FTC Enforcement

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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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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