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On July 1, 2021, the Federal Trade Commission (FTC) announced that it settled allegations against Toronto-based Kuuhuub Inc., along with Kuuhuub's Finnish subsidiaries Kuu Hubb Oy and Recolor Oy (together, defendants), that...more
The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more
Protecting the privacy of our children is inherent to parenting. Parents guard against posting pictures of their children on social media or restrict the amount of time and the types of access they have on electronic devices....more
For many companies, the "hap-happiest season of all" coincides with the busiest season of all. Business owners and employees are racing to fill customer orders in time for the holidays, which also means an avalanche of new...more
The Federal Trade Commission (“FTC”) released an updated version of its guidance on complying with the Children’s Online Privacy Protection Act (“COPPA”) on June 21, 2017. Companies that collect personal information from...more
A consumer’s television or computer may be emitting silent signals that her smartphone can hear, recognize and answer back, but the consumer can’t sense them at all. These signals are telling retailers about their customer’s...more
The Federal Trade Commission (FTC) recently proposed amendments to its Gramm-Leach-Bliley Act (GLBA) rules requiring motor vehicle dealers to send their customers an annual privacy notice. The amendments would allow motor...more
In law school, everybody learns the adage that hard cases make bad law. When it comes to the Federal Trade Commission, a better aphorism might be, “easy cases make new law.” The FTC’s recent settlement with Nomi Technologies...more
Dis-Like! Senator Markey Urges the FTC to Investigate Facebook’s New Policies - As we previously reported, Facebook has proposed a number of revisions to its Data Use Policy and Statement of Rights and...more
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
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
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
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
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
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
The Federal Trade Commission (“FTC”) has announced its amended Children’s Online Privacy Protection Act (“COPPA”) Rule, which becomes effective July 1, 2013....more
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
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
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
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