Shortly after FTC staff published the results of their study on cross-device tracking (described in this prior blog post), the FTC issued its own comprehensive report on the topic.  In addition to highlighting many of the same benefits and privacy concerns raised by cross-device tracking, the FTC report provides an update on industry self-regulatory efforts in this area, along with practical recommendations for those involved in cross-device tracking, based on learnings from past FTC enforcement actions.
Continue Reading Don’t Get Your Wires Crossed When Cross-Device Tracking

Earlier this month, the FTC announced that a third-party study and report on cross-device tracking had been completed by the Office of Technology, Research and Investigation (“OTech”), following up on their presentation on this topic at the FTC’s 2015 workshop.  The FTC released its own report on cross-device tracking last week, which will be covered in a subsequent blog post.  OTech’s study focused on: 1) what information companies are collecting and may be using to track consumers across devices, and 2) what companies are disclosing about their cross-device tracking in privacy policies or otherwise (the answer is not much!). 
Continue Reading FTC Highlights Third-Party Report Finding That Companies Are Hiding the Ball on Cross-Device Tracking

On December 20, the FTC announced a settlement with digital marketing platform Turn Inc. over claims that the company deceptively tracked users across the Internet for advertising purposes.  The announcement highlights the importance of maintaining an accurate privacy policy in a complex digital world and the need for advertisers, agencies, publishers and platforms to understand the legal and business risks posed by the use of cookies, tags, device identifiers and other digital marketing technology.

Continue Reading FTC Hits Targeting Platform Turn Inc. for Deceptive Online Tracking