FTC Settles Complaint Against Venmo

On February 27, the Federal Trade Commission (FTC) reached a settlement with Paypal, Inc. relating to the privacy and security practices of Venmo, Paypal’s peer-to-peer payment service. The FTC alleged that Venmo failed to adequately disclose to its users that transfers of funds from their Venmo balances to external bank accounts were subject to review, and such funds could be frozen or removed in cases of suspected fraud. The FTC’s complaint also charges that Venmo misled users about the scope of Venmo’s “bank grade security systems,” as well as the extent to which users could control the visibility of their transactions. Venmo allows individuals to send and receive…

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New Guidance about Transparency: Notices Must Be Accurate, Clear and Easy To Locate

Important guidance about the General Data Protection Regulation’s (GDPR) transparency requirements has been released from Europe. The Article 29 Working Party, an advisory body that oversees data protection in the EU, issued a paper that provides practical guidance and clarity about the obligations of data controllers with respect to informing individuals about the collection, use and protection of their data. The GDPR requires that notices must: be concise, transparent, intelligible and easily accessible (Article 12.1); use clear and plain language (Article 12.1); the requirement for clear and plain language is of particular importance when providing information to children (Article 12.1); be provided in writing “or by other means, including where…

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