Archives: Mobile

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Math Question As Age-Gate and Invite-A-Friend Under Fire

The Children’s Advertising Review Unit of the Council of Better Business Bureaus (“CARU”) routinely monitors web sites and mobile apps for compliance with its Guidelines and the Children’s Online Privacy Protection Act (“COPPA”).  Through that routine monitoring, CARU recently discovered the information practices of the 1st through 7th grade mobile applications called Friendzy (e.g., 1st … Continue Reading

FTC Settles Advertising-Related COPPA Charges Against Two App Developers

This week, the FTC announced settlements with two developers of children’s apps that it claimed had failed to comply the Children’s Online Privacy Protection Act (“COPPA”). While any COPPA enforcement by the FTC is noteworthy, these cases are particularly interesting in that they are the FTC’s first COPPA enforcement actions that are based on allegations that a child-directed online service … 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

New Connecticut Mini-TCPA Provides for Giant Penalties and Attorneys’ Fees

Companies sending text messages or conducting voice telemarketing in Connecticut beware! Connecticut has substantially amended its telemarketing law (the “mini-TCPA”), which now may regulate even more conduct than the federal TCPA – particularly, push notifications and in-app messages. In addition, the mini-TCPA provides for reasonable attorneys’ fees, which may present an incentive for plaintiffs to … Continue Reading


The Children’s Advertising Review Unit of the Council of Better Business Bureaus (CARU) routinely monitors advertising to children.  Through those monitoring efforts, CARU brings challenges against advertisers for alleged non-compliance with its Self-Regulatory Program for Children’s Advertising and the Children’s Online Privacy Protection Act (COPPA).  In a recent case published on March 10, 2014, CARU … 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 “Internet of Things” Workshop Explores Privacy Risks and Benefits

The Federal Trade Commission’s long awaited “Internet of Things” public workshop was held Nov. 19, 2013, and webcast live (with presentations, transcripts and videos to be archived for ready access at to explore a wide range of potential privacy and security issues associated with Internet-connected devices everywhere – at home, work and in the car.   … Continue Reading

Sweepstakes and Contests Now Easier To Run on Facebook

Yesterday (Aug. 27, 2013) Facebook updated the section of its Pages Terms applicable to administering sweepstakes and contests on Facebook (see HERE and HERE).  In essence, Facebook removed almost all of the prior restrictions they imposed.  For example, companies no longer have to run their sweepstakes or contests via an app, nor are they prohibited … Continue Reading

New Federal Guidance for BYOD Security Released

The National Institute of Standards and Technology (“NIST”) is at it again.  This past Monday it released an update of its 2008-era special publication to reflect the tremendous growth of mobile devices since:  Guidelines for Managing the Security of Mobile Devices in the Enterprise (SP 800-124r1))(the “Mobile Guidelines”).  The Mobile Guidelines are designed to go … Continue Reading

THE FTC UPDATES ITS .COM DISCLOSURES GUIDANCE — Focus on Mobile and Space-Constraints; Frowns Upon Certain Common Practices

On March 12, 2013, the FTC released its long-awaited update to its year 2000 Dot Com Disclosures guidance; a document issued to help businesses develop legally compliant online ads.  Having recognized that much has changed in online advertising since 2000, the FTC’s update focuses not only on web sites, but also on social media activities and … Continue Reading

FTC Releases Recommendations for Mobile Privacy Disclosures

This weekend’s excellent Superbowl game, which was delayed by a power outage that prompted several announcers in passing to mention the “extra power” used by tablets and smartphones, highlighted that the mobile arena continues to take center stage everywhere.  We’ve covered the growing attention on mobile privacy policies and data gathering in recent posts (see, … Continue Reading

California AG Releases Mobile App Guidelines; Industry Responds

Last week, California Attorney General Kamala Harris released a set of recommendations titled “Privacy on the Go” directed toward the mobile app industry that seeks to “educate the industry and promote privacy best practices.”  The guidelines separately address app developers, app platform providers, mobile ad networks, operating system providers, and mobile carriers. A coalition of … Continue Reading