Cynthia Larose

Cynthia Larose

Mintz Levin

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Latest Posts › FTC


Privacy Monday, September 28, 2015: More on US-EU Safe Harbor — what’s next?

We will be following up our post last week regarding the latest US-EU Safe Harbor decision out of Europe with further analysis both from the Mintz Privacy team and our international network of privacy specialists. Our...more

9/28/2015 - Advocate General Consent Data Privacy Data Protection Authority Data Security Edward Snowden EU EU Data Protection Laws European Court of Justice (ECJ) Facebook FTC International Data Transfers U.S. Commerce Department US-EU Safe Harbor Framework

Privacy Tuesday – August 24, 2015 – FTC vs. Wyndham Update

Rather than our usual Privacy Monday “bits and bytes,” we have a breaking story relating to the ongoing Wyndham/FTC saga. Today, Wyndham Worldwide Corp. lost a critical round in the Third Circuit. Anticipated since...more

8/25/2015 - Best Practices Credit Cards Cybersecurity Data Breach Data Privacy Data Security FTC FTC v Wyndham FTCA Personally Identifiable Information Section 5 Unfair or Deceptive Trade Practices Wyndham

FTC Takes Action Against Retail Tracking Start-Up Nomi Technologies

On Thursday, April 23, the FTC settled deception charges against start-up Nomi Technologies, Inc. related to Nomi’s in-store, sensor-based, tracking technology.1 This is the first FTC enforcement action against emerging...more

4/30/2015 - Corporate Counsel Data Collection Enforcement Actions FTC Mobile Devices Mobile Privacy Popular Retailers Web Tracking Young Lawyers

Cross-Device Tracking: The New World

Facebook does it. Google does it. It’s everywhere in the mobile ad ecosystem. And your smartphone does it often than you know, according to a study released on Monday by Carnegie Mellon....more

3/27/2015 - Cross-Device Data Collection Facebook FCC FTC Google Internet of Things Mobile Devices Web Tracking

Privacy Tuesday – March 2015: COPPA Refresh

On Friday, the FTC published updates to the COPPA FAQs, the Commission’s compliance guide for businesses and consumers, to address the applicability of COPPA and the Amended COPPA Rule to educational institutions and...more

3/24/2015 - COPPA Educational Institutions FTC

Privacy Tuesday - March 2015: Unpacking the Obama Administration’s Consumer Privacy Proposal

Taking another “step” toward developing comprehensive privacy legislation, the White House has released a discussion draft of the Consumer Privacy Bill of Rights Act of 2015. The draft reflects the Fair Information Practice...more

3/17/2015 - Consumer Privacy Bill of Rights Data Collection FTC Personally Identifiable Information

Cybersecurity and Privacy in State of the Union Address

As expected in his State of the Union address last night, President Obama made it very clear that cybersecurity is on his agenda for 2015. After stating that: “No foreign nation, no hacker should be able to shut down...more

1/22/2015 - Barack Obama Consumer Privacy Bill of Rights Cybersecurity FERPA FTC Personal Data Notification and Protection Act Privacy Laws State of the Union

White House Proposes National Data Breach Notification Standard

This has been a big week for cybersecurity announcements from Washington. In what the White House has called a series of “SOTU Spoilers,” President Obama announced his intention to follow through on some of the...more

1/15/2015 - Breach Notification Rule Cybersecurity FTC Obama Administration Privacy Policy Proposed Legislation

Privacy Tuesday – January 6, 2015

Welcome to the first Privacy Tuesday of 2015! We hope that you enjoyed our 12 Days of Privacy series (and if you missed it, they are all linked in the right column of the blog…). Three things that you should...more

1/6/2015 - Board of Directors C-Suite Executives Chick-Fil-A Cybersecurity Data Breach Experian FTC Hackers PHI Privacy Laws Privacy Policy SnapChat

Privacy Monday (on Tuesday….) November 2014

Sometimes the day just gets away from you ….. Here are three privacy & security things you should know for your week: 1. FTC Cites TRUSTe With Misrepresenting Practices – Fines $200,000 Apparently TRUSTe...more

11/18/2014 - Auto Manufacturers Automotive Industry Enforcement Actions FTC Misrepresentation US Department of State USPS V2V

Time to Step Up Your COPPA Compliance

The Federal Trade Commission (FTC) has made good on its promise to actively enforce the recently amended Children’s Online Privacy Protection Act (COPPA). Here is what you should know about the latest enforcement actions...more

9/26/2014 - COPPA Data Collection FTC Parental Consent Settlement Yelp

Privacy Tuesday – June 2014 #2

DC Update from Politico Morning Tech - “DATA BREACH DRAFT DELAYED – The thorny issue of FTC enforcement has slowed efforts to release a draft of Rep. Lee Terry’s data breach bill, according to sources close to the...more

