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FTC Issues Mobile App Guidance

The Federal Trade Commission (FTC) recently published guidance relating to the development and use of mobile applications.  In its publication, MARKETING YOUR MOBILE APP: GET IT RIGHT FROM THE START, the FTC addresses advertising and privacy issues relating to mobile apps. Specifically, the FTC reminds app developers to:

Tell The Truth About What Your App Can Do

Everything you proclaim, expressly or impliedly, about your app must be truthful and not misleading, and you cannot omit material information.

Disclose Key Information CLEARLY and CONSPICUOUSLY

Any disclosures about your app must be “big enough and clear enough that users actually notice them and understand what they say.”  

Build Privacy Considerations From the Start

Adopt privacy protections (e.g., limit the user information collected and securely store and safely dispose of such information), make the app’s default settings consistent with what the average consumer would expect, receive express user agreement to collect and share such information that is not obviously collected or shared.

Be Transparent About Your Data Practices

Be sure to explain what information your app collects, and what use you make of the information collected.

Offer Choices that are Easy to Find and Easy to Use

Provide options regarding privacy and data, such as privacy settings, opt-outs, and other mechanisms for user control of their personal information, and make sure such options are clear and conspicuous.

Honor Your Privacy Promises

Consistently apply the practices outlined in your privacy policy, privacy settings, and statements regarding security.  Also, receive users’ affirmative consent before making material changes to these policies and practices.

Protect Kids’ Privacy

If your app targets or collects information from children, you must follow the Children’s Online Privacy Protection Act (COPPA) and the FTC’s COPPA Rule.

Collect Sensitive Information Only With Consent

If you are collecting sensitive information such as medical, financial, or geolocation information, receive users’ affirmative consent before collecting.

Keep User Data Secure

At the very least, you must take reasonable steps to keep sensitive data secure.



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