Margaret Utterback quoted in article “Managing the Risky Business of Loyalty Programs”Compliance Week 03/31/15
Below is an excerpt:
“When you sign up for those programs, you are not generally anticipating that the information could be transferred to another organization and is an asset a company might someday sell,” says Margaret Utterback of the law firm Quarles & Brady. She draws a comparison to Facebook’s $22 billion purchase of the messaging service What’s App in 2014. The FTC intervened when Facebook first told users it would maintain What’s App’s existing privacy agreement, and then changed its mind. The FTC could likewise intervene in similar situations involving the sale or transfer of loyalty program data.