6/24/2014 - Data Breach Enforcement FTC Internet Retailers Proposed Legislation Retailers

FTC Data Security Authority Confirmed, For Now: Wyndham’s Motion to Dismiss Denied

The FTC’s Claim - A New Jersey federal judge has confirmed the Federal Trade Commission’s (“FTC”) authority to regulate data security and bring claims against companies suffering data breaches due to inadequate...more

4/15/2014 - Cybersecurity Data Breach Data Protection FTC Wyndham

Stop Phoning It in on Mobile Security: What Your Business Needs to Know About the FTC’s Settlements with Fandango and Credit Karma

If you’re like most Americans, you probably think that the worst thing that Fandango, the online movie ticket service, has ever done to you is make you watch those commercials with the creepy talking paper bags before your...more

4/4/2014 - Cybersecurity Fandango FTC Mobile Devices

BREAKING NEWS: FTC Announces Major Settlement with Apple

Apple Agrees to Pay Consumers At Least $32.5 Million to Settle Complaint of Unfair Billing Related to Children’s In-App Charges - FTC Chairwoman Edith Ramirez just announced (press conference) that Apple, Inc....more

1/16/2014 - Apple Children's Products FTC Mobile Apps Unfair or Deceptive Trade Practices

Privacy Monday – January 13, 2014

These are busy times in the data privacy/security world. If Misery Loves Company, Target Has Friends - Target was not the only target of data thieves this holiday season. Reports over the weekend revealed that...more

1/14/2014 - CAN-SPAM Act Canada Cyber Attacks Cybersecurity Data Breach Data Protection FTC Privacy Laws Privacy Policy

Privacy Monday – November 18, 2013

The month of November is quickly slipping by – this is the time to be looking at the 2014 cybersecurity and data privacy goals and updates and planning ahead. Our selected bits and bytes for this Monday...more

11/19/2013 - Cybersecurity Cybersecurity Framework Data Protection FTC NIST NSA Parental Consent Privacy Laws SCOTUS Surveillance

FTC Votes 4-0 to Extend Public Comment Deadline on Two COPPA Proposals

The FTC has announced that, as a result of the recent shut down of the agency, the Commission has voted unanimously to extend the public comment periods for two recent proposals under the COPPA Rule. Specifically, the public...more

10/29/2013 - COPPA FTC Safe Harbors

Privacy Monday – October 21, 2013

Privacy tidbits and bytes for this Monday – App Developers – Put this on your calendar! Now that the US government shutdown is over, the Federal Trade Commission (FTC) has announced its participation in a workshop...more

10/21/2013 - App Developers Canada Data Protection EU FTC Mobile Privacy

Privacy Monday: October 7, 2013

Despite the government shutdown, the Supreme Court is in for the 2013-2014 session. There are a couple of privacy cases on the agenda. U.S. v. Wurie and Riley v. California - At issue: Separate appeals over...more

10/8/2013 - Cell Phones Cybersecurity Data Collection Data Protection FTC IPO Privacy Policy SCOTUS Search & Seizure Search Warrant Twitter

Guide to Compliance with the Amended COPPA Rule

What Is COPPA? •Children’s Online Privacy Protection Act, enacted by Congress in 1998 •Congress directed the Federal Trade Commission (FTC), the nation’s consumer protection agency, to issue and enforce regulations...more

6/29/2013 - Actual or Constructive Knowledge Advertising Networks COPPA FTC Geolocation Internet Service Providers (ISPs) Mobile Apps Online Platforms Online Privacy Protection Act Parental Consent Penalties Persistent Identifiers Personally Identifiable Information Photographs Safe Harbors Third-Party Liability Websites

Revised FTC Guide on ‘Red Flags’ Identity Theft Rule Published

UPDATE: The Federal Trade Commission recently issued a revised guide on the Red Flags Identity Theft Rule, designed to help businesses comply with the requirements of the Rule. Compliance with the Red Flags Rule for entities...more

6/28/2013 - Data Protection FTC Identity Theft Red Flags Rule

FTC Guidelines for Mobile Applications: New Standards for Transparency and Notification Dictate Responsibilities for All Parties...

Mobile applications allow users to direct ill-tempered birds toward the buildings of evil pigs and can operate as a tool to let you know when is the best point in a movie to excuse yourself to the nearest restroom. They are...more

3/1/2013 - Advertising Advertising Networks Data Collection FTC Mobile Apps Online Privacy Protection Act Privacy Policy Social Media

#3 in our 2013 Issues Series: Privacy of Mobile Applications

As we continue our “new year, new look” series into important privacy issues for 2013, we boldly predict...more

1/9/2013 - COPPA Data Collection Delta Airlines FTC Mobile Apps Online Privacy Protection Act Parental Consent Privacy Policy

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