Julia Siripurapu

Julia Siripurapu

Mintz Levin

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Breaking News: The COPPA Enforcement Actions Are Here!

As we predicted in prior blog posts, the Federal Trade Commission has begun its vigorous enforcement of the Amended COPPA Rule. And one of the players is not a child-related site, so read on. The Commission just announced ...more

9/18/2014 - Civil Monetary Penalty COPPA Corporate Counsel Data Collection FTC Minors Mobile Apps Online Reviews Personally Identifiable Information Settlement Yelp

Do you want your under 13 kid to have a Gmail or YouTube account? Google does…..

According to recent media reports, Google is allegedly designing a Google account for children under 13 which would permit children in this age group to officially create their own Gmail account and to access a kid-friendly...more

8/25/2014 - COPPA Email FTC Google Minors Popular YouTube

Massive Data Breach Affects 4.5 Million Patients in 29 States

Community Health Systems, Inc. (the “Company”), one of the largest hospital organizations in the country, announced via a public filing (Form 8K) made yesterday with the Securities and Exchange Commission (“Report”) that the...more

8/21/2014 - Cyber Attacks Data Breach EHR HIPAA HITECH Hospitals Notice Requirements PHI

Update on Google Unauthorized Children’s In-App Purchase Class Action: THE SHOW MUST GO ON!

U.S. District Court Judge Ronald M. Whyte has issued an order granting in part and denying in part Google’s Motion to Dismiss the class action filed against the Company on ­March 7 in the U.S. District Court for the Northern...more

7/24/2014 - Children's Online Games Class Action Digital Downloads Google Google Play Store Mobile Apps Motion to Dismiss Parental Consent

COPPA Update: FTC Provides More Flexibility on Obtaining Verifiable Parental Consent

Some clarification and a bit more flexibility was forthcoming late last week from the Federal Trade Commission to help ease compliance with the “new” COPPA. In its recent update to three FAQs in Section H (Verifiable...more

7/22/2014 - App Store COPPA Credit Cards Debit Cards FTC Parental Consent

Round Two for Snapchat: Agreement with the Maryland Attorney General Settling Claims of Consumer Deception and COPPA Violations

Just a little over a month after settling charges of false promises of disappearing user messages (among other things) with the Federal Trade Commission (“FTC”), mobile app developer Snapchat, Inc. (“Snapchat” or “Company”)...more

6/19/2014 - COPPA FTC Marketing Mobile Apps SnapChat Unfair or Deceptive Trade Practices

SaaS, PaaS and the Cloud? Part 3: Think Before You Float

You’ve heard over and over about the benefits of moving to the cloud, and you’re ready (or not quite ready but being pressured) to move technology to the cloud (or other hosted services model). Now what? There are so many...more

5/24/2014 - Cloud Computing Cloud-Based Services Technology Contracts

Software Audits: Strategies for Licensees

Audits Have Become More Common - If you have received a software audit request from your software vendor or one of the industry trade groups representing software publishers, such as the Software & Information Industry...more

5/8/2014 - Audits Client Access Licenses License Agreements Software Software Developers

FTC Updates COPPA FAQs to Address Education Space

The FTC has just 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 businesses...more

4/25/2014 - COPPA Data Protection FTC Public Schools Students

State Data Security Breach Notification Laws

The general definition of “personal information” or “PI” used in the majority of statutes is: An individual’s first name or first initial and last name plus one or more of following data elements: (i) Social Security number,...more

4/24/2014 - Breach Notification Rule Data Breach Data Protection

Demystifying the SOC Reports: What are they, what do they cover, and which one(s) do you need?

If you are an IT sourcing professional or an attorney negotiating IT agreements, you have probably encountered the terms AT 101, SSAE No. 16, SOC, SOC1SM, SOC2SM and SOC3SM. These are terms that are well understood by...more

4/7/2014 - AICPA Cybersecurity Security Technology

Online Protection for Children: Delaware following California?

