The State of Texas and Meta Platforms Inc. (“Meta”) have agreed to a $1.4 billion settlement, to be paid out over five years, to resolve claims relating to Meta’s alleged use of facial recognition technology without user consent.  This settlement marks the largest privacy settlement obtained by a single state and is the first one

The California Privacy Protection Agency (“CPPA”) discussed at its July 16 meeting new enforcement focuses in addition to current goals.  While the new focuses are largely in line with general trends, they also serve as a reminder that specific and nuanced compliance decisions can make a big difference.

As the CPPA has made clear in

Minnesota becomes the latest state to move to pass legislation regulating the processing and controlling of personal data (HF 4757 / SF 4782). If signed into law by Governor Tim Walz, the Minnesota Consumer Data Privacy Act, or MCDPA, would go into effect on July 31, 2025 and provide various consumer data privacy

The FTC published guidance warning companies that “[i]t may be unfair or deceptive for a company to adopt more permissive data practices—for example, to start sharing consumers’ data with third parties or using that data for AI training—and only inform consumers of this change through a surreptitious, retroactive amendment to its terms of service or

The Colorado Department of Law (“DoL”) has published a shortlist of potential universal opt-out mechanisms (“UOOMs”).  Beginning on July 1, 2024, companies will be required to allow consumers to opt out of the sale of their personal data or use of their personal data for targeted advertising using any UOOMs that are ultimately included in

A Deep Dive Into FinCEN’s Latest Proposals Under the CTA

On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed rulemaking (“NPRM”) regarding access by authorized recipients to beneficial ownership information (“BOI”) that will be reported to FinCEN under the Corporate Transparency Act (“CTA”).  The CTA requires covered entities –

On October 20, 2022, Texas Attorney General Ken Paxton brought suit in Texas district court against Google for alleged violations of the Texas Capture or Use of Biometric Identifier Act (“CUBI”).  The  petition claims that Google violated CUBI by collecting, analyzing, and storing the facial geometry of individuals who appear in photos that have

On August 24, California Attorney General Rob Bonta announced a $1.2 million settlement with Sephora over allegations that the cosmetic retailer had violated the California Consumer Privacy Act (CCPA).  This first public enforcement action—and subsequent noncompliance letters the Attorney General sent to other retailers—clearly highlight the continued focus of regulators on online tracking practices and opt-out signals such

The August 31 closing of the California legislative session likely marked the end of hopes for an extension of the limited exemptions for employee and business-to-business (B2B) data that have existed for the California Consumer Privacy Act (“CCPA”) since its inception.  As a result, when the the California Privacy Rights Act (CPRA) goes into effect

On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Cyber Security Regulations.  The Amendments, if adopted, would further regulatory trends and impose important new requirements on covered entities.

The Amendments contain three significant changes relating to ransomware.  First, the Amendment specifically adds “the deployment of ransomware