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ARTICLE · 30 JANUARY 2012

Broken Privacy Promises From Upromise? FTC Settlement And Key Takeaways (Update)

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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According to the Federal Trade Commission, the most remarkable aspect of Upromise, an online college savings program, was not how much its users saved. Rather, it was how much they were giving away.

United StatesPrivacy
Jake Romero
Jake Romero
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According to the Federal Trade Commission, the most remarkable aspect of Upromise, an online college savings program, was not how much its users saved. Rather, it was how much they were giving away. The FTC has announced settlement regarding a complaint it had filed against Upromise, Inc. alleging that the corporation has violated the Federal Trade Commission Act ("FTC Act"). We have an analysis of the complaint and consent order and some key takeaways for businesses.

Upromise and the "TurboSaver Toolbar"

Since 2005, Upromise has operated a membership reward service that is designed to help its users create a savings account for future college tuition payments. Its users receive discounts and rebates on products they purchase from Upromise's merchant and retail partners and the value of those discounts and rebates is then collected in a college savings account. As part of its service, Upromise offered its users the Upromise "TurboSaver Toolbar," a software download

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