Last week, Snap Inc. (“Snap” or the “Company”) – the parent company of the wildly popular app Snapchat (“Snapchat” or the “App”) – became a publicly traded company on the New York Stock Exchange in the biggest tech IPO since Alibaba in 2014.  Priced at $17 per share, the Snap stock opened at $24 per share on Thursday morning and closed at $24.48 per share, bringing the Company’s market capitalization to approximately $28 billion. In today’s post, we’re taking a closer look at Snap’s S-1 filing (“Snap S-1”) with the U.S. Securities and Exchange Commission (SEC) with a particular focus on the Company’s disclosures of risk factors associated with cybersecurity and privacy risks.  Continue Reading A Deep Dive into Privacy/Security Disclosures in Snap’s S-1

Written by Julia Siripurapu, CIPP

Just a little over a month after settling charges of false promises of disappearing user messages (among other things) with the Federal Trade Commission (“FTC”), mobile app developer Snapchat, Inc. (“Snapchat” or “Company”) announced (blog post) that on June 12th  the Company entered into an agreement with the Office of Maryland Attorney General Douglas Gansler to resolve similar claims of consumer deception as well as additional allegations of failure to comply with the Children’s Online Privacy Protection Act (“COPPA”) and its implementing rule (as amended, the “COPPA Rule”). Continue Reading Round Two for Snapchat: Agreement with the Maryland Attorney General Settling Claims of Consumer Deception and COPPA Violations

Written by Jake Romero, CIPP/US

As a country we are quickly approaching a time in which most adults will be disqualified from being elected to public office because of something they posted on their social media account while growing up.  Against this backdrop of over-sharing, Snapchat, Inc. won over the hearts of its users with the promise that its mobile application would permit the user to send messages that would “disappear” after a designated number of seconds.  As the popularity of the mobile application grew, so too did concerns regarding its data security practices and its ability to deliver on the promises made to its users.  By December 2012, various methods for accessing or keeping photos and video sent through the mobile app (“snaps”) began circulating on the Internet.  Then, in the final days of 2013, a vulnerability in the application allowed hackers to obtain and publish millions of Snapchat usernames and phone numbers. Continue Reading “Selfie” Assessment – 4 Key Lessons from Snapchat’s Settlement with the FTC