Thomas (Tom) C. Bell

Thomas (Tom) C. Bell

Perkins Coie

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Latest Publications


Buried in the Fine Print—The FTC Addresses Prior Express Consent Under the TSR

In a July 14, 2015 letter to PayPal, the FTC indicated that consent language buried within a “lengthy user agreement” does not satisfy the requirement under the Telemarketing Sales Rule (TSR) that companies obtain prior...more

8/12/2015 - FTC PayPal Prior Express Consent Robocalling TCPA Telemarketing Telemarketing Sales Rule User Agreements

FTC Ramps Up Scrutiny of Retail Location Analytics

To improve customer experience and understand customers’ movements and interactions on their premises, retailers, hotels and other brick-and-mortar businesses increasingly use signals from mobile devices to observe their...more

5/11/2015 - Data Analytics Data Collection FTC Mobile Devices Persistent Identifiers Popular Privacy Policy Retailers Startups Technology Wi-Fi Hotspot

Top 12 Ways Retailers Can Address Privacy Issues This Holiday Season

In this installment of “Perkins Coie Wrapping Papers,” we take inspiration from “The Twelve Days of Christmas” to provide an overview of the top twelve privacy and data security issues retailers should consider as the year...more

12/12/2014 - Data Protection Holidays Internet Retailers Personally Identifiable Information Retailers TCPA Year-End Planning

Retailers Beware: Massachusetts Court Restricts Ability To Collect ZIP Codes At Point Of Sale

The Supreme Judicial Court of Massachusetts recently held that collecting a consumer's ZIP code at the point of sale may violate Massachusetts General Laws Chapter 93, Section 105(a) (Section 105(a)), which restricts the...more

3/19/2013 - Credit Cards Data Collection Personally Identifiable Information Retailers ZIP Codes

The Retail Point Of Sale Goes Mobile

Mobile point-of-sale payment terminals have experienced explosive growth over the past year. Unlike a traditional point-of-sale terminal, a mobile terminal communicates wirelessly when processing payment cards. There are...more

12/29/2012 - Data Protection Debit and Credit Card Transactions Mobile Payments PCI Personally Identifiable Information Point of Sale Terminals Retail Market

Is Your Company's Mobile App Violating CalOPPA?

On December 6, 2012, the California attorney general filed suit against Delta Airlines for failing to provide mobile application users with adequate notice of its privacy practices. According to the complaint, the "Fly...more

12/13/2012 - Compliance Delta Airlines Kamala Harris Mobile Apps Online Privacy Protection Act Personally Identifiable Information Privacy Policy

Don't Let a Data Breach Diminish Your Retail Profits This Holiday Season

For the first time, online retail sales exceeded $1 billion on Black Friday and reached nearly $1.5 billion on Cyber Monday this year. Analysts expect this increase in e-commerce to continue, and Forrester Research estimates...more

11/30/2012 - Data Breach E-Commerce

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