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Confirmed11 filings · 10 statesUnverified claimConfirmedEnforcedmoderate sensitivity

Merged incident · 11 filings

Totally Promotional — November 2023 breach

Clustered 11 filings across 10 jurisdictions · filing window Oct 16, 2024 → Nov 25, 2024. View entity profile → Other incidents for this victim →

⚠ 2 cross-filing discrepancies →Merge100%

Determination

Confirmed

Members

11 filings

States

Affected · reported

39,024

First → last filing

Oct 16, 2024 → Nov 25, 2024

Merge confidence

100%

incident inc_baa8643f8eec417b · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 11 regulatory filings. The filings describe unauthorized access. Intrusion Nov 20, 2023–Oct 20, 2024, discovered Jul 10, 2024 — the first regulatory filing landed 98 days later (flagged late). 39,024 individuals reported across the linked filings. Data reported: PCI, Financial account, Identity (basic), and 1 more. Notifications rolled out on a 40-day schedule across 11 filings beginning Oct 16, 2024. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental

Notification delay

98days

Discovered → first regulatory filing

Discovery variance

65days

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 · 33dOregon✓ OR AG ≤45dSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline

No cross-filing comparison data available for this incident.

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