On October 22, 2013, the Federal Trade Commission (FTC) announced a proposed settlement of a case against Aaron’s, Inc., a national rent-to-own retailer with more than 1,800 locations in 48 states, having alleged that Aaron’s knowingly played a direct and vital role in its franchisees’ installation and use of software on rental computers that secretly monitored consumers.
Continue Reading National Rent-to-Own Company Settles FTC Charges of Enabling Computer Spying by Franchisees
Matthew Staples
California Extends Security Breach Notification Requirements to Online Account Credentials
By Matthew Staples on
Posted in Cybersecurity, Privacy
California, which enacted the pioneering security breach notification law in 2002, again has taken the lead in security breach notification legislation. In an effort to protect consumers against unauthorized access to their online accounts, California has extended its security breach notification law to cover individuals’ online account credentials (i.e., a user name or email address, in combination with a password or security question and answer, that would permit access to an online account) in amendments that will take effect on January 1, 2014.1 This article discusses California’s existing security breach notification obligations, as well as the changes provided for in these amendments.
Continue Reading California Extends Security Breach Notification Requirements to Online Account Credentials
Digital Advertising Alliance Releases Guidance on the Application of Its Self-Regulatory Principles to the Mobile Environment
By Lydia Parnes, Tonia Klausner & Matthew Staples on
Posted in Regulatory
New Self-Regulatory Guidance Joins Other Privacy and Transparency-Related Considerations for Participants in the Mobile Ecosystem
On July 24, 2013, the Digital Advertising Alliance (DAA), comprised of the largest media and marketing trade associations in the U.S., released new guidance regarding mobile and other devices (Mobile Guidance).1 The Mobile Guidance explains how the DAA’s existing Self-Regulatory Principles for Online Behavioral Advertising (OBA Principles)2 and Self-Regulatory Principles for Multi-Site Data (MSD Principles)3 (together, the DAA Principles) apply to companies operating in the mobile ecosystem. It sets forth specific requirements for the collection and use of precise location information, as well as two new categories of data: “cross-app data” and “personal directory data.”
Continue Reading Digital Advertising Alliance Releases Guidance on the Application of Its Self-Regulatory Principles to the Mobile Environment