The agreement calls $20.5 million the Maximum Cash Payment, but the label is easy to misunderstand. It is not reserved solely for payments to people who used CVS digital services. The same ceiling covers approved claims, settlement administration, attorneys’ fees and costs, and service awards.

The agreement defines the underlying claims as arising from CVS’s alleged disclosure of health or private information, personal information, browsing data, identifiers, or other data to Criteo and other technology providers or third parties. It says the alleged disclosures occurred through technology embedded on CVS digital properties.

Claimants seeking up to $10 must submit reasonable documentation showing an interaction with a CVS digital property before preliminary approval. The agreement gives examples such as browser history, dated screenshots, and email receipts for online purchases. A personal statement alone does not count as reasonable documentation, although it may explain other records.

A person who does not provide those records may seek up to $5. A documentation-based claim that is not cured can be treated as the lower payment option. Both amounts can be reduced proportionally if the total settlement obligations exceed the $20.5 million cap after approved deductions.

Before assessing whether claims fit under the cap, the agreement deducts administration expenses and any court-approved attorneys’ fees, costs, and service awards. Class counsel may seek fees and costs of up to 37.5% of the cap. That request could reach $7,687,500, although the court may award less.

The agreement is not contingent on the court granting the full fee request. It also provides for service awards in an amount not exceeding $2,500, subject to approval.

Uncashed checks follow the same direction. Checks would remain valid for 180 days, after which undistributed money would return to the defendants.

The settlement class includes all living individuals who accessed CVS digital properties in the United States before preliminary approval, subject to listed exclusions. The agreement does not require a person to have received notice, submitted a claim, or collected money before becoming bound. The critical step is whether that person remains in the class rather than opting out.

The released claims include known and unknown claims relating to the causes of action, the use of any technology on CVS digital properties, or any interactions with any of the CVS Digital Properties. The release protects CVS, Criteo, their related entities, and listed technology providers including Medallia, Quantum Metric, Adobe, Braze, and Branch Metrics.

CVS and Criteo have a unilateral termination option if more than 5,000 class members submit valid and timely opt-out requests. Because the agreement provides no estimate of the class population, it is not possible to calculate what fraction of the class that threshold represents.

A class member who wants the court to reject or change the settlement must remain in the class. The agreement requires an objection to be filed with the court and mailed to class counsel, defense counsel, and the settlement administrator.

The objector must provide grounds and known legal support. If represented, the filing must identify counsel, disclose counsel’s class action objections during the previous five years, and include relevant court orders. The objector must also state whether artificial intelligence was used to prepare the objection.

If preliminary approval is granted, the administrator would begin notice within 45 days. The opt-out and objection deadlines would fall 30 days before the scheduled final approval hearing. The claim deadline would fall 15 days before that hearing.

The agreement contains formulas for those deadlines, not the calendar dates themselves. Those dates must come from a future court order and approved notice.

The defendants expressly deny the complaint’s allegations, deny violating any law, and deny acting improperly. They say they entered the agreement to avoid the expense, burden, disruption, and uncertainty of further litigation.

The plaintiffs do not concede that their claims lack merit. Their lawyers state that they investigated the facts and law, considered the risks of continued litigation, and concluded that the settlement is fair and in the class’s best interests.

No merits ruling appears in the supplied material. Court approval of a settlement would determine whether the negotiated deal is fair enough to bind the class. It would not, by itself, establish that the alleged data disclosure occurred.

The settlement consideration section lists cash payments, administration costs, attorneys’ fees and costs, and service awards. The supplied agreement does not describe a requirement that CVS or Criteo remove specific technology, change data practices, submit to an audit, delete previously collected data, or provide a new privacy control.

That does not establish that no operational changes occurred elsewhere. It means the settlement document provided here does not make such a change part of the negotiated class relief.

The proposed CVS settlement puts a large number at the top of the page, but the agreement divides that number among claim payments, administration, fees, costs, and awards. It limits payments to one per household, permits proportional reductions, and sends residual money back to the defendants.

In return, the deal seeks finality across a class whose size is not disclosed and a release that reaches technology use and interactions throughout CVS digital properties. Whether that is a fair exchange is the question the court will eventually have to answer.