A recent settlement between a flashlight mobile application maker and the Federal Trade Commission shines some light on the agency’s requirements regarding the disclosure of data, according to Reed Freeman and Adam Fleisher on Morrison Foerster’s Socially Aware Blog.
The authors note that over the past years there have been many settlements between the FTC and companies it finds do not have actual practices that are consistent with the promises made in their privacy policies. However, this case is unique in that the FTC is alleging a material omission instead of a violation of an affirmative representation.
