On February 27, 2018, the Federal Trade Commission (“FTC”) announced a proposed administrative settlement with PayPal, Inc. over allegations that the company failed to make adequate disclosures to users regarding its Venmo peer-to-peer payment service. The settlement underscores the importance of effectively disclosing material information to consumers, including accurately communicating privacy and security practices and user control over optional settings.

Specifically, the FTC alleged that Venmo


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