Penalty Amount
$100,000
Connecticut, Oregon, and the District of Columbia reached a $100,000 settlement with Easy Healthcare Corporation, the operator of the Premom ovulation tracking app, for sharing sensitive user health and location data with third parties without appropriate disclosures or user consent. The settlement requires the company to implement comprehensive privacy and security programs, obtain consent before sharing health or location data, and provide users with a method to delete their personal information.
Easy Healthcare must implement and maintain a comprehensive privacy and information security program. Specific requirements include: collecting personal information only for legitimate purposes; making enhanced disclosures about data collection; refraining from sharing health or location information with third parties without user consent and from using health information for targeted advertising; providing a method for consumers to request deletion of their personal information; conducting due diligence and monitoring of third parties; performing a privacy risk assessment considering risks to women; and undergoing independent assessments of its privacy and data security practices.
In-house legal teams should review vendor agreements (particularly those involving SDKs or third-party data processors) and customer-facing agreements (terms of service, privacy policies) for clauses governing data sharing, user consent, and data retention. Specific clauses to scrutinize include: data sharing/license provisions (to ensure they require explicit, prior consent for sensitive health and location data), breach notification requirements (to align with mandated security programs), and data retention/deletion terms (to guarantee a user deletion method is provided). Changes may be needed to mandate granular consent for health/location data, require audits of third-party SDKs, and incorporate explicit user deletion rights and timelines.
Entity
Easy Healthcare Corporation
Also known as: Easy Healthcare
Industry
Healthcare$100K
The FTC charged Easy Healthcare Corporation, operator of the Premom fertility app, with deceiving users by sharing their sensitive health data with third parties for advertising without consent and failing to notify breaches as required by the Health Breach Notification Rule. Under a proposed consent decree, the company will pay a $100,000 civil penalty, be barred from sharing health data for advertising, and must implement privacy and security measures.
Connecticut Attorney General William Tong joined a coalition of states and local governments in filing suit against NHTSA over its rule weakening fuel economy standards for new passenger cars and light trucks. The lawsuit alleges the rule violates the agency’s statutory mandate and the Administrative Procedure Act; no penalty or final remedy is reported.
Connecticut Attorney General William Tong joined a multistate coalition suing the EPA over its repeal of greenhouse gas pollution limits for power plants and separately filed a notice of intent to sue over regulation of existing gas plants. The coalition asks the court to overturn the repeal and restore the protections; the release reports no monetary penalty or final order.
$400.0M
Connecticut Attorney General William Tong announced a $400 million settlement with Sandoz Inc. and Fougera Pharmaceuticals Inc. resolving allegations that the generic drug manufacturers conspired to inflate prices, limit competition, and restrain trade. The settlement includes consumer restitution and injunctive reforms; court approval was being sought.
Connecticut Attorney General William Tong joined a coalition of 21 attorneys general in submitting a comment letter opposing a DHS rule that allows certain affirmative asylum applications to be referred to removal proceedings without an asylum officer interview. The coalition argues the rule violates federal law and harms asylum seekers, including unaccompanied children; this was a policy opposition letter, not a privacy enforcement action.
Connecticut and Massachusetts co-led a coalition protest urging FERC to reject the proposed NextEra Energy-Dominion Energy merger. The coalition argued that the merger could increase market power and threaten energy affordability, reliability, and competition; the release does not report a final enforcement decision or penalty.