Apple is days away from releasing the public version of iOS14.5, which will bring a seismic shift in the way the operating system functions with respect to privacy. In particular, the operating system introduces two major changes.

The first change is a requirement that all apps must include a privacy nutrition label within the App Store that helps users better understand the app developer’s privacy practices prior to download (this feature is actually already live). The second change is a requirement that all apps that use information for tracking purposes must obtain opt-in consent from the user prior to engaging in such tracking.

As a privacy lawyer in the ad tech space, I’ve been closely watching the dialogue around iOS14 since these changes were unveiled at WWDC last June, and I thought it would be helpful to provide my thoughts on these changes. This post reflects my own opinion, and not those of the firm or anyone else.


Continue Reading iOS 14.5: An Imperfect Step Forward for Privacy

On July 24, 2019, the FTC announced a $5 billion settlement with Facebook to address Facebook’s alleged violations of the FTC Act and its 2012 consent order with the FTC. The settlement comes as no surprise to the privacy community – Facebook has been closely scrutinized by the public and regulators since the Cambridge Analytica data incident in March 2018 and indicated to investors earlier this year that it anticipated a fine from the FTC between $3 and $5 billion.

We have read the complaint, settlement, and press releases issued by the FTC and Facebook, and provide our thoughts below on what it means for business:
Continue Reading Business Takeaways from the FTC $5 Billion Settlement with Facebook