State AGConfirmed12 filings · 11 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedmoderate sensitivity
Merged incident · 12 filings
Totally Promotional — November 2023 breach
Clustered 12 filings across 11 jurisdictions · filing window Oct 16, 2024 → Nov 25, 2024 (dated filings only). View entity profile → Other incidents for this victim →
⚠ 2 cross-filing discrepancies →Merge100%
incident inc_baa8643f8eec417b · merged by human · confidence 100%
Confirmed breach. Merged as one breach: 12 regulatory filings. The filings describe unauthorized access. Intrusion Nov 20, 2023–Oct 20, 2024, discovered Nov 20, 2023. 39,024 individuals reported across the linked filings. Data reported: Identity (basic), Financial account, PCI, and 1 more. Notifications rolled out on a 40-day schedule across 11 dated filings beginning Oct 16, 2024. Each member filing remains the legal record for its jurisdiction.
Litigation Timing
SupplementalDiscovery variance
298days
Range of discovered_at dates across filings
Filing span
40days
Time between earliest and latest filing
Not recorded for this incident
Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster.
Regulatory clocksVermont✗ VT AG >45 bdayWashington✗ WA AG >90dMaine⏱ ME AG >30d · 33dDate basis✓ Clock withheld · confirmation dateSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline
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