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The New EU-US Privacy Shield: Safe Harbor 2.0

Two days after the expiration of the informal deadline to replace the Safe Harbor Framework invalidated by the Court of Justice of the European Union in October 2015, the EU and US have come to terms on a new framework—the...more

Navigating the Unsafe Harbor: Keep Calm and Carry On

The Court of Justice of the European Union (CJEU) issued its landmark decision in Maximillian Schrems v. Data Protection Commissioner on October 6, 2015, ultimately invalidating the U.S.-EU Safe Harbor Framework. Under...more

Buried in the Fine Print—The FTC Addresses Prior Express Consent Under the TSR

In a July 14, 2015 letter to PayPal, the FTC indicated that consent language buried within a “lengthy user agreement” does not satisfy the requirement under the Telemarketing Sales Rule (TSR) that companies obtain prior...more

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