News & Analysis as of

Third-Party Personal Data

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #430 – GrubHub Confirms Security Incident Through Third Party Vendor

If you are a GrubHub customer, read carefully. The app has confirmed a security incident involving a third-party vendor that allowed an unauthorized threat actor to access user contact information, including some customer...more

Husch Blackwell LLP

Texas Files First Privacy Law Enforcement Action

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On January 13, 2025, Texas Attorney General’s Office filed its first lawsuit enforcing the Texas Data Privacy and Security Act (“TDPSA”). The law went into effect on July 1, 2024. The complaint also states claims under Texas’...more

A&O Shearman

Zooming In on AI - #6: AI under financial regulations in the U.S., EU and U.K.

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Many governments are grappling with the question of how to regulate artificial intelligence to ensure it is adopted safely and used responsibly without hampering innovation. Governments have generally indicated similar...more

BakerHostetler

First Circuit Adds Another Notch to the IRS’ Belt - Upholds Power To Summons Information from Virtual Currency Exchanges

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Anyone who thought blockchain would keep their cryptocurrency transactions private from the IRS needs to think again. According to the First Circuit’s recent holding, cryptocurrency users do not have a Fourth Amendment...more

Womble Bond Dickinson

Calhoun v. Google - Continued Considerations for Privacy Notices

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Website owners often struggle to design privacy policies that are not only comprehensive, but also comprehensible. The tension between these competing concerns was in sharp focus in a recent Ninth Circuit decision, Calhoun v....more

Davis Wright Tremaine LLP

Empire State of Minding the Minors: New York Laws Aim To Ensure Children’s Privacy and Online Safety

On June 7, 2024, the New York Legislature passed two bills to protect children online. The Stop Addictive Feeds Exploitation (SAFE) for Kids Act, S7694A, prohibits social media platforms from providing defined "addictive...more

Robinson+Cole Data Privacy + Security Insider

Federal Trade Commission Continues to Target Healthcare Companies for Unauthorized Data Disclosures

The Federal Trade Commission (FTC) has assumed the authority to enforce unauthorized data disclosures under the Federal Trade Commission Act (FTC Act). During the past three weeks, the FTC has used this authority to go after...more

Akin Gump Strauss Hauer & Feld LLP

FTC’s Proposed Settlement with Blackbaud Requires Data Deletion and Data Governance

On February 1, 2024, the Federal Trade Commission (FTC) announced that it had reached a proposed settlement with that would require Blackbaud Inc. (“Blackbaud”) to delete personal data it does not need to retain and upgrade...more

WilmerHale

The EU Data Act: A new European legal framework with rules for data access, switching cloud providers and interoperability

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On 22 December 2023, the EU published Regulation (EU) 2023/2854, the Data Act, in the Official Journal of the EU. The Data Act is a new regulation providing harmonised rules on access to data, switching cloud providers and...more

Constangy, Brooks, Smith & Prophete, LLP

Delaware Personal Data Privacy Act becomes law

On September 11th, Gov. John Carney (D) signed the Delaware Personal Data Privacy Act into law. The Act will take effect January 1, 2025. With the DPDPA on the books, the number of states with comprehensive privacy laws...more

Sheppard Mullin Richter & Hampton LLP

In 2024 Oregon Will Join Short List of States Requiring Data Broker Registration

Oregon recently joined Vermont and California as the third state requiring data broker registration before collecting, selling, or licensing “brokered personal data.” Several types of entities are exempt from the law. These...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

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The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Bradley Arant Boult Cummings LLP

Pet Stairs, Wiretapping, and Cookies: Implications of the Third Circuit’s Popa Opinion

The case of Popa v. Harriet Carter Gifts, Inc. “began with a quest for pet stairs.” Plaintiff Ashley Popa searched Harriet Carter Gifts’ website, added pet stairs to her cart, but never completed the purchase. During her...more

Barnea Jaffa Lande & Co.

Israeli Privacy Protection Authority Clarifies Scope of Duty to Inform on Collection and Use of Personal Information

Israel’s Privacy Protection Authority (PPA) recently published its position on the duty to inform when collecting and using personal data. This is an important position, as it clarifies how to design the interface with the...more

Husch Blackwell LLP

How do the CPRA, CPA & VCDPA treat sales?

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Keypoint: Organizations subject to these laws will need to determine whether they are engaging in “sales,” which can be a complex and multifaceted analysis given the statutes’ varying definitions and exemptions....more

Fox Rothschild LLP

Shape Up Or Ship Out: UK Information Commissioner’s Office Issues New Opinion Regarding Adtech Initiatives

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What does the U.K. Information Commissioner’s Office have to say about what it takes for adtech initiatives to be compliant with data protection? “There is an opportunity for market participants to move towards developing...more

Fox Rothschild LLP

The ‘Morning After’ Third Party Cookies

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The development of alternative techniques to “third-party” cookies cannot be done at the expense of the right of individuals to protect their personal data and privacy, according to France’s Commission Nationale de...more

Jackson Lewis P.C.

New York Considering Dramatic Expansion Of Consumer Privacy Rights

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In 2018, the California Consumer Privacy Act (“CCPA”), which provides for an expansive array of privacy rights and obligations, was enacted. At the time, it was reasonable to wonder whether California’s bold example would...more

Fox Rothschild LLP

French Court: Use Of Vendor With U.S. Parent May Require Additional Security Measures

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Even in the absence of a cross-border transfer of personal data from the European Union to a third country, if you are using a vendor that has a U.S. parent company, get ready to implement supplementary measures, says the...more

Spirit Legal

The end of dark patterns in “cookie walls”: German court bans deceptive designs

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Website operators are not permitted to use cookies and similar tracking technologies for analysis and marketing purposes without the informed consent of users, if this involves sharing personal data with third parties and...more

Fox Rothschild LLP

Apps Controlling Access In The Age Of COVID-19: The Spanish AEPD Weighs In

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Spanish data protection authority Agencia Española de Protección de Datos (AEPD) has published helpful guidelines on the data protection aspects of using mobile apps intended to control access to places of business while the...more

Bradley Arant Boult Cummings LLP

CCPA and AdTech: Mark Your Calendar for July 31st

A little more than six months ago, we addressed the challenges businesses faced in complying with CCPA when it came to their use of third-party adtech such as pixels, beacons and trackers. In line with the evolving nature of...more

Pillsbury Winthrop Shaw Pittman LLP

China Publishes Best Practices for Protection of Personal Information

On March 6, 2020, the State Administration of Market Regulation of the People’s Republic of China (PRC) and the Standardization Administration of the PRC published an updated version of the “Information security...more

Morgan Lewis

Restrictions On The Provision Of Personal Data To Third Parties Outside Japan

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In line with the recent wave of regulations governing the use of personal data, the Personal Information Protection Act of Japan restricts the provision of personal data to third parties, with a particular focus on the...more

Bricker Graydon LLP

FTC announces new and improved data security guidance

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On January 6, 2020, Andrew Smith, Director of the Federal Trade Commission (FTC) Bureau of Consumer Protection, announced three significant improvements to the FTC’s approach to data security enforcement cases....more

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