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Oregon’s Privacy Law Update Adds to Patchwork Approach to Minors and Location Data

Oregon will begin to regulate the use of minors’ information and sale of users’ location data (regardless of age) with an update to its Oregon Consumer Privacy Act. These revisions will go into effect January 1, 2026. As...more

US Privacy Footprint Continues to Expand: Tennessee and Minnesota Join the State Law Club

The US “comprehensive” law landscape continues to expand, with two more states—Tennessee (July 1) and Minnesota (July 31) —joining the “comprehensive” privacy law club. Five of these -Delaware, Iowa, Nebraska, New Hampshire,...more

Growing List of States Attempting to Regulate Kids’ Online Privacy: Vermont Joins the Group

Vermont has joined the list of states attempting to regulate the use of children’s information collected online, passing an Age-Appropriate Design Code Act. This law mirrors ones we have seen in other US states as well as the...more

Big Sky State Makes Big Privacy Updates

Montana’s privacy law has received a refresh and updates will go into effect October 1, 2025 – exactly one year since the law took effect. The law was modified with SB 297, and changes include coverage, approach with minors,...more

Oregon Extends Privacy Law to Specifically List Auto Makers

In ongoing tweaks to state privacy laws, Oregon has amended its state privacy law to cover auto manufacturers. Specifically, those that process or control personal information that they get from a person’s use of a car... ...more

North Dakota Passes New Data Security Law for “Financial Corporations”

North Dakota recently passed a law establishing new rules for certain financial companies operating in the state – specifically “financial corporations.” The new obligations will take effect on August 1, 2025. They will apply...more

Growing List of States Attempting to Regulate Kids’ Social Media Accounts: Nebraska Husks Up

Nebraska’s governor signed a bill into law that, among other things, creates the Parental Rights in Social Media Act. The provisions of the law will go into effect July 1, 2026, unless challenged. The law is similar to...more

Montana Amends Law to Cover Collection and Use of Neural Data

Montana recently revised its Genetic Information Privacy Act to address neural data. The law went into effect in 2023, and applies to both entities that offer genetic testing services as well as entities that use genetic...more

Michigan AG Sues Roku Over Alleged Privacy Violations

The Michigan Attorney General has filed a complaint against Roku, a popular TV content platform, alleging, among other things, violations of the Children’s Online Privacy Protection Act and the Video Privacy Protection Act...more

Virginia Will Add to Patchwork of Laws Governing Social Media and Children (For Now?) 

Virginia’s governor recently signed into law a bill that amends the Virginia Consumer Data Protection Act. As revised, the law will include specific provisions impacting children’s use of social media. Unless contested, the...more

Belgian DPA Finds Broad Tax Information Transfers to IRS Unlawful

The Belgian Data Protection Authority recently ruled that a Belgian government entity, FPS Finance, cannot transfer the personal data of “accidental Americans” to the IRS. According to the decision, the transfers needed to...more

Lessons from the FTC: The Cleo AI Settlement

The FTC’s settlement with Cleo AI gives some indication as to what we might see from the agency in the coming months. The FTC alleged, among other things, that Cleo AI’s actions violated Section 5 of the FTC Act. In...more

New Era of Collaboration? States Team Up to Coordinate on Privacy Laws

The California Privacy Protection Agency announced this month that it, along with six other states, will be forming a new group called the “Consortium of Privacy Regulators.” (The other states are Colorado, Connecticut,...more

Insurance Cybersecurity Certifications: An (Updated) State Roundup

Over half of US states require annual compliance certifications from insurance providers. While the filing time frames for this year draw to a close, companies may want to keep them in mind not only for next year, but as a...more

Arkansas’ Kids Social Media Law: Another One Bites the Dust

Arkansas’ second attempt at regulating minor’s access to social media – in the form of the Social Media Safety Act (SB 689) – has again been struck down as unconstitutional. The court permanently enjoined the state from...more

Auto Insurer Settles With New York AG Over Insurance Application Platform Security Issues

The New York Attorney General recently entered into an assurance of discontinuance with Root Insurance Company following a 2021 data incident. According to the AG, the threat actors obtained people’s drivers’ license numbers...more

US State AI Legislation: Virginia Vetoes, Colorado (Re)Considers, and Texas Transforms

The Virginia law, like the Colorado Act, would have imposed various obligations on companies involved in the creation or deployment of high-risk AI systems that influence significant decisions about individuals in areas such...more

SEC Creates New Tech-Focused Enforcement Team

On February 20, the SEC announced the creation of its Cyber and Emerging Technologies Unit (CETU) to address misconduct involving new technologies and strengthen protections for retail investors. The CETU replaces the SEC’s...more

Utah Pioneers App Store Age Limits

Utah’s governor recently signed the first law which puts age restrictions on app downloads. The law (the App Store Accountability Act, SB 142), was signed yesterday (Wednesday, April 26, 2025). We anticipate that the law may...more

Oregon’s Privacy Law: Six Month Update, With Six Months to End of Cure Period

Oregon’s Attorney General released a new report this month, summarizing the outcomes since Oregon’s “comprehensive” privacy law took effect six months ago. A six-month report isn’t new: Connecticut released a six month report...more

New York AG Settles with School App

The New York Attorney General recently entered into an assurance of discontinuance with Saturn Technologies, operator of an app used by high school and college students. The app was designed to be a social media platform that...more

Common Privacy Pitfalls in M&A Deals

Many expect that deal activity will increase in 2025. As we approach the end of the first quarter, it is helpful to keep in mind privacy and data security issues that can potentially derail a deal. We discussed this in a...more

FTC Requests Input from Tech Platform Users About Speech

The Federal Trade Commission recently requested public comment from users of tech platforms. In particular, the impact the platforms may have on user speech. Input is sought -by May 21- on the extent to which tech firms are...more

Forget It!: EDPB Announces Focus on Right to Erasure in 2025

Right of erasure (or “right to be forgotten”) has been selected by the European Data Protection Board as its priority enforcement topic for 2025. This work is being done under the “Coordinated Enforcement Framework” or “CEF.”...more

FTC COPPA Updates Provide New Protections for Children

In the waning days of the Biden administration, the FTC published an update to its COPPA Privacy Rule. The status of this update, however, is unclear. The revisions to the rule were posted on the FTC website prior to the...more

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