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Are Cookies Banners Crumbling?

As anyone who uses the internet can attest, cookies banners pop up on almost every type of website and offer a dizzying and often annoying array of approaches and options to consumers. It is difficult to parse through what...more

Navigating Consumer Opt-Outs in Corporate Transactions: Insights on California’s AB 1824

On September 29, 2024, California Governor Gavin Newsom signed AB 1824  into law, amending the California Consumer Privacy Act (CCPA) to require entities involved in corporate transactions, such as mergers and acquisitions,...more

New York May Lead the Pack Through Imposition of Data Excise Taxes

New York may lead the charge on implementation of data excise taxes (i.e., “data mining taxes”) which will impose taxes on businesses that collect personal data. These data excise taxes primarily target large tech companies...more

Washington My Health Data Act FAQ's: Processing Biometric Data

What are the unique features concerning the processing of biometric data under the MHMDA? The MHMDA defines “biometric data” very broadly. Specifically, biometric data is “data that is generated from the measurement or...more

Time to Comply: Washington My Health My Data Act

On April 27, 2023, the Washington State governor signed into law the My Health My Data Act or the MHMDA. In spite of the onerous and at times confusing requirements of the MHMDA, the Washington Attorney General (AG) has only...more

California's Delete Act: A First of Its Kind Data Broker Law

On October 10, 2023, California Governor Gavin Newsom signed SB 362 into law. The “Delete Act” is intended to bridge a gap in consumer privacy rights – whereas the California Privacy Rights Act (the CPRA) grants consumers the...more

The Future of Insurance - Colorado’s New ECDIS and AI Model Regulations

On September 21, 2023, the Colorado Division of Insurance adopted a Final Regulation implementing S.B. 21-169, the 2021 law governing Colorado-licensed insurers’ use of external consumer data and information sources (ECDIS),...more

A Kinder, Gentler Consumer Health Data Bill: Nevada’s SB 370

On June 16, 2023, Nevada Governor Joe Lombardo signed SB 370 into law. This new law is a consumer health data bill that is similar in many ways to Washington’s My Health My Data Act (MHMDA). SB 370, like most provisions of...more

Colorado’s “Loyalty Program” regulations are final, and they blow California’s rules out of the water

On March 15, 2023, the Colorado Attorney General’s Office announced the finalization of the Regulations implementing the Colorado Privacy Act (CPA), which will take effect on July 1, 2023. Covered businesses that make use of...more

FTC Policy Statement to Biometric Information and Technology

The Federal Trade Commission (“FTC”) has issued a policy statement addressing biometric technologies in a signal of enforcement actions to come: It states: “In light of the evolving technologies and risks to consumers, the...more

Precise Geolocation: Recent Trends and Enforcement

“Precise Geolocation” has become a hot button issue in the privacy world with recent data privacy laws seeking to regulate the collection and processing of such information, including in California and Virginia. The...more

HR data is now regulated under California privacy law: How to tackle compliance

2023 will be yet another dynamic year for data privacy regulation.  In addition to the data privacy laws in Virginia, Colorado, Utah, and Connecticut going into force this year, businesses also have to contend with the fact...more

Comparison of the CCPA & CPRA with Pending 2021 Comprehensive Federal Privacy Legislation - S. 1494

In the last year, we continued to see a shift in the privacy landscape of the United States, including the passage of comprehensive privacy legislation in both Virginia and Colorado, while other states still have bills under...more

Comparing the Data Protection Assessment Requirements Across the Next Generation of U.S. State Privacy Laws

What is a data protection impact assessment (DPIA)? A data protection impact assessment or data protection assessment (DPIA) is a form of risk assessment that is designed to help organizations identify, analyze and...more

The CPRA Digest: Contracting with “Contractors”

On November 3, 2020, Californians voted to pass Proposition 24, expanding and modifying the California Consumer Privacy Act (“CCPA”), which came into force on January 1, 2020. The new California Privacy Rights Act (“CPRA”)...more

FAQ: What is Session Replay Software and why is it under attack?

Session Replay Software is a type of software typically utilized by businesses with consumer-facing websites. These businesses are typically very interested in making their website more interactive and responsive to consumer...more

FTC Says that One Cannot Retain the Fruit of the Tainted Tree

Setting new precedent in the world of data, the FTC has found that the work product of ill-gotten data is no longer retainable by the developer.  On January 11, 2021, the U.S. Federal Trade Commission (FTC) announced that it...more

The CPRA Digest: Data Minimization

On November 3, 2020, Californians voted to pass Proposition 24, expanding and modifying the California Consumer Privacy Act (“CCPA”), which came into force on January 1, 2020. The new California Privacy Rights Act (“CPRA”),...more

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