News & Analysis as of

Privacy Alert: Privacy Lessons Learned From Uber

It’s not just health care companies, credit card companies, or big box retailers that need to be careful when it comes to privacy. Any company collecting user data from mobile apps—including geolocation data, user address...more

California says you can track online, but you can't hide your tracking

California law will soon require website and mobile app operators to disclose additional information in their privacy policies. Because the law applies to operators of websites and online services (including mobile apps) that...more

Privacy & Cybersecurity Update: FTC Mobile Privacy Disclosures: Building Trust Through Transparency

Overview - On February 1, 2013, the Federal Trade Commission (FTC) issued a staff report providing guidance and promoting best practices to improve transparency throughout the mobile app ecosystem (the Report). The...more

Two California Privacy Bills Introduced

California Assemblyman Isadore Hall introduced Assembly Bill 257 which addresses mobile privacy. The bill would codify many of the best practices proposed by the California Attorney General in her report titled “Privacy on...more

California Does It Again! - Recommends Best Practices for the Mobile App Industry

In last month’s Technology Advisory, I described recent actions of the California Attorney General designed to improve privacy protections for users of mobile applications. This included an agreement the California Attorney...more

Taming the Wild West: FTC Report Urges Mobile App Industry to Adopt Strong Privacy Measures

App providers and developers are in the hot seat again. On the same day that the FTC fined the social networking app Path $800,000 over allegations that it collected personal information without obtaining consumers’ consent,...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

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

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

Privacy-on-the-Go: California Attorney General and Major Mobile Application Platforms Agree to Privacy Principles for Mobile...

Application developers have been put on notice by the State of California. It is time to pay attention to user privacy and collection of information from user devices. In an effort led by the office of California...more

California’s Attorney General Releases Privacy Recommendations for Mobile Apps

California’s Attorney General released, on January 10, 2013, a lengthy set of recommended privacy practices aimed at app developers, app platform providers, mobile ad networks, operating system developers, and mobile...more

FTC Survey: Disclosure Of Use Of Private Information In Mobile Apps For Children Is Insufficient

A report recently released by the Federal Trade Commission (FTC) reveals that mobile applications targeted at children often collect and share children’s private information with third parties but generally do not provide...more

Privacy Resolutions for Mobile App Providers in the New Year

The end of 2012 saw a flurry of activity in the area of privacy enforcement. In July, Kamala Harris, the Attorney General of California, announced the formation of California's own state agency to investigate and enforce the...more

Advertising Law -- Jan 02, 2013

In This Issue: Does a Virtual Pet Site Violate COPPA?; Legislative Updates: Geolocation bill and VPPA Updates Advance, ECPA Update Stalls; Dunkin’s “Best Coffee” Slogan Can’t Be Trademarked; Takeoff: First California...more

Increasing Scrutiny of Consumer Data Collection

Recent FTC and California Attorney General actions highlight the need to reassess privacy policies. The Federal Trade Commission (FTC) recently ordered the data brokerage industry to provide information on the collection...more

FTC Issues Substantially Revised COPPA Rule, Effective July 1, 2013: Review of Changes and Compliance Tips

On December 19, 2012, the Federal Trade Commission (“Commission”) announced long-awaited amendments to its rule implementing the Children’s Online Privacy Protection Act (“Rule”). The changes – which take effect on July 1,...more

California AG Files First Suit for Alleged Mobile App Privacy Policy Violations

After serving notice that mobile app companies must comply with California's online privacy statute, last week Attorney General Kamala Harris filed the first of what is likely to be many suits against companies that develop,...more

FTC Announces Investigations of Kids App Providers and California’s AG Sues Delta over Fly Delta App’s Privacy Practices

Two recent developments should have all app providers reviewing their privacy practices and policies. On Monday, December 10, the Federal Trade Commission released its latest report on privacy disclosures and kids apps....more

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

California AG Files First Mobile Application Privacy Suit

On December 6, California Attorney General Kamala Harris (AG) announced an enforcement action against Delta Airlines for allegedly failing to comply with the state’s Online Privacy Protection Act. This is the first action...more

California Attorney General Brings Privacy Law Enforcement Action Against Delta Air Lines Over "Fly Delta" Mobile Application

Long-known as an ardent protector of individual privacy rights, California brought its first legal enforcement action under state privacy laws on December 6, 2012, when state Attorney General Kamala D. Harris filed suit...more

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