The FTC Final Report: Protecting Consumer Privacy in an Era of Rapid Change

Modern marketing professionals have access to an astounding amount of information on consumers’ tastes, preferences and habits. The marketing departments at credit card companies, in particular, can track a staggering amount of information, all without a consumer’s knowledge. For example, if an individual went for a period of time without using a credit card to buy groceries, and then began to use the card again for regular grocery purchases, those facts might suggest to the credit card company that the consumer may have been experiencing some financial distress (say, job loss), but is now in a more stable situation and could be in a better position to handle more credit in the future. And, if a credit card company does not already have or track this kind of data, it can — like other marketers — obtain this information from data brokers — e.g. companies that buy and sell personal consumer information.

Please see full Alert below for further information.

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Published In: Antitrust & Trade Regulation Updates, Communications & Media Updates, Consumer Protection Updates, Privacy Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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