Carolina Alonso

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Modeling the Privacy Catwalk: Practical Steps Forward

By Carolina Alonso and Nikki Edmunds on September 28, 2022 Posted in Data Privacy

What’s Trending? (Privacy a la Mode) Notable fashion brands have been engaging in a “trial period” of new technologies as privacy laws and privacy enforcement are trending – for example, exploring integrating branding into digital assets in video games, virtual reality (VR) and augmented reality (AR) technology, metaverses, and non-fungible tokens (NFTs). Fashion naturally pushes … Continue Reading

Focus on Children’s Privacy Intensifies as Daily Life Moves Online

By Carolina Alonso and Melinda L. McLellan on April 9, 2020 Posted in Children’s Privacy

With physical schools closed indefinitely, classrooms have moved online, either introducing or significantly expanding children’s use of virtual education technology and highlighting certain privacy concerns. Responding to this evolving environment, on April 9 the Federal Trade Commission (FTC) issued COPPA Guidance for Ed Tech Companies and Schools during the Coronavirus to address some common compliance … Continue Reading

Hoping for a New Year’s Resolution: Clarity on the Sale of Personal Information of California Minors

By Carolina Alonso, Alan L. Friel and Patrick Waldrop on January 9, 2020 Posted in Children’s Privacy

Those who keep an eye on privacy laws may be familiar with how monumental the Children’s Online Privacy Protection Act (COPPA) was when it first became effective in 1998. COPPA requires online services that directly target children under the age of 13, or reasonably know that children visit the online service, to obtain verifiable parental … Continue Reading

Children’s Privacy Law Updates: Tricks or Treats?

By Carolina Alonso and Patrick Waldrop on October 31, 2019 Posted in CCPA, Children’s Privacy

It’s finally here! Halloween, the day every kid dreams of for months. It’s a scary time in the world of children’s privacy law – what with the California Consumer Privacy Act (CCPA) lurking around the corner and the specter of FTC enforcement still lingering in the air. But this year, you’ve planned. You know exactly … Continue Reading

New FTC Provides Insights Into Its Plan for a Balanced Approach to Data Privacy and Security

By Alan L. Friel, John Busch and Carolina Alonso on December 19, 2018 Posted in Federal Legislation, GDPR, Online Privacy

This year brought unprecedented focus on consumer privacy – the rollout of the European Union General Data Protection Regulation (GDPR), the Cambridge Analytica controversy and Congressional hearings, a GDPR-light law coming out of California, more and bigger security incidents, and multiple proposals for an omnibus federal data protection law. The Federal Trade Commission (FTC or … Continue Reading

Connecting the Dots Between Security Practices and Legal Obligations: California’s Connected Devices Bill

By Carolina Alonso and Alan L. Friel on April 4, 2018 Posted in Internet of Things

Turning on the lights, hearing the weather forecast, learning fun facts, and playing your favorite song in the kitchen are simple when one can give short voice commands to a personal assistant device that is connected to the internet and to other devices in your home. Connected devices are increasingly being used in the home, … Continue Reading

The Video Privacy Protection Act: Watching the Courts Through Crossed Eyes

By Carolina Alonso, Alan L. Friel and Niloufar Massachi on March 7, 2018 Posted in Advertising, Behavioral Advertising, Children’s Privacy, Geolocation, Information Governance, Information Security, Marketing, Online Privacy, Privacy Class Actions

The Video Privacy Protection Act (VPPA), passed by Congress in 1988, is intended to prevent a “video tape service provider” from “knowingly” disclosing an individual’s “personally identifiable information” (PII) to third parties where that individual “requested or obtained … video materials,” such as “prerecorded video cassette tapes or similar audio visual materials.” At the time … Continue Reading

Toying With Children’s Data: Lessons From the FTC’s First Connected Toys Settlement Action

By Alan L. Friel and Carolina Alonso on January 17, 2018 Posted in Advertising, Children’s Privacy

Every year, especially around the holidays, more and more products that connect to the internet hit the market. For adults, connected home devices that act like personal domestic assistants have become increasingly popular. Children have been adding connected toys, some of which have the intelligence and programming to become a child’s best friend, to their … Continue Reading

From the Mouths of Babes: FTC Issues COPPA Enforcement Policy Regarding Voice Recordings

By Carolina Alonso, Alan L. Friel and Melinda L. McLellan on November 7, 2017 Posted in Children’s Privacy, Enforcement, Internet of Things, Online Privacy

On October 23, the Federal Trade Commission (FTC) released new guidance on how the Children’s Online Privacy Protection Act (COPPA) Rule may apply to audio recordings of children’s voices collected by websites and online services. Reflecting the FTC’s recent focus on privacy and security concerns related to the Internet of Things (IoT), the nonbinding Enforcement … Continue Reading