News & Analysis as of

Mobile Apps Disclosure Requirements Federal Trade Commission (FTC)

Ankura

DHHS OCR and FTC Issue Warning to Hospital Systems and Telehealth Providers Regarding Privacy and Security Risks

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On July 20, 2023, the Department of Health and Human Services (DHHS) through the Office of Civil Rights (OCR) and the Federal Trade Commission (FTC) issued a joint letter to hospitals and telehealth providers alerting them to...more

McDermott Will & Emery

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

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Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Dechert LLP

Dechert Cyber Bits - Issues 38

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SEC Finalizes Cybersecurity Disclosure Rules for Public Companies - On July 26, 2023, the Securities and Exchange Commission (“SEC”) voted to adopt new rules requiring public companies to make certain disclosures...more

Hinch Newman LLP

Advertising Law Alert: FTC Announces New Health Products Compliance Guidance

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In December 2022, the the Federal Trade Commission published new guidance regarding representations about the benefits and safety of health-related products: Health Products Compliance Guidance. Federal Trade Commission...more

Dechert LLP

Dechert Cyber Bits - Issue 10

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SEC Proposes New Cybersecurity Rules for Public Companies - On March 9, 2022, the Securities and Exchange Commission (“SEC”) announced proposed amendments to its rules on cybersecurity. The proposed rules aim to “enhance and...more

ArentFox Schiff

Privacy Update: Corporate Boards - Don’t Underestimate Your Role in Data Security Oversight

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The Federal Trade Commission (FTC) continues to put emphasis on the importance of corporate board involvement in privacy and data security. Corporate Boards: Don’t Underestimate Your Role in Data Security Oversight - The...more

Rivkin Radler LLP

Flo Health Settles With FTC Over Privacy Violations

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Flo Health, Inc., which markets a menstrual and ovulation tracking app, recently entered into a settlement with the Federal Trade Commission (FTC) to dispose of charges that Flo improperly shared consumer data with third...more

Rothwell, Figg, Ernst & Manbeck, P.C.

10 Thoughts Regarding Apple’s New “Privacy Nutrition Labels”

In December 2020, Apple started requiring Apps to display mandatory labels that provide a graphic, easy-to-digest version of their privacy policies.  They are being called “privacy nutrition labels,” presumably a reference to...more

Wilson Sonsini Goodrich & Rosati

FTC Grants Sears’ Petition to Reopen and Modify 2009 Order Concerning Online Browsing Tracking

The Federal Trade Commission (FTC) recently granted a petition by Sears Holding Management requesting that the FTC reopen and modify a 2009 FTC order settling charges that Sears failed to disclose adequately the scope of...more

Hogan Lovells

Hogan Lovells Represents Sears in Achieving First-Ever Modification to FTC Privacy Consent Order

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The FTC has approved the first-ever petition to reopen and modify a privacy-related consent order. The petition, filed by Sears Holdings Management Corporation, sought to amend the terms of Sears’ 2009 consent order (the...more

WilmerHale

Time to Set the Clock: Self-Regulatory Enforcement of Cross-Device Tracking Begins in February 2017

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The Digital Advertising Alliance (DAA) recently announced that self-regulatory enforcement of its cross-device guidance will begin in February 2017. Accordingly, companies that engage in cross-device tracking and...more

Ballard Spahr LLP

To (Dis)Close for Comfort–FTC Workshop Seeks Effective Consumer Disclosures

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A goal of providing effective disclosures to consumers is to allow consumers to make informed decisions. But what must be done to make disclosures effective? This was the question the Federal Trade Commission (FTC) explored...more

Manatt, Phelps & Phillips, LLP

Advertising Law - July 2016 #4

Sen. Franken Hits Pause on Pokémon GO - After the Pokémon GO app was downloaded approximately 7.5 million times in the United States alone in its first week of release, Sen. Al Franken (D-Minn.), the chairman of the...more

Carlton Fields

Learning from Venmo’s Compliance Issues: How to Avoid Inadequate Privacy Disclosures

Carlton Fields on

PayPal, the company responsible for the popular mobile payments app, Venmo, recently agreed to voluntarily bolster its privacy and security disclosures—and pay a $175,000 penalty—in response to an enforcement action brought...more

BCLP

Subscription-Based Business Models: An Overview of Auto-Renewal Regulations

BCLP on

The demand for subscription-based and recurring revenue business models is growing faster than ever. According to a 2014 report by The Economist Intelligence Unit, 80 percent of customers are demanding new consumption models...more

Sheppard Mullin Richter & Hampton LLP

Serious Games Require Serious Attention to Marketing Statements

Lumos Labs recently paid $2 million to the FTC to settle claims that it deceived consumers about its brain training application’s ability to increase cognitive function. According to the FTC, the company alleged that its...more

Manatt, Phelps & Phillips, LLP

Advertising Law - October 2015 #2

"Flying Rabbi" Suit Crash Lands in NY Appellate Court - A New York man was unsuccessful in his lawsuit accusing Jimmy Kimmel of misappropriating his image during a skit on the late night TV show, Jimmy Kimmel Live! ...more

Ervin Cohen & Jessup LLP

The Nuts and Bolts of Digital Advertising

“We have the best mobile app on the market!” “Subscribe now and win an Apple watch!” “Download our software and we guarantee an increase in your business within 30 days!” That all sounds quite wonderful, actually. Where do I...more

Cooley LLP

Disclosure At The Mobile Check-Out: The FTC's View On Mobile Shopping Apps

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In its August 1st report entitled "What's the Deal — An FTC Study on Mobile Shopping Apps," the FTC provides guidance on various disclosures that should be made by mobile apps along with reinforcing a number of prior...more

Orrick, Herrington & Sutcliffe LLP

Mobile Apps Remain Regulatory Focus as FTC Enforces Data Privacy of Popular Program

The provider of the immensely popular “Brightest Flashlight Free” mobile app for Android reached a settlement with the Federal Trade Commission (FTC) over charges that it collected sensitive personal information, including...more

Wilson Sonsini Goodrich & Rosati

"Eye on Privacy" Newsletter - March 2013

In this issue: - FTC Releases Privacy Disclosure Guidelines for Mobile Ecosystem - California Attorney General Issues Privacy Practice Recommendations for Mobile Ecosystem - Mobile Apps: Learning from...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update: FTC Mobile Privacy Disclosures: Building Trust Through Transparency

Overview - On February 1, 2013, the Federal Trade Commission (FTC) issued a staff report providing guidance and promoting best practices to improve transparency throughout the mobile app ecosystem (the Report). The...more

Troutman Pepper

FTC Survey: Disclosure Of Use Of Private Information In Mobile Apps For Children Is Insufficient

Troutman Pepper on

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

Davis Wright Tremaine LLP

FTC Again Challenges Kids' Mobile App Data Collection and Disclosure Practices

The Federal Trade Commission (“FTC”) released on December 10, 2012, its second staff report on disclosures for mobile apps targeted at children, building on its prior report issued 10 months earlier....more

BakerHostetler

FTC Launches Investigation of Children's Mobile App Compliance with COPPA; Continues to Study "Comprehensive" Data Collection

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Monday, on a call with reporters to discuss the findings of its second survey of kids mobile device applications, attorneys with the Federal Trade Commission (1) called on industry – app developers, app stores, and third...more

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