[{"source":"FTC USA Business Blog Posts","id":3203250,"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","pubDate":"Thu, 08 Oct 2026 08:06:59 +0200","url":"https://www.ftc.gov/business-guidance/blog/2019/04/i-dressup-data-security-mess","titre":"i-Dressup and a data security mess-up"},{"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","pubDate":"Thu, 08 Oct 2026 08:06:58 +0200","source":"FTC USA Business Blog Posts","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","id":3203247},{"source":"FTC USA Business Blog Posts","description":"Setting the debt parking brake lfair November 30, 2020 | 12:14PM Setting the debt parking brake By Lesley Fair What are the biggest risks of parking? A dinged door? A bruised bumper? For consumers victimized by the pernicious practice of debt parking, the impact on their financial health can be devastating. And if you’re a debt collector who engages in debt parking, an FTC settlement with Midwest Recovery Systems suggests you could face law enforcement action for violations of the FTC Act, the Fair Debt Collection Practices Act, and the Fair Credit Reporting Act. Just what is debt parking? It’s the practice of placing purported debts on consumers’ credit reports without first attempting to communicate with the consumer about the debt. Some call it “passive debt collection,” but there’s nothing passive about the injury it can inflict. Consumers often don’t learn about it until a mortgage company, prospective employer, or other decision maker pulls their credit report and spots what appears to be an unpaid debt. With a house, car, or job in the balance, many people feel pressured to pay up – even though they may not actually owe the money. That’s the tactic the FTC says Missouri-based Midwest Recovery Systems and owners Brandon M. Tumber, Kenny W. Conway, and Joseph H. Smith engaged in. According to the lawsuit, since at least 2015, the defendants have reported to credit reporting agencies more than $98 million in bogus or highly questionable debts for payday loans, debts subject to unresolved fraud claims, debts in bankruptcy, debts in the process of being rebilled to consumers’ medical insurance, and even debts people had already paid. The FTC alleges the defendants continued to collect those debts even in the face of billowing red flags about their validity. In fact, when consumers were able to dispute the purported debts, the defendants have regularly concluded that between 80% and 97% of them were either inaccurate or invalid. That’s not surprising, given that many of those debts originated from certain payday lenders and others whom the FTC has sued for their own illegal practices. Here’s an example cited in the complaint of how the defendants used debt parking to help line their pockets with millions in gross revenue. When applying for a mortgage, a consumer was told that an outstanding medical debt of $1,500 had lowered his credit score, which threatened to put the kibosh on buying a house. He contacted the hospital where he supposedly owed the debt, only to be told that he owed just an $80 co-pay. In spite of that, the FTC says the defendants refused to remove the debt and threatened the consumer with a lawsuit if he didn’t pony up. His complaint was one of thousands that Midwest Recovery received. For people who work in the collections field, the pleading in this case merit a careful read. In addition to alleging the defendants made false or unsubstantiated representations in violation of the FTC Act and the Fair Debt Collection Practices Act , the complaint expressly challenges their debt parking tactics as an unfair practice under the FDCPA. The FTC says they also violated the FDCPA by failing to provide validation notices – one of the protections in the statute designed to ensure consumers have the information they need to dispute an invalid debt. Three other counts charge the defendants with violating the Fair Credit Reporting Act by furnishing information to credit reporting agencies they knew or had reasonable cause to believe was inaccurate, by failing to conduct reasonable investigations of disputes, and by failing to report the results of those investigations to consumers. The settlement suggests some takeaway tips for others in the collections ecosystem. Consumers’ credit reports are a NO PARKING zone. This is the first FTC case to address debt parking – and thus the first to challenge the practice as unfair under the FDCPA – but the message couldn’t be clearer. Debt collectors that park fake or","id":3201875,"titre":"Setting the debt parking brake","url":"https://www.ftc.gov/business-guidance/blog/2020/11/setting-debt-parking-brake","pubDate":"Wed, 07 Oct 2026 14:05:06 +0200"},{"pubDate":"Tue, 06 Oct 2026 08:06:23 +0200","url":"https://www.ftc.gov/business-guidance/blog/2018/08/first-consumer-review-fairness-case-takes-promoters-big-bucks-amazon-claim","titre":"First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim","source":"FTC USA Business Blog Posts","id":3199075,"description":"First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim lfair August 6, 2018 | 11:11AM First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim By Lesley Fair T he marketers behind a purported money-making promotion called Sellers Playbook appear to have skipped the chapter about complying with federal and state consumer protection laws. That’s the allegation in a complaint filed by the FTC and the Minnesota Attorney General . In addition, it’s the FTC’s first case charg ing violations of the Consumer Review Fairness Act. The roots of the allegations go back to another venture sued by the FTC earlier this year: FBA Stores, also known as Amazing Wealth System and Amazon Wealth Systems. The defendants in that case ran online ads and in-person workshops that claimed to reveal the secret s of making major money on Amazon. But few, if any, of the consumers who forked over thousands of dollars and implemented their “plug-and-play systems” earn ed the kind of cash the defendants claimed. Which brings us to Sellers Playbook, Exposure Marketing, Jessie Conners Tieva, and Matthew Tieva – Minnesota-based defendants charged with pitching the same kind of “secrets” to making big bucks on Amazon . According to the just-filed lawsuit , the striking similarities should come as no surprise. That ’s because defendant Jessie Tieva was a regular speaker at Amazing Wealth Systems’ workshops. How successful was she in getting consumers to sign up? The complaint charges that Ms. Tieva and her team generated more than $3.4 million in sales for Amazing Wealth Systems. And let’s be clear: We’re not talking about $3.4 million in sales by consumers who successfully implemented the system. We mean $3.4 million that consumers shelled out to the operators of Amazing Wealth Systems for which Tieva was paid a handsome commission. The complaint alleges that the new Sellers Playbook venture is, in effect, a copycat of the now-defunct Amazing Wealth Systems operation. The earning claims certainly have a familiar ring to them. Here’s how Sellers Playbook touted their “opportunity”: “Holy cow, guys. That’s when you start seeing the returns of what we want you to have, $20,000 a month,” “Potential Net Profit: $1,287,463.38,” “Starting with $1000...1 year later over $210,000,” and “How many of you would like to learn how to turn a $5- to $10,000 investment into a $25- to a $1.2 million return with your investment? Yeah. And you’re going to learn those strategies before you leave here today. There are a few other things Amazon Wealth Systems and Sellers Playbook have in common: 1) Neither company has any affiliation with Amazon; and 2) Both companies charged consumers hundreds of dollars – or even hefty five-figure fees – to sign up. Of course, few consumers make the kind of earnings the defendants claimed. According to the complaint, many of the webpages promoting Sellers Playbook contained an inconspicuous earnings disclaimer in grey near the bottom of the page. What’s more, at a live event, the defendants briefly displayed this slide, which one of the presenters downplayed with this statement: “That’s why they have us do this again. It makes the lawyers happy, disclaimers. But you got to do your part. Money’s not going to fall from the sky. But as long as you do a part, it’s going to happen.” T he complaint challenges the defendants’ earning claims as false or unsubstantiated under FTC law and the Minnesota Prevention of Consumer Fraud Act. What’s more, the lawsuit alleges multiple violations of the FTC’s Business Opportunity Rule . The FTC and the AG also charge that provisions in the defendants’ form contracts try to restrict consumers’ ability to post reviews of their products, services, or conduct , in violation of the Consumer Review Fairness"}]