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FTC Publishes revised COPPA FAQs, clarifies parental consent methods

The FTC has issued three new FAQs clarifying the “verifiable parental consent” requirements under the COPPA Rule. In one of the revised FAQs, the FTC reiterates that the COPPA Rule’s list of parental consent methods is not exhaustive and that operators are free to use other “reasonably calculated methods” to obtain consent.  According the revised … Continue Reading

California Passes Law Giving Minors an “Eraser Button”

On September 23, California Gov. Jerry Brown signed SB 568 into law, a bill that gives minors in California the right to require that Internet companies delete content posted online by the minors.  This concept is sometimes referred to as an online “eraser button.”  The law takes effect Jan. 1, 2015. The law does not give minors the … Continue Reading

Tales from the (En)crypt(ed): What Happens to Your Online Account Information When You Die?

Have you ever wondered what happens to your online account information when you die?  Well, in a few days, the Uniform Law Commission (ULC) will be considering this very issue – fiduciary access to digital assets – at its annual meeting in Boston, MA. The ULC has been working on a draft uniform state law … Continue Reading

PENDING CALIFORNIA BILLS SEEK TO EXPAND PRIVACY PROTECTIONS

Written by Scott W. Pink and Carissa L. Bouwer California has long been a leader in legislative efforts to protect online privacy rights of consumers.  California passed the nation’s first security breach disclosure law, the first law requiring online privacy policies, and more recently, the first set of privacy guidelines for mobile app providers.  This year … Continue Reading

FTC Announces Long-Awaited COPPA Revisions: Restricts Behavioral Advertising and Retention of Data from Children, Among Others

Federal Trade Commission (FTC) Chairman Jon Leibowitz and Senate Commerce Committee Chairman John D. (Jay) Rockefeller IV announced the FTC’s long-awaited amended COPPA Rule at a press conference earlier today. In prior blog postings, we have noted that this seems to be the year of the mobile application. The FTC’s new COPPA rule continues with … Continue Reading

The Year of the Mobile App — Senate Advances Geolocation Tracking Bill

As 2012 comes to a close, it seems like 2012 has been the year of the mobile app.  In 2012, we have seen numerous bills regarding privacy and data security as well as cybersecurity, but the one that actually is moving alone pertains to mobile apps.  On Thursday, the Senate Judiciary Committee approved geolocation legislation … Continue Reading

FTC Publishes Guidelines Designed to Assist Mobile App Providers with Privacy Compliance

Earlier this month, the FTC published guidelines designed to assist mobile app providers in complying with privacy and truth-in-advertising principles.  In the guidelines, the FTC walks through certain privacy principles, which it set forth in its Privacy Report issued last March.  Specifically, the FTC encourages mobile app providers: to incorporate privacy principles into the design … Continue Reading

FTC Proposes Additional Revisions to COPPA Rules — Comments Due September 10, 2012

The Federal Trade Commission (FTC) has sought comment on additional revisions to its rules implementing the Children’s Online Privacy Protection Act (COPPA).  In September 2011, the FTC sought comment on proposed revisions to the COPPA rule, including changes to the definition of personal information.  For our advisory on the FTC’s prior modifications, click here.  Having received … Continue Reading
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