News & Analysis as of

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

Designing for Privacy & Web Success

Originally published in Website Magazine, on January 18, 2013. It is a safe prediction for 2013 that public awareness of websites’ data privacy issues will continue to increase. In the last few years, popular websites,...more

FTC Assesses $800,000 Fine Against Mobile App Operator and Issues Mobile Privacy and Security Guidance

The Federal Trade Commission has emphasized in the past that general privacy protections in the website space apply equally to mobile services, but a new FTC Staff Report released on Friday hones in on some privacy...more

Path/FTC Settlement - Much More Than A Slap On The Wrist

On February 1, 2012, “smart journal” application provider, Path, Inc. (“Path”) agreed to settle Federal Trade Commission (“FTC”) charges that it deceived consumers and improperly collected personal information in violation of...more

Social Networking Mobile App Developer Agrees to Pay $800,000 and Implement Comprehensive Privacy Program to Settle Claims for...

On February 1, 2013, the Federal Trade Commission (FTC) announced a settlement with Path, Inc., a social networking mobile application developer. Path offers and distributes "smart journal" mobile apps, which permit users to...more

FTC Releases Guidance on Mobile Privacy Best Practices; Enters Into $800K Consent Order with Path

The FTC guidance released February 1 is Mobile Privacy Disclosures: Building Trust Through Transparency: A Federal Trade Commission Staff Report. In Mobile Privacy Disclosures, the FTC as the primary federal regulator on...more

FTC Announces New COPPA Enforcement Action & Mobile Privacy Staff Report

Authorship credit: Michael Young At a press conference this morning, outgoing FTC Chairman Jon Leibowitz announced an $800,000 settlement of its recent enforcement action against Path, the operator of a social networking...more

FTC Fines Path Mobile Social Networking App $800,000 for Privacy Breaches

The developer of the popular Path social networking app for mobile devices has agreed to settle Federal Trade Commission charges that it deceived users by collecting their personal information without their consent. As part...more

FTC Path Settlement - Text Copy of Chairman's Remarks

Full text copy of Federal Trade Commission Jon Leibowitz’s remarks on the agency’s $800,000 settlement with social networking app Path for deceiving users by collecting personal information without authorization, and by...more

Privacy Update: Complying With COPPA Under The FTC's New Children's Online Privacy Protection Rules

In December 2012, the Federal Trade Commission (FTC) issued updated rules to the Child's Online Privacy Protection Act (COPPA), which significantly expand COPPA's scope and application. COPPA, which governs the collection,...more

Privacy Alert: COPPA Amendment Impacts Apps, Ads and Social Networks

After a two-year comment process, the Federal Trade Commission adopted its long-awaited amendments to the Children's Online Privacy Protection Rule in December 2012. The amendments, which go into effect July 1, 2013,...more

FTC Updates Rule for Children’s Online Privacy Protection

The U.S. Federal Trade Commission recently updated the rule for children’s online privacy protection, expanding a business’s obligations and accountability for online data collection activities....more

FTC Announces COPPA Rule Changes

The Federal Trade Commission (FTC) published its final rule amendments today in the Federal Register updating the FTC regulations that implement the Children’s Online Privacy Protection Act (COPPA Rule)....more

Recent Privacy Developments: California AG Continues to Lead on Mobile with New Recommendations and FTC Amends COPPA

Nearly all businesses today are involved in some way in the development or distribution of mobile applications. The first part of this Client Alert highlights recent activities of the California State Attorney General to...more

#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

FTC Amends COPPA Rule and Previews Future Enforcement Policies

On December 19, 2012, the Federal Trade Commission ("FTC") adopted the first amendments to the Rule promulgated under the Children's Online Privacy Protection Act (hereinafter, "COPPA" for the Act, and "COPPA Rule" for the...more

FTC Strengthens Laws To Protect Children’s Privacy

On December 19, 2012, the Federal Trade Commission (FTC) made major changes to the Children’s Online Privacy Protection Act (COPPA) for the first time in nearly 15 years, by significantly amending the Children’s Online...more

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