The Bottom Line The FTC’s latest COPPA review will not only impact online services that traditionally have been directed to children, but may extend to services that historically have not been considered child-directed, such as interactive television, interactive gaming and chatbots. The COPPA Continue Reading
After 20 Years, COPPA Shows No Signs of Slowing Down
6th Edition: Trends in Marketing Communications Law Last year marked 20 years since Congress passed the Children’s Online Privacy Protection Act (COPPA). Fittingly, the Federal Trade Commission (FTC) kicked off 2018 by settling two back-to-back cases with companies alleged to have violated COPPA. Continue Reading
Two Websites Settle FTC Allegations That They Failed to Secure Consumer Data
The Bottom Line The security of consumer data is an important priority for the FTC and has become even more important in recent years, particularly when such data is subject to attacks by malicious third parties. The FTC emphasized that both settlements contained “new requirements” going beyond Continue Reading
Video Social Networking App Agrees to Pay $5.7 Million to Settle FTC’s COPPA Action
The Bottom Line The sheer size of the Musical.ly settlement illustrates that the FTC continues to have a strong interest in enforcing COPPA. Online services cannot hide behind language in their terms and conditions claiming not to be child-directed when they include numerous activities that Continue Reading
New York Attorney General Reaches Record COPPA Settlement with AOL
The Bottom Line The AOL settlement – which requires AOL to pay the largest COPPA penalty ever to date — is the most recent instance in which the New York Attorney General’s Office has sought to enforce COPPA. While most ad tech industry members have long known that behavioral advertising cannot be Continue Reading
Developments in Connected Technology Create New COPPA Challenges
5th Edition: Trends in Marketing Communications Law After a resoundingly quiet 2017, the Federal Trade Commission (FTC) started 2018 with a bang, announcing two back-to-back settlements with companies alleged to have violated the Children’s Online Privacy Protection Act (COPPA). The FTC’s Continue Reading
What We Can Learn from the FTC’s 2017 Privacy and Data Security Update
The Bottom Line The FTC exercises broad reach over privacy and data security issues across numerous industries. The Report shows a continuing trend towards more enforcement actions and increased penalties. All companies should review their privacy and data practices to confirm that they are in Continue Reading
With GDPR Deadline Looming, Ad Tech Community Proposes Collaborative Industry Solution
The Bottom Line Ad tech companies, and all other businesses subject to the GDPR, are facing an imminent compliance deadline. Companies may be able to seek GDPR-compliant solutions through their own internal initiatives, using third-party services or collaborating with others in the Continue Reading
FTC Announces First COPPA Action Involving Connected Toys
The Bottom Line As the first COPPA case involving connected toys, the FTC's settlement with VTech should be a reminder to all companies that they must fully comply with COPPA and must take reasonable steps to protect sensitive data, particularly any data collected from children. In addition, Continue Reading
Children’s Privacy and Children-Directed Influencer Marketing Face Greater Scrutiny
4th Edition: Trends in Marketing Communications Law Regulators and industry watchdogs, concerned that children are becoming more vulnerable to new technologies and sales techniques used by marketers, are taking a stronger stance against practices that violate children’s privacy and marketing Continue Reading