Perkins on Privacy
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Perkins on Privacy

Perkins on Privacy keeps you informed about the latest developments in privacy and data security law. Our insights are provided by Perkins Coie's Privacy & Security practice, recognized by Chambers as a leading firm in the field. 
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December 11, 2024 Regulatory Enforcement Federal Trade Commission

FTC Staff Paper Finds that Most Surveyed “Smart” Products Fail to Disclose Duration of Support

 On November 26, 2024, the FTC released a staff paper regarding the disclosure of the duration of the support for the software of connected consumer devices. As the FTC staff explained, if a manufacturer stops providing software updates, products may lose their “smart” functionality, become insecure, or stop working entirely. Against that backdrop, the FTC examined the software support disclosures of manufacturers of 184 connected consumer products. The FTC concluded that just under 89% of the product web pages for the studied devices did not disclose a software support period. View blog post
Security
December 4, 2024 Privacy Compliance New Administration Regulatory Enforcement Federal Trade Commission

How the FTC’s Approach to Privacy, Security, and AI Enforcement May Change

 The new administration is likely to have a significant impact on the Federal Trade Commission’s (FTC’s) approach to privacy, data security, and other technology-related aspects of consumer protection, including artificial intelligence (AI). View blog post
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November 7, 2024 Regulatory Enforcement Data Security Data Breach and Incident Response Federal Trade Commission

FTC and State Coalition Settle Data Breach Cases with Marriott

 In 2018, Marriott announced a data breach affecting its Starwood reservation system, thought at the time to have affected up to 500 million people worldwide. These settlements arise from that incident, as well as two smaller incidents that also affected Starwood and Marriott. The FTC alleges these incidents exposed payment card information, unencrypted passport numbers, and loyalty account information, along with other information like names, dates of birth, and contact information. View blog post
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August 14, 2024 Data Security Regulatory Enforcement Children’s Privacy Federal Trade Commission

FTC Order Bans Anonymous Messaging App from Serving Minors

 The Federal Trade Commission (FTC) and the Los Angeles County District Attorney announced a complaint and proposed stipulated order concerning the “NGL: ask me anything” anonymous messaging app. View blog post
Financial Services & Investments
March 18, 2024 Regulatory Enforcement Federal Trade Commission

FTC Obtains $16.5M from Avast for Sale of Sensitive Data

The FTC's action against Avast reflects its continued focus on the mass collection and sale of sensitive personal data for advertising purposes.

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March 14, 2024 Children’s Privacy Legislative Developments

Kids Online Safety Act Gains Momentum in the Senate

Last month, Senators Richard Blumenthal (D-Conn.) and Marsha Blackburn (R-Tenn.) reintroduced the Kids Online Safety Act (KOSA), initially introduced last term, noting that the bill now has 62 cosponsors, bipartisan support, and is poised to pass in the Senate.

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January 26, 2024 Regulatory Enforcement Federal Trade Commission

The FTC Continues its Focus on Location and Sensitive Data

 The Federal Trade Commission (FTC) followed its recent spate of enforcement in the location and sensitive data space with the announcement of another enforcement action and proposed settlement with InMarket Media, Inc. (InMarket). View blog post
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August 1, 2023 Children’s Privacy Federal Trade Commission Regulatory Enforcement

COPPA: Public Comment Period Open for Proposed Verifiable Parental Consent Method

For the first time since 2015, the Federal Trade Commission (FTC) has been asked to approve a new "verifiable parental consent" (VPC) method under the Children's Online Privacy Protection (COPPA) Rule. 

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