Penalty Amount
$100,000
Connecticut, Oregon, and the District of Columbia reached a $100,000 settlement with Easy Healthcare Corporation, the operator of the Premom ovulation tracking app, for sharing sensitive user health and location data with third parties without appropriate disclosures or user consent. The settlement requires the company to implement comprehensive privacy and security programs, obtain consent before sharing health or location data, and provide users with a method to delete their personal information.
Easy Healthcare must implement and maintain a comprehensive privacy and information security program. Specific requirements include: collecting personal information only for legitimate purposes; making enhanced disclosures about data collection; refraining from sharing health or location information with third parties without user consent and from using health information for targeted advertising; providing a method for consumers to request deletion of their personal information; conducting due diligence and monitoring of third parties; performing a privacy risk assessment considering risks to women; and undergoing independent assessments of its privacy and data security practices.
In-house legal teams should review vendor agreements (particularly those involving SDKs or third-party data processors) and customer-facing agreements (terms of service, privacy policies) for clauses governing data sharing, user consent, and data retention. Specific clauses to scrutinize include: data sharing/license provisions (to ensure they require explicit, prior consent for sensitive health and location data), breach notification requirements (to align with mandated security programs), and data retention/deletion terms (to guarantee a user deletion method is provided). Changes may be needed to mandate granular consent for health/location data, require audits of third-party SDKs, and incorporate explicit user deletion rights and timelines.
Entity
Easy Healthcare Corporation
Also known as: Easy Healthcare
Industry
Healthcare$100K
The FTC charged Easy Healthcare Corporation, operator of the Premom fertility app, with deceiving users by sharing their sensitive health data with third parties for advertising without consent and failing to notify breaches as required by the Health Breach Notification Rule. Under a proposed consent decree, the company will pay a $100,000 civil penalty, be barred from sharing health data for advertising, and must implement privacy and security measures.
$500K
Connecticut Attorney General William Tong announced settlements with SunRun, Inc., Elevate Solar Solutions, and two salespeople over allegations of deceptive solar sales, including impersonating consumers and locking homeowners into long-term contracts without consent. SunRun must pay $300,000 and provide consumer relief; Elevate and the salespeople face a stated $200,000 penalty, with $100,000 suspended subject to ongoing compliance.
$8.0M
Connecticut announced an $8 million settlement with Mylan over allegations that it used agreements to delay generic EpiPen competitors and took other actions that inflated prices. Mylan also agreed to provide 10,000 free EpiPens; the release states that Mylan denies wrongdoing.
Connecticut Attorney General William Tong joined a coalition of 22 attorneys general in filing an amicus brief challenging DHS’s policy and practice of conducting warrantless civil immigration arrests. The press release describes a court challenge, not a privacy enforcement action or monetary penalty.
$625K
Connecticut reached a $625,000 settlement with Frontier Communications Parent Inc. over an April 2024 breach in which compromised employee and vendor credentials were used to access internal systems and exfiltrate unencrypted personal information of 58,841 Connecticut residents. The settlement requires Frontier to strengthen its security program, implement specific safeguards and training, and obtain an independent third-party assessment.
$2.6M
Connecticut and New York found that Boston Children’s Health Physicians and its security vendor, XTIUM, failed to use reasonable safeguards, resulting in hackers accessing sensitive personal, medical, and employee information. The companies agreed to pay penalties totaling $2.64 million and implement enhanced cybersecurity measures.