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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

FTC Finalizes ‘Click to Cancel’ Rule

On October 16, the FTC announced that it has finalized its “click to cancel” rule, that will require sellers to make it much easier for consumers to cancel subscriptions. The final rule is part of the FTC’s ongoing review of...more

CARU Settles With KidGeni AI Platform Over Alleged Privacy Violations 

The Children’s Advertising Review Unit recently settled with KidGeni – a generative art platform intended for children- for allegedly violating both CARU’s guidelines and COPPA. According to CARU, which is a self-regulatory...more

How to Succeed in Environmental Marketing Claims

Environmental marketing claims often present something of a Catch-22—companies that are doing actual good for the environment deserve to reap the benefits of their efforts, and consumers deserve to know, while at the same...more

FTC Continues Focus on Children’s Privacy

The FTC recently took two well-publicized steps in the children’s privacy space. First, it penalized WW International (formerly, Weight Watchers) and its subsidiary, Kurbo, for alleged COPPA violations. Second, it unanimously...more

FTC Fines Lead Generation Company $1.5M Citing Misuse of Consumer Financial Data

A California-based lead generation company recently settled with the FTC for $1.5 million over alleged privacy violations. The FTC argued that the company deceptively acquired consumer personal information and improperly...more

OpenX Ad Exchange Settles With FTC Over Alleged COPPA and Other Violations

OpenX Technologies recently agreed to pay $2 million to settle FTC allegations that the advertising platform violated the FTC Act and the Children’s Online Privacy Protection Act. OpenX runs a programmatic ad exchange,...more

Lead Generator Settles with FTC Over Alleged FCRA and FTC Act Violations

On January 7, the FTC announced that a California-based lead generator agreed to settle with the FTC for $1.5 million to resolve allegations that through a number of its subsidiaries, the company induced consumers into...more

CARU Revises its Guidelines to Address Increase in Online Media

The Children’s Advertising Review Unit (CARU) recently revised its children’s advertising guidelines to address the increased prevalence of online media directed to children. Of note, the guidelines now apply to content...more

A COPPA First: Safe Harbor Program Removed From Approved List

The FTC recently announced the removal of Aristotle International, Inc. from the list of seven approved safe harbor programs under the Children’s Online Privacy Protection Act. Programs that are approved by the FTC must place...more

Mobile Advertising Company Gets Flack from FTC for Failure to Deliver Upon Advertised Promises

Tapjoy, Inc. (“Tapjoy”), a mobile advertising company, settled FTC allegations that it failed to provide promised in-game rewards to consumers. Tapjoy operates an advertising platform that works within mobile games and offers...more

Back to School Special: Is My Multi-Age Platform Subject to Child Protection Requirements?

In our online world, one of the challenges (and opportunities) for companies is the increased use of their websites, apps, and connected devices. For platforms directed to both adults and children, or platforms previously...more

Back to School Special: But I’m Just an Ad Network! Am I Subject to Children’s Privacy Laws?

As we wrote previously, kids are spending more of their days online and are using online platforms for virtual learning and entertainment. Much of this environment is funded through online advertising. All companies thus need...more

Back to School Special: COPPA Consent in the COVID Era

In the current pandemic era, kids are spending more time online, be it for school or entertainment. Companies are therefore gearing up for increased interaction with children online or through connected devices. As children...more

Back to School Special: Recordings, Photos, Kids, and Parental Consent

In this remote era, companies are increasingly being approached by their business teams with ideas about products and services that involve video or audio recordings of their consumers. It may also involve letting people...more

FTC Workshop Provides Insight on Best Practices to Mitigate Informational Injuries

On December 12, 2017, the FTC hosted a workshop to discuss informational injuries that consumers may suffer when their personal information is misused. Discussion topics included the types of informational injuries consumers...more

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