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California’s Privacy Regulatory Odyssey Continues: Formal CCPA Rulemaking on the Horizon Amidst Expanded Data Broker Requirements

On November 8, 2024, the California Privacy Protection Agency (CPPA) Board met to discuss and vote on various proposed California Consumer Privacy Act (CCPA) regulations related to cybersecurity audits, automated...more

California Appeals Court Moves Up Enforcement Date for Latest CCPA Regulations

On February 9, 2024, the California Third District Court of Appeals in Sacramento overturned a lower court order that postponed enforcement of the California Privacy Protection Agency’s (CPPA) newest rules. The decision...more

California Enacts One-Stop Mechanism for Data Broker Deletion Requests

California residents may soon be able to click “backspace” on data brokers doing business in the state. On October 10, 2023, California Governor Gavin Newsom signed Senate Bill 362, colloquially known as the Delete Act, into...more

OCR and FTC Issue Joint Letter to Healthcare Companies Warning About Online Tracking Technologies

On July 20, 2023, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) and the Federal Trade Commission (FTC) sent a joint letter to approximately 130 hospitals, telehealth providers, health...more

Texas, Oregon, and Delaware Join the Comprehensive U.S. State Privacy Law Landscape

New Requirements Include Identifying Specific Third Parties to Whom Businesses Disclose Data and Consent for Targeted Advertising to Teens - Texas, Oregon, and Delaware are the latest states to join the growing landscape...more

Sacramento Superior Court Delays Enforcement of CPRA Implementing Regulations

In a shocking turn of events, a Superior Court for the County of Sacramento issued a ruling on June 30, 2023, enjoining the enforcement of the California Privacy Protection Agency’s (the “Agency’s”) California Privacy Rights...more

FTC Announces Proposed Settlement with Premom Fertility Tracking App for Privacy Practices

On May 17, 2023, the Federal Trade Commission (FTC) announced a proposed settlement agreement (in the form of a stipulated order) with Easy Healthcare Corporation, which operates the Premom fertility tracking app (Premom)....more

The Sixth State: Iowa Enacts Comprehensive Privacy Law

On March 28, 2023, Iowa Governor Kim Reynolds signed “An Act Relating to Consumer Data Protection” (SF 262) (ICDPA), making Iowa the sixth U.S. state to enact a comprehensive consumer privacy law following California,...more

Colorado AG’s Office Announces Final Colorado Privacy Act Rules: Key Takeaways

On March 15, 2023, the Colorado Attorney General’s (Colorado AG) office released the final version of the Colorado Privacy Act (ColoPA) rules (the final rules), which are based on public comments on the third version of the...more

FTC Announces Settlement with BetterHelp for Disclosing Consumers’ Health Information to Third-Party Advertisers

On March 2, 2023, the Federal Trade Commission (FTC) announced a proposed settlement agreement (also referred to as “proposed consent order”) with BetterHelp, Inc., an online counseling service, for allegedly disclosing its...more

Colorado Attorney General’s Office Releases Third Version of Draft Rules for Colorado Privacy Act: Key Takeaways

On January 27, 2023, the Colorado Attorney General’s (Colorado AG) office released the third version of its proposed draft rules (third draft) for the Colorado Privacy Act (ColoPA) based on public comments it received on...more

California AG Targets Mobile Apps for Failing to Honor or Provide Mechanism for Opt-Out Requests

On January 27, 2023, the California Attorney General (California AG) Rob Bonta announced an “investigative sweep” of mobile apps in retail, travel, and food service industries for failing to provide a mechanism for—or...more

Colorado Attorney General’s Office Releases Modified Draft Rules for Colorado Privacy Act: Key Takeaways

On December 21, 2022, the Colorado Attorney General’s office published an updated version of proposed draft rules (“modified draft rules”) to the Colorado Privacy Act (ColoPA), which revise the initial draft rules issued in...more

California Privacy Protection Agency Releases Modified Proposed CPRA Regulations - Key Takeaways

On November 3, 2022, the California Privacy Protection Agency (CPPA, or the Agency) issued modified proposed regulations implementing the California Privacy Rights Act (CPRA),1 which revise the initial proposed regulations...more

California Legislature Passes Far-Reaching Online Privacy and Content Regulation Bill for Minors

On August 30, 2022, the California legislature passed the California Age-Appropriate Design Code Act (the Act). Modeled after the UK's Age-Appropriate Design Code, California's act drastically changes the landscape of online...more

California Attorney General Settles First-Ever CCPA Enforcement Action

On August 24, 2022, the California Attorney General (AG) announced the entry of a final judgment to resolve claims that makeup retailer Sephora violated the California Consumer Privacy Act (CCPA). Notably, this is the...more

Privacy Post-Dobbs: Recent Guidance from U.S. Regulators

On June 24, 2022, the United States Supreme Court issued its decision in Dobbs v. Jackson Women's Health Organization,1 opening a legal path to state laws restricting or prohibiting access to certain reproductive health...more

Colorado Attorney General Issues Pre-Rulemaking Considerations for the Colorado Privacy Act

On April 12, 2022, the Colorado Attorney General's Office released "Pre-Rulemaking Considerations for the Colorado Privacy Act," which provides a series of topics and questions for which the office seeks informal public...more

Utah Poised to Become Fourth State with General Privacy Law

Utah is poised to become the fourth state to enact comprehensive consumer privacy legislation, following California, Virginia, and Colorado. Earlier this month, Utah's legislature passed the Utah Consumer Privacy Act (S.B....more

Colorado Attorney General Announces Privacy Rulemaking

The Colorado Attorney General's office is poised to begin the rulemaking process for the Colorado Privacy Act (ColoPA). On January 28, 2022, Colorado Attorney General Phil Weiser issued prepared remarks outlining key...more

California Privacy Protection Agency Issues Invitation for Preliminary Comments on Proposed Rulemaking Under the California...

The California Privacy Protection Agency (CPPA), the newly formed state agency responsible for implementing the California Privacy Rights Act (CPRA), recently posted its first invitation for public comment on proposed...more

California Attorney General Mandates CCPA-Covered Businesses Honor the Global Privacy Control and Announces Update on CCPA...

Recently, the Office of the Attorney General of California announced three major updates that 1) added to the California Consumer Privacy Act's (CCPA) opt-out rules related to the sale of personal information, 2) made it...more

FTC Settles COPPA Action Against “Coloring Book for Adults”

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

Virginia Legislature Sends Novel Privacy Law to Governor's Desk

Virginia is poised to become the second U.S. state to enact broad consumer privacy legislation. While the legislation draws some parallels with the California Consumer Privacy Act (CCPA) and upcoming California Privacy Rights...more

Apple Requires Apps to Include New Privacy "Nutrition Label" by December 8, Delays Opt-In for Tracking Requirement Until Early...

Apple recently announced that app developers must check a series of yes/no boxes that will generate a "nutrition label"-style summary of the app's privacy practices. This new summary, formally called "App Privacy," will be...more

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