Auto-renewal

$10M FTC Settlement Highlights Importance of Auto-renewal Transparency

The Federal Trade Commission (“FTC”) settled charges with Age of Learning—the operator of ABCmouse, a digital learning program for children—that the company: (1) failed to disclose material auto-renewal terms, (2) did not obtain consumers’ ...
FTC COPPA FAQs

FTC Issues Revised FAQs for COPPA Compliance

On July 22, 2020, the Federal Trade Commission (“FTC”) issued revised FAQs regarding the Children’s Online Privacy Protection Act and the FTC Rule issued thereunder (together “COPPA”). The COPPA FAQs provide practical ...
FTC Tapplock Settlement

Not So Safe and Secure: FTC Settles Over Smart Lock Representations

The Federal Trade Commission (“FTC”) recently gave final approval to a settlement with the Canadian smart locks company Tapplock, Inc. over alleged deceptive practices in the data security context. Tapplock offers Internet-connected, ...
‘Tiny’ COPPA Case Provides Broad Guidance

‘Tiny’ COPPA Case Provides Broad Guidance

At the end of April, the U.S. District Court in New Mexico dismissed most, but not all, of the New Mexico Attorney General’s claims against a group of Ad Networks and Google ...
Influencer Marketing

FTC Seeks Public Comment on Approach to Influencers, Endorsements, Testimonials, and Reviews

With the rise of influencer marketing, promotional social media content, and endorsed reviews, the Federal Trade Commission (“FTC”) has increased its enforcement and is now looking to expand its guidance related to ...
Key Changes in the AG’s Updated Proposed CCPA Regulations

Key Changes in the AG’s Updated Proposed CCPA Regulations

The California Attorney General released an update to its proposed California Consumer Privacy Act Regulations, and companies have until 5 pm PT on February 24 to submit comments on this updated draft ...
YouTube and Google Fined $170 Million for COPPA Violations; FTC to Investigate YouTube Channels Next

YouTube and Google Fined $170 Million for COPPA Violations; FTC to Investigate YouTube Channels Next

Following an extensive investigation, the Federal Trade Commission (“FTC”) announced a settlement with Google and its subsidiary YouTube for the largest-ever civil penalty for violations under the Children’s Online Privacy Protection Act ...
FTC Says Unroll.me Deceived Consumers on Access and Use of Information

FTC Says Unroll.me Deceived Consumers on Access and Use of Information

The Federal Trade Commission announced a settlement and consent decree with email receipt management company Unroll.me, a subsidiary of Slice Technologies, Inc. Unroll.me offered a service that helped users unsubscribe from unwanted ...
The Carrot and The Stick: Trends and Considerations in the Equifax/FTC Settlement

The Carrot and The Stick: Trends and Considerations in the Equifax/FTC Settlement

Following a breach affecting 145 million consumers, the Federal Trade Commission has announced a settlement with Equifax for up to $700 million, the largest ever for a data breach. In the same ...
ZwillGen’s FTC Team on the Meaning of the FTC Facebook Settlement

ZwillGen’s FTC Team on the Meaning of the FTC Facebook Settlement

Following a yearlong investigation triggered in part by the Cambridge Analytica incident, the Federal Trade Commission (FTC) has announced a much anticipated settlement with Facebook, Inc. The Commission determined that the company ...