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SettlementLow Risk

FTC Orders InMarket to Halt Precise Location Data Sales

InMarket MediaMay 1, 2024Federal Trade Commission

Summary

The FTC settled with InMarket Media for unlawfully collecting and using consumers' precise location data without adequate notice and consent. The order prohibits InMarket from selling or sharing precise location data, requires deletion of collected data, and mandates consumer consent mechanisms and privacy programs.

Remedy

InMarket is banned from selling or sharing precise location data, must delete previously collected location data unless consent is obtained or data is deidentified, must provide a way for consumers to withdraw consent and request deletion, and must create sensitive location data and privacy programs.

InjunctionData DeletionCompliance ProgramBan

Contract Impact

In-house legal teams should review all vendor agreements (particularly those involving SDK integrations or third-party data sources), customer contracts, and data processing addendums. Focus on clauses governing data collection scope, consent mechanisms, data sharing/licensing rights, data retention, and breach notification. Changes will likely be needed to explicitly prohibit the collection, use, or sharing of 'precise location data' without granular, informed consent; mandate data deletion protocols; require robust privacy programs; and impose obligations on any third-party SDK providers to obtain valid consumer consent.

Contract Search Terms

precise location data clauseinformed consent requirementSDK consent provisionsdata sharing prohibitiondata deletion mandateconsumer consent mechanismlocation data restrictionsthird-party data collectionprivacy program requirementsopt-out mechanism

Violation Types

Entity Details

Entity

InMarket Media

Also known as: InMarket

Industry

Data Broker

Official Sources

Source Evidence

Entity Name
"InMarket Media"
Violation Types
"failed to fully inform consumers about how their location data—which can include sensitive information about where they live, work and worship—would be used"
Violation Types
"failed to ensure that third-party apps that use its SDK obtained informed consent from consumers."
Violation Types
"precise location data"
Violation Types
"unlawfully collected and used consumers’ location data"

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