: exploit_public_facing

During the incident: Promptly commenced an investigation to better understand the nature and scope of this activity
Undertook a review of the affected data to determine what information was impacted and to whom it related
Providing written notice of this incident to relevant state regulators
Working to implement additional safeguards and training to its employees
Providing impacted individuals with guidance on how to better protect against identity theft and fraud
Changes made: Removing the code at issue
Reviewing and adjusting our existing policies and procedures to reduce the likelihood of a similar future event
Implementing additional safeguards and training to its employees
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 14 weeks(98 days from discovery to filing)
Compliance flags: WA AG >90d
Discovery-date grounding: unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 11 filings · 10 states

View merged incident ↗

New Hampshire State AGOct 16 · first

California State AGOct 16 · first

Vermont State AGOct 16 · first

Maine State AGOct 16 · first

Oregon State AGOct 16 · first

Montana State AGOct 16 · first

Indiana State AGOct 16 · first

Massachusetts State AGOct 16 · first

Washington State AGOct 16 · first · this page

South Carolina State AG+1d

California State AG+40d

Pattern: first filing Oct 16 (NH), last Nov 25 (CA) — a 40-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://agportal-s3bucket.s3.amazonaws.com/databreach/BreachA31000.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Oct 16, 2024
Raw hash: 8ed489d2aa221f198eb412bc938a4350ffa329ce1351912ab845f52a5f6b5993

Linked disclosures

Regulatory filings (10) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityTotally Promotional

Incidentdiscovered Jul 10, 2024

Stated responsePromptly commenced an investigation to better understand the nature and scope of this activity

ComplianceWA AG >90d

Extraction provenanceno artifact recorded

Source provenanceagportal-s3bucket.s3.amazonaws.com