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App developers: Consider state law

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States have become more aggressive when it comes to privacy laws, with California definitely leading the pack.

One issue as of late: Online privacy statements and when they should be disclosed to consumers. The state attorney general has decided to pursue 100 mobile app developers and companies, for possible violations of the California Online Privacy Protection Act, which governs online services that collect personally identifiable information.

The AG initially targeted "those who have the most popular apps available on mobile platforms," a statement from the AG's office said. Companies will have 30 days to "conspicuously post" a privacy policy within their app that informs users of what personally identifiable information about them is being collected and what will be done with that data.

Compliance Week notes that in February, the state reached an agreement with Amazon, Apple, Google, Hewlett-Packard, Microsoft and Research in Motion to give consumers an opportunity to review an app's privacy policy before they download the app rather than after. Facebook subsequently signed on as well.

Companies will no doubt rush to comply.

"Although specific companies receiving the letters were not named, media reports have identified some of the larger ones as United Airlines, Delta, and OpenTable," ComplianceWeek noted.

Other states may try to put this issue in play as well. It does not seem onerous to re-engineer certain account opening paths to disclose the privacy statement earlier.

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