Kari Rollins and Julia Kadish of Sheppard Mullin write:
The FTC recently settled with smart lock maker Tapplock, Inc., a Canadian company, over allegations that it deceived consumers with false claims about its product’s security practices. These allegations arose based on vulnerabilities that a security researcher demonstrated – not in the aftermath of a data security breach where these complaints often originate.
In its complaint, the FTC cited claims Tapplock made in its product advertisements, including that the product was “secure,” with an “unbreakable” design. The FTC also noted that Tapplock’s privacy policy stated that the company deployed “reasonable precautions and follow[s] industry best practices to make sure [personal information] is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.”
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