California Issues Privacy Policy Warnings to App Developers

This article first appeared in Cyberlaw Currents, a Frankfurt Kurnit legal blog.

On October 30, 2012, the California Attorney General's office issued to up to 100 mobile app developers and companies. The Attorney General's letters, a sample version of which is available here notified addressees that they violated California's privacy law by collecting personally identifiable information from consumers without first posting their privacy policies conspicuously and in a way that is reasonably accessible to consumers. Companies that fail to correct the noncompliance within 30 days after being notified could face fines of up to $2,500 for each download of a noncompliant app. This enforcement action follows a Joint Statement of Principles wherein seven major app and social platforms (Amazon, Apple, Facebook, Google, Hewlett-Packard, Microsoft, and Research in Motion) committed to taking steps to enhance consumer privacy, as we discussed previously here.