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Robin Moore

The Recent Facebook Breach Shouldn’t Lead to GDPR Fines
Security

The Recent Facebook Breach Shouldn’t Lead to GDPR Fines

Facebook is reportedly facing a fine of up to $1.6B [https://www.cnbc.com/2018/10/04/facebook-data-breach-top-eu-regulator-officially-opens-investigation.html] for last month’s hack of ~50M Facebook accounts (~4M belong to Europeans). My view is that any fine would be a
04 May 2019 4 min read
Did Google violate its security obligations by retaining just two weeks of logging data?
Security

Did Google violate its security obligations by retaining just two weeks of logging data?

Here’s the background in case you missed it: Google+ had a vulnerability which made it possible for third parties to access, via the Google+ API, private Google+ user data between 2015 and March 2018. Google found no evidence that this bug was ever exploited, although it only had two
04 May 2019 5 min read
When circumstances change, update your advice (location-based data edition)
Privacy

When circumstances change, update your advice (location-based data edition)

Part of your job as product counsel is to monitor changing perceptions of privacy practices. When those perceptions have changed, you should re-do your legal analysis to ensure it’s still valid.
04 May 2019 2 min read
How to Make Your App Store TOS (More) Enforceable
Contracts

How to Make Your App Store TOS (More) Enforceable

Your TOS link must be “clear and conspicuous.” Your TOS link needs to be "clear and conspicuous" for it to be binding. “Clear and conspicuous” depends on typography, visual clutter, placement, and language—that is, the factors you’d expect if you’ve spent time with the various
27 Apr 2019 3 min read
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