News & Analysis as of

The States Also Rise: Recent Settlements Illustrate Potential Pitfalls Regarding Children’s Privacy Laws

Earlier this summer, we highlighted a settlement where the FTC proposed its largest fine to date under the Children’s Online Privacy Protection Act (COPPA) against software maker InMobi. The InMobi settlement attracted...more

I accept!

So, you’re ready to launch your new online business or mobile app. The website looks great, and the app tile has an elegant, simple design that’s sure to stand out on phone and tablet screens. Missing anything? Oh, yeah, that...more

Recent FTC Consent Decree with InMobi for Unlawful Geolocational Tracking Provides Insight for App Developers

Recently in United States v. InMobi Pte Ltd., the Federal Trade Commission (FTC) set a new standard for geolocational tracking. The FTC told app developers and app marketers one simple rule: honor consumers location privacy...more

Self-Regulatory Actions Signal Warning for Mobile Apps that Allow Third Parties to Collect Information for Interest-Based...

Recent actions against two prominent mobile app developers serve as a warning for companies that authorize third parties to collect and use information over time for advertising in mobile apps (known as interest-based...more

Mobile Advertising Company Settles FTC Charges It Tracked Consumers’ Locations Without Permission

InMobi, a Singapore-based mobile advertising company that allegedly tracked the locations of hundreds of millions of consumers – including children – without consent, will pay $950,000 in civil penalties and implement a...more

Going Geo-Loco: FTC Settles with Mobile Ad Network over Geolocation Collection

The FTC announced a settlement on Wednesday with mobile advertising company, InMobi Pte Ltd., concerning allegations that the company deceptively tracked the geolocation of hundreds of millions of unknowing consumers,...more

Children's Privacy Online: The Interplay Between Mobile Applications and the Children's Online Privacy Protection Act

The activities of children on the internet, whether via computers, smart phones, or tablets, have grown exponentially in recent history. As internet access for children increased, parents began losing control of the amount...more

Mobile Applications that Track User Information Have the FTC’s Attention

Similar to website browsers, many mobile applications collect a variety of information from the user, including, the user’s identity, usage history, past log-ins, and location. This enables the application to provide various...more

Two mobile app developers collect persistent identifiers and pay out $360,000 in fines for COPPA violations

LAI Systems, LLC (LAI) and Retro Dreamer agreed to pay civil penalties of a combined $360,000 to settle charges issued by the Federal Trade Commission (FTC) that they violated the Children’s Online Privacy Protection Act...more

FTC Takes Action against App Developers on COPPA Allegations Involving Persistent Identifiers

The FTC has announced enforcement actions against two app developers that allegedly violated the Children’s Online Privacy Protection Act (COPPA) by using persistent identifiers to serve advertising to children. The...more

The FTC Won’t Let Them Be: Enforcement Action Brought Against App Developers for Violation of Children’s Privacy Law Presents New...

In a recent show of force—which some believe is the tip of the iceberg—the Federal Trade Commission (FTC) brought an enforcement action against two mobile application (app) developers for violating the Children’s Online...more

Does Your Website Privacy Policy Need Some Love?

Everyone does it, especially startups. You need a privacy policy for your website, and your legal budget is limited. Hop onto Facebook (or Google, or Amazon) — cut, paste and voilà! — your startup has a shiny new privacy...more

Advertising Law - September 2015 #2

FTC Reviews Kids’ Apps for Privacy Progress - Three years after conducting a survey on apps directed to children, the Federal Trade Commission’s Office of Technology Research and Investigation decided to check back with...more

Status Updates - December 2014

Yik Yak arrests. For several months now we at Socially Aware have been writing about how college students have been using the purportedly anonymous messaging app Yik Yak to communicate deeply offensive remarks and threats of...more

Caution: Your Mobile App May Unintentionally Violate COPPA

As online activity shifts to mobile devices, regulators are watching. Last week, Yelp agreed to settle a claim with the FTC for $450,000 for its alleged violations of the Children’s Online Privacy Protection Act (COPPA). As...more

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

COPPA’s “Safe Harbor” Grows with FTC’s Approval of iKeepSafe’s Self-Regulating Framework

The Federal Trade Commission (FTC) has announced that it approved iKeepSafe’s Safe Harbor Program application, allowing the company’s self-regulating framework to serve as a safe harbor under the Children’s Online Privacy...more

On the Eighth Day of Privacy, my Mobile Apps Know Everything About Me . . .

Of all the “Days of Privacy” looking forward to 2014, we believe that the issues surrounding mobile applications and privacy will see some of the most intense regulatory focus …. read on, and be prepared…....more

Advertising Law -- May 31, 2013

A Friendly Reminder from the FTC: You May Be in Trouble - Continuing the countdown to the effective date of the amended Children’s Online Privacy Protection Act Rule, the Federal Trade Commission sent “educational...more

Selected Highlights from the FTC's COPPA FAQs

The FTC posted on its website an updated version of its COPPA FAQs. (The FTC amended its COPPA Rule in December 2012, which we summarized in this Alert.) The deadline for complying with the amended COPPA Rule is July 1, 2013....more

Privacy Regulators Take to the Web in Search of Deficient Privacy Policies

Regulators have historically taken a reactive approach to privacy and information security issues related to websites and mobile apps, often waiting to take action until a potential violation has been brought to their...more

FTC Serves Notice on App Developers About Children’s Privacy

The Federal Trade Commission has made it quite clear that it is serious about advising mobile app developers that the rules of the road will be changing very soon. Since 2011, the Commission has been working to update the...more

Advertising Law -- Feb 21, 2013

In This Issue: Neutrogena Escapes Class Certification; It's Not "Hip" to Steal Contact Info; Leibowitz Leaves the FTC—Who Will Take His Place?; A Court Ruling Wouldn't Be Kosher; California Supreme Court: Some Online...more

Advertising Law -- Feb 15, 2013

In This Issue: The FTC and the Mobile Ecosystem: Enforcement Action, Report, and Educational Materials Released; Size Really Does Matter – At Least for Subway Sandwiches; Will Maryland Be the Next California?; CARU...more

The FTC and California’s Attorney General Recommend Detailed New Privacy Practices and Disclosures for Entities Operating in the...

The Federal Trade Commission (FTC) and California Attorney General’s office each recently issued detailed guidance for providers of mobile platforms, apps, ad networks, and their trade associations....more

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