On May 14, 2015, Visa announced several updates to its Global Compromised Account Recovery Program (“GCAR”), which helps card issuers recover costs and fraud losses after a data compromise. These modifications appear to be designed to address changes in the payment environment and align GCAR recoveries more closely with the current estimated costs and risks […]
Privacy Policy
FTC Settles With Retail Tracking Firm Regarding Alleged Opt-out Misrepresentation
On April 23, 2015, the FTC and Nomi Technologies, Inc. (“Nomi”) settled the FTC’s misrepresentation charges related to Nomi’s “Listen” service, a multiple sensor technology that allows retailers to measure consumers’ in-store movements. Nomi’s sensors track consumers as they browse physical stores. According to the complaint, “Nomi places sensors in its clients’ retail locations that detect […]
White House Releases Report on Big Data and Differential Pricing
The White House Council of Economic Advisors recently released a report titled “Big Data and Differential Pricing.” “Differential pricing” refers to the practice of charging different prices to different groups of people for the same (or similar) products or services. The White House report explores the uses of big data for differential pricing, including the […]
23 Privacy Enforcement Authorities Issue a Joint Open Letter to App Marketplaces
On December 9, 2014, a joint open letter (“Letter”) was issued to the operators of seven (7) app marketplaces, urging them to “make the basic commitment to require each app that can access or collect personal information, to provide users with timely access to the app’s privacy policy.” Although the Letter was sent to Apple, […]
CFPB’s Final Rule Allows Online Privacy Notice Posting In Certain Circumstances
The Consumer Financial Protection Bureau (CFPB) recently published a final rule regarding annual privacy notices from financial institutions to their customers. The rule allows financial institutions that limit their consumer data-sharing and meet other requirements to post their annual privacy notices online rather than delivering them individually. Under the Gramm-Leach-Bliley Act (GLBA), financial institutions generally […]