FTC Enforcement

Click-to-Cancel Rules and Your SaaS Subscription Agreement

If you sell an auto-renewing subscription, your SaaS subscription agreement (and the cancellation flow that goes with it) is under more legal pressure now than it was a year ago, even though the FTC’s federal “click-to-cancel” rule was struck down in 2025. Enforcement didn’t stop. It just shifted to older

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A Few Things You Should Know About the NAI and SaaS Privacy

Short answer: the Network Advertising Initiative (NAI) is the self-regulatory body for third-party online advertising, and its Code of Conduct matters to SaaS vendors because it treats data that identifies a device or computer, not just a named person, as regulated. If your product touches third-party ads, tracking, or persistent

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A Brief Outline of Privacy Issues for App Developers.

Short answer: app developer privacy comes down to three things. If you build apps, you need a clear privacy policy, just-in-time notices when you collect sensitive data, and privacy built into the design from the start. The FTC, state regulators, and the app stores all expect it, and getting it

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2 Takeaways From the CarrierIQ Situation

Short answer: the CarrierIQ takeaways for software vendors come down to two things. In a vendor-plus-platform stack, the party that decides what data to collect and whether to disclose it carries the privacy responsibility. And a too-broad indemnity can put the software vendor on the hook for the platform’s mistakes.

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FTC’s Negative Option Rule

Short answer: the FTC’s Negative Option Rule is the federal standard for how you sell subscriptions, free-to-paid trials, and auto-renewals, and the core idea is simple: you cannot treat a customer’s silence as a “yes.” The headline “Click-to-Cancel” version of that rule was struck down by a federal appeals court

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Google Buzz FTC Settlement: 3 SaaS Privacy Takeaways

Short answer: the Google Buzz FTC settlement taught SaaS vendors three lessons: set new “connect people” features to off by default, never use data for a purpose beyond what your policy disclosed, and put one person in charge of privacy. A single default setting can trigger FTC action. Google settled

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