Archives: Location Data

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First Circuit Ruling May Extend Reach of VPPA

On April 29, 2016, the First Circuit Court of Appeals addressed the question of what data constitutes “personally identifiable information” and who is a “subscriber” under the Video Privacy Protection Act (VPPA) in Yershov v. Gannet Satellite Information Network, Inc. The plaintiff claimed that Gannett shared information identifying him and the video clips that he … Continue Reading

Retail-Tracking Service Provider Nomi Technologies Settles FTC Complaint Over False Statement in its Privacy Policy

Last week, the Federal Trade Commission announced a complaint against and proposed settlement with Nomi Technologies, Inc.* (“Nomi”), based on allegations that Nomi included a false representation in its Privacy Policy. Nomi is an analytics provider offering services to brick-and-mortar retail locations through its “Listen” service. To provide the service, Nomi utilizes beacons placed within … Continue Reading

FTC Settlement Provides Guidance Regarding an App’s Collection of Geolocation Data, When Data Collection and Sharing May Begin, and Privacy Representations in a License Agreement

A recent FTC settlement provides some illuminating guidance for app developers and publishers regarding the sharing of geolocation data, when an app may begin collecting and sharing data, and privacy representations made in a license agreement or similar document. In re Goldenshores Technologies, LLC. This settlement is the first to impose substantial conditions upon the collection … Continue Reading

FTC’s Amended COPPA Rule Seeks to Keep Up with the Internet Revolution

The FTC announced that it had finalized amendments to the Children’s Online Privacy Protection Act (COPPA) Rule, which the FTC originally enacted in 2000.  The original Rule was created with the goal of protecting the online privacy of Children younger than the age of 13 (“Children”) by requiring that websites: 1) obtain parental consent before … Continue Reading

GAO Study Gives Low Marks to Companies Regarding Transparency to Consumers of Use of Location Data

The Government Accountability Office (“GAO”) released a study in September, 2012 analyzing the collection, use and disclosure practices of fourteen companies operating in the mobile field regarding location data collected from consumers.  In the absence of laws or regulations regarding the collection of location data specifically, the GAO compared the policies of the fourteen companies to … Continue Reading