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#2247516 - 01/12/21 05:36 PM Farming Data from Apps
Tesla Offline
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Joined: Nov 2003
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Hi! I have a question. We have an app that innocently offers to track spending, calculate net worth, track budget goals and manage cash flow. If that information can be used to promote certain products or services to customers are there any disclosures required and do those disclosures need to appear on advertisements for that app?
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eBanking / Technology
#2247782 - 01/18/21 03:47 PM Re: Farming Data from Apps Tesla
Andy_Z Offline
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Andy_Z
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Posts: 27,196
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Advertising disclosures would be on the ads themselves. If the app is gathering data and ads are generated from that data, the ad has the disclosure per Reg Z, DD, etc. and the app should (IMHO) indicate how the information may be used, some privacy info, and perhaps an opt-out. You're getting into legal EULA disclosures and the results may be one of those state laws are getting into where consumers have a right to see what is collected and where and to have data removed.
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#2247783 - 01/18/21 03:48 PM Re: Farming Data from Apps Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,620
Ok - thank you! I just felt like something was wrong with this idea but couldn't put my finger on it. Thanks again.
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