United States:
FTC Penalizes Membership Reward Service For Violating Order
19 June 2017
by
Daniel J. McLoon
,
Jonathon Little
,
Todd McClelland
,
Adam Salter
,
Undine Von Diemar
,
Olivier Haas
,
Richard Johnson
,
Mauricio Paez
,
Kevin Lyles
,
Jeff Rabkin
,
Michiru Takahashi
,
Jörg Hladjk
,
Anand Varadarajan
and
Nicole Perry
Jones Day
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On March 17, the Federal Trade Commission ("FTC")
announced a civil penalty against a membership reward
service, Upromise, for failing to disclose the extent of its data
collection practices. Despite a 2012 order requiring the company to
make clear and prominent disclosures, the FTC alleged that the
company failed to make appropriate disclosures or to obtain the
necessary assessments certifying protection of consumer data. As
part of the new order, the company must pay $500,000 and implement
the remedial measures prescribed in the 2012 order.
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