[{"url":"https://www.ftc.gov/business-guidance/blog/2019/04/i-dressup-data-security-mess","source":"FTC USA Business Blog Posts","id":3203250,"pubDate":"Thu, 08 Oct 2026 08:06:59 +0200","titre":"i-Dressup and a data security mess-up","description":"i-Dressup and a data security mess-up lfair April 24, 2019 | 3:08PM i-Dressup and a data security mess-up By Lesley Fair Kids love to play dress-up, but parents wouldn’t want them rummaging through the attic or climbing to the top shelf of the wardrobe without permission and proper supervision. The i-Dressup.com website offered users – including children – a virtual way to play dress-up and design clothes without those potential dangers. But according to an FTC complaint, Unixiz, Inc. , the company behind i-Dressup, violated the Children’s Online Privacy Protection Act in ways that created different kinds of risks. COPPA puts two separate sets of protections in place to help keep parents in control of personal information collected from their kids online. First, COPPA-covered companies must clearly disclose their information policies and get parental consent before collecting personal information from children under 13. Second, companies must provide reasonable and appropriate security for the data they collect. According to an FTC settlement, i-Dressup fell short on both COPPA requirements. The complaint alleges i-Dressup failed to provide sufficient notice on its site of the information it collected online from kids, how it used it, its disclosure practices, and other specifics required by the COPPA Rule. The company’s direct notices to parents were deficient, too. Among other things, they didn’t include the COPPA-required statement that if parents don’t provide consent within a reasonable time, i-Dressup will delete their online contact information from its records. Stick with the story because that failure turned out to be particularly troubling. In addition to letting users play online games, i-Dressup featured a community where they could “explore their creativity and fashion sense with unique personal profiles” and interact with others. To register, i-Dressup required people to submit a user name, password, birthdate, and email address. If the birthdate indicated the person was under 13, the email field changed to “Parent’s Email.” Once the under-13 user filled in the required fields and clicked “Join Now,” i-Dressup collected the personal information and sent a message to the address entered into the Parent’s Email field. The person receiving the email could consent by clicking the “Activate Now!” button. However, if the parent didn’t give consent, i-Dressup retained the personal information it had collected from the child online. The FTC says the company’s failure to delete that information violated Section 312.5(c)(1) of the COPPA Rule. In addition to violating COPPA’s parental consent provisions, i-Dressup allegedly violated the Rule’s data security requirements . According to the FTC, i-Dressup stored and transmitted users’ personal information (including passwords) in plain text. In addition, the company failed to perform network vulnerability testing of its network, even for well-known threats like SQL attacks; it didn’t implement an intrusion detection and prevention system; and it didn’t monitor for potential security incidents. The upshot? The company learned that a hacker had gained entry to its network and accessed information about 2.1 million users, including approximately 245,000 users who indicated they were under 13. To settle the case , i-Dressup and its owners will pay a $35,000 civil penalty. They’re also prohibited from violating COPPA in the future, and can’t sell, share, or collect any personal information until they implement a comprehensive data security program and get independent biennial assessments. In addition, they’ll have to provide the FTC with an annual certification of compliance. The message for sites and operators covered by COPPA is that an effective system of parental consent is only the first step toward compliance. Section 312.8 of the COPPA Rule also requires you to “establish and maintain reasonable"},{"description":"FTC consumer protection year in review offers 2020 vision for your business lfair January 8, 2020 | 9:26AM FTC consumer protection year in review offers 2020 vision for your business By Lesley Fair They say hindsight is 20/20, but what about foresight? We’re not ones to prognosticate, but a look at notable FTC cases and initiatives from the past year suggests some topics likely to be top of mind in months to come. Here is a non-exhaustive list of issues in our 2019 rearview mirror and likely visible through the 2020 windshield. Consumer privacy. The FTC’s $5 billion enforcement action against Facebook made history and headlines, but the other notable part of the case is the monumental change the order mandates to Facebook’s privacy ecosystem. The Commission opinion in Cambridge Analytica reaffirms the proposition that like any other claim, a company’s privacy promises are viewed through the lens of established FTC consumer perception principles. A series of cases demonstrates the agency’s continued commitment to challenging false or misleading representations about businesses’ compliance with the EU-U.S. Privacy Shield Framework. Another important development is the FTC’s proposed settlement with Retina-X . It’s our first action against a marketer of stalking apps – software that allowed purchasers to monitor the mobile devices on which they’re installed, without users’ knowledge. COPPA. Congress passed the Children’s Online Privacy Protection Act to ensure that when it comes to the collection of kids’ personal information online, parents are in the driver’s seat. The FTC settlement with YouTube – brought in conjunction with the New York Attorney General – alleges that the company collected kids’ personal data without parental consent, in violation of the COPPA Rule . The $170 million