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 privacy policy.” In other words, the long-standing practice of simply updating the privacy policy may not provide sufficient notice to consumers…
By: Ballard Spahr LLP
By: Ballard Spahr LLP