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1、Manipulative Design Patternsin Opt-Out ProcessesGood LuckOpting OutMay 2026ABOUT EPICThe Electronic Privacy Information Center(EPIC)is a 501(c)(3)non-profit public interest research advocacy center in Washington,D.C.EPIC was established in 1994 to focus public attention on emerging privacy and civil

2、 liberties issues.EPIC advocates for privacy,algorithmic fairness,and government accountability.Learn more at epic.org.AUTHORSCaroline Kraczon,EPIC CounselJustin Sherman,EPIC Scholar In ResidenceACKNOWLEDGEMENTS The authors would like to thank EPIC Counsel Kara Williams,Senior Counsel Sara Geoghegan

3、,and Deputy Director and Policy Director Caitriona Fitzgerald for their comments on this report,as well as Deputy Director and Director of Enforcement John Davisson for his support throughout this research effort.FUNDING STATEMENTThis project was supported by funding from the Foundation for Public S

4、ervice(FPS)a 501(c)(3)fiscally sponsored project of Global Impact.HOW TO SUPPORT EPIC EPICs mission is to secure the fundamental right to privacy in the digital age for all people through advocacy,research,and litigation.As a fully independent non-profit,EPIC does not accept corporate or government

5、sponsorships.We need your support.Please consider donating online at epic.org/donate.To learn about about additional ways to support EPIC,such as donor-advised funds and qualified charitable donations,visit epic.org/support-epic/.Anonymous donations are accepted.TABLE OF CONTENTSIntroduction.4Litera

6、ture Summary.8Legal Summary.14Methodology.17Analysis.23Overall Trends(Not Necessarily Manipulative).23Manipulative Design Patterns.27Failing to Provide a Clear Mechanism to Opt Out of Sale and Sharing of Personal Information.27Not Clearly Linking Opt-Out Form from Homepage and/or Privacy Policy.29Re