civil penalty broke the record for the largest remedy in an FTC COPPA case, set months before in our $5.7 million settlement with Musical.ly , now known as TikTok. If you’re a YouTube channel owner, read a special Business Blog post for tips on determining if your content is directed to children. Data security. Is your company honoring its data security promises and taking reasonable steps to safeguard the sensitive information in its possession? The FTC, CFPB, and State AG actions against Equifax illustrate how consumers are injured when companies ignore reasonably foreseeable threats. The settlement, which totals between $575 million and $700 million – also reminds businesses that heeding warnings about known risks is more prudent (and cost-effective) than the alternative. Three threads tie together the FTC’s unrelated actions against LightYear Dealer Technologies and InfoTrax Systems . They both sell management software to specific industries. They both allegedly failed to take reasonable steps to secure their networks, resulting in damaging data breaches. And they’re both covered by similar new orders the FTC has introduced in recent data security cases. If you or your clients are players in the Internet of Things, the settlement of the FTC’s litigation against connected device company D-Link sends an unmistakable message: The future of the IoT marketplace depends on secure software development. Endorsements, certifications, and influencers. Why is the FTC concerned about the accuracy of endorsements and certifications? Because they’re material to consumers. The FTC says Truly Organics’ claim that its personal care products were “certified organic” lathered up a double bubble of deception. First, its merchandise contained ingredients that weren’t organic. Second, the company falsely claimed that its products were certified by USDA’s National Organic Program. Other FTC developments focused on the use of endorsements in social media. The FTC’s action against Devumi alleges the company sold fake followers, phony subscribers, and bogus","pubDate":"Thu, 08 Oct 2026 08:06:58 +0200","id":3203247,"titre":"FTC consumer protection year in review offers 2020 vision for your business","url":"https://www.ftc.gov/business-guidance/blog/2020/01/ftc-consumer-protection-year-review-offers-2020-vision-your-business","source":"FTC USA Business Blog Posts"},{"description":"Brussels, 12 September - During its September plenary meeting, the European Data Protection Board (EDPB) has adopted guidelines on the interplay between the Digital Services Act (DSA) and the General Data Protection Regulation (GDPR) . These are the first set of EDPB guidelines on the interplay between the GDPR and the EU’s recently adopted digital laws. The DSA aims to complement the rules of the GDPR to ensure the highest level of protection of fundamental rights in the digital space. Its main goal is to create a safer online environment in which the fundamental rights of all users, including the right to freedom of expression, are protected. It applies to online intermediary services , such as search engines and platforms. Several provisions included in the DSA entail the processing of personal data by intermediary service providers. The EDPB guidelines contribute to the consistent application of the DSA and of the GDPR, insofar as some provisions of the DSA concern the processing of personal data by intermediary service providers and include references to GDPR concepts and definitions. While it is up to the competent authorities under the DSA - with the support of the European Board for Digital Services and EU courts - to interpret the DSA, there are a number of provisions which relate to the GDPR. These include: notice-and-action systems that help individuals or entities report illegal content recommender systems used by online platforms to automatically present specific content to the users of the platform with a certain relative order or prominence the provisions to ensure a high level of privacy, safety, and security of minors and prohibiting that profile-based advertising using their data is presented to them transparency of advertising by online platforms prohibition of profiling-based advertising using special categories of data  The EDPB guidelines help to understand how the GDPR should be applied in the context of DSA obligations. The EDPB also provides practical guidance relating to the cross-regulatory cooperation between authorities to coordinate enforcement which will provide more legal certainty for intermediary service providers and ultimately to protect the rights and freedoms of individuals. The guidelines will be subject to public consultation, providing stakeholders with the opportunity to comment and provide feedback. EDPB Chair Anu Talus said: “By clarifying the interplay between the DSA and the GDPR, these guidelines mark a significant step towards ensuring a coherent and effective EU digital rulebook, and they will help uphold the fundamental rights and freedoms of individuals. I hope that stakeholders, including the competent authorities under the DSA, will make the most of the opportunity to contribute to the public consultation\". More work in the pipeline Following these first guidelines on the interplay between the GDPR and the DSA, further work is underway with other regulators to clarify the new cross-regulatory landscape and maintain coherent and consistent safeguards for the protection of personal data. In this regard, the EDPB is working on joint guidelines with the European Commission on the interplay between the Digital Markets Act (DMA) and the GDPR, as well as on joint guidelines on the interplay between the AI Act and EU data protection laws.","id":2368407,"pubDate":"Fri, 12 Sep 2025 15:51:31 +0200","titre":"Interplay between the DSA and the GDPR: EDPB adopts guidelines","url":"https://www.edpb.europa.eu/news/news/2025/interplay-between-dsa-and-gdpr-edpb-adopts-guidelines_en","source":"EDPB News"}]