Consumers frequently reveal personal information about themselves through a variety of daily online and offline activities. For fashion designers and retailers, this consumer information represents a valuable tool to identify, target, and expand customer advertising and messaging. This information can be utilized by employing a data broker, or a company who aggregates consumer information and do provide information about the relevant consumer marketplace. Data brokers collect, maintain, manipulate, and share a significant amount of data about consumers without ever directly interacting with them. While data brokers afford a major advantage for retailers, including fashion companies, they also raise privacy concerns for the consumers that data brokers profile. The Federal Trade Commission (“FTC”) recently issued a report summarizing the results of its study on the activities of nine data brokers, and recommended that Congress consider enacting legislation to make data broker practices more transparent or to give consumers greater control over the personal information that is collected about them and shared by data brokers.[1] This post summarizes the portions of the FTC’s report that are most relevant for fashion retailers and designers.
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Lindsay Colvin Stone
Lindsay Colvin Stone is an associate in the Labor and Employment Practice Group in the firm's New York office.
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