Delaware state representative Darryl Scott recently introduced the Child Online Protection Act (House Bill 261 or the “Bill”), to the state’s House of Representatives. If passed, the Bill would: (1) prohibit the online...more

3/25/2014 - COPPA Data Protection Privacy Laws

Unauthorized Children’s In-App Purchases Round Two: Google Faces Class Action

Just two months after Apple’s settlement with the FTC over lax parental controls over children’s in-app purchases, Google takes the spotlight with claims of unauthorized children’s in-app purchases in the Google Play Store!...more

3/19/2014 - Android Apple Children's Products Class Action Free-to-Play Games Games Google Google Play Mobile Apps

“Sophisticated” Breach Exposes 300,000 Student Records at University of Maryland: 3 Questions You Should Ask

Officials at the University of Maryland (“University” or “UMD”) announced that UMD was the victim of a significant security breach that took place on Tuesday, February 18 (the “Breach” or “Incident”). The Incident,...more

2/21/2014 - Cyber Attacks Data Breach Data Protection Hackers Student Records Universities

Complaint from BBB Triggers HarperCollins COPPA-Compliance Measures

The Children’s Advertising Review Unit (CARU) announced that it has recommended that HarperCollins Publishers Ltd. (the “Company”) modify its information collection practices on its Ruby Redfort child-directed website (the...more

2/21/2014 - Better Business Bureau Compliance COPPA HarperCollins

FTC Approves Another COPPA Safe Harbor Program

The FTC has announced its unanimous approval for the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule (the “kidSAFE Seal Program”). The Commission’s decision comes after...more

2/18/2014 - COPPA FTC Safe Harbors

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

COPPA: New Year, New Requests to FTC For Investigation of Violations

As we predicted in our prior blog post reviewing the key children’s privacy developments of the past year, 2014 is turning out to be the year of enforcement of children’s privacy regulations! The first two requests for...more

1/9/2014 - Center for Digital Democracy COPPA FTC Marvel Comics Privacy Policy

COPPA: “Knowledge-Based Authentication” Method Approved by Federal Trade Commission

The FTC has announced (press release) that it has unanimously approved the knowledge-based authentication method proposed by Imperium, LLC (“Imperium”) as a COPPA-compliant method of obtaining verifiable parental consent...more

1/6/2014 - COPPA FTC Parental Consent

On the Seventh Day of Privacy, the FTC Gave to Me….

Significant compliance obligations with children’s privacy rules! Last December, the FTC gave to us the long awaited (or maybe not so much by covered entities!) final amendments to the 14-year old Children’s Online...more

12/17/2013 - COPPA Data Collection FTC Internet Personally Identifiable Information Privacy Laws

Google pays BIG to state Attorney Generals for Improper Consumer Tracking

Earlier this month, Google, Inc. (“Google” or “Company”) entered into an agreement with the Attorney Generals of 37 states and the District of Columbia, settling allegations of violation of the participating states’...more

11/25/2013 - Compliance Google Invasion of Privacy Web Tracking

Another major medical data breach in California

Or….why are health care institutions still leaving laptops containing PHI unencrypted???? The Los Angeles Times (the “Times”) reported this week the theft of two laptops from an administrative office of hospital group...more

10/24/2013 - Data Breach Data Protection Encryption Fraud Healthcare PHI

FTC Seeks Public Comment on Proposed kidSAFE COPPA Safe Harbor Program

In a Federal Register notice to be published shortly, the FTC is seeking public comment on the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule. This provision enables...more

9/19/2013 - COPPA FTC Public Comment Safe Harbors Self-Regulatory Organizations

FTC Invites You to Comment on Another COPPA Verifiable Parental Consent Method

The FTC has announced that it is seeking public comment on a second verifiable consent method proposed under the Voluntary Commission Approval Process provision of the COPPA Rule. The proponent is Imperium, LLC (“Imperium”),...more

9/11/2013 - Consent COPPA FTC Parental Consent Verification Requirements

You Can Have a Say on a New Mechanism for Obtaining Verifiable Parental Consent under the COPPA Rule

Yesterday, the FTC published a Federal Register notice requesting public comment on the first new method for obtaining verifiable parental consent submitted for FTC approval by AssertID, Inc under the Voluntary Commission...more

8/22/2013 - COPPA FTC Parental Consent

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