This post was also written by Frederick Lah.
A California state assemblyman proposed legislation this week attempting to require that online privacy policies be no more than 100 words. The legislation would also require that the privacy policy “be written in clear and concise language, be written at no greater than an 8th grade reading…
Today, the Federal Trade Commission released detailed guidance on privacy in the mobile environment – at the same time it announced its largest-ever settlement with an app developer for alleged privacy violations. Combined with aggressive action on mobile privacy issues by the California attorney general’s office, Mobile Privacy Disclosures provides every company associated with…
This post was also written by Amy S. Mushahwar.
This morning the FTC released a supplemental notice of proposed rulemaking on the Children’s Online Privacy Protection Act (COPPA) Rule. This is not a final rule. The notice suggests further modifications to proposed definitions released in the September 2011 Notice of Proposed Rulemaking on the…
This post was written by Joshua Marker.
Catalog and retail marketing in California just got a little bit trickier. No longer can retailers require that a customer provide a ZIP code to complete a credit card transaction, and this may impede the ability of many retailers to generate in-store marketing leads. On February 10, 2011, the California Supreme Court held that the Song-Beverly Credit Card Act (“the Act”) covers key components of an individual’s address as ‘personal identification information’ in a credit card transaction.
In that case, Pineda v. Williams-Sonoma Stores, Inc., No. S178241, Williams-Sonoma’s practice of collecting individual’s ZIP codes when completing a credit card transaction was at issue. Williams-Sonoma collected these ZIP codes for credit card verification purposes and developed a retail marketing lead list from its in-store transactions. The California Supreme Court found that this practice violated Section 1747.08(a)(2) of the Act, as ZIP codes are ‘personal identification information’ covered by the Act, and the collection of that information was thus prohibited.…
