FTC v. CartManager
The FTC obtained a settlement from CartManager. CartManager operates shopping cart functionality as a service for third party website customers. CartManager used personal information from the shopping carts in conflict with customers’ privacy policies presented to users.
An unexpected change like that appears to leave the service provider at risk of an FTC enforcement action. While I’m sure some service providers engage in egregious behavior, I also hope the FTC will be tolerant if a service provider gets screwed by customers whose privacy policies were outside of the provider’s control.