Following the public comment period, the Federal Trade Commission (“FTC”) this week approved a final order settling charges that Upromise, Inc., a membership reward service aimed at consumers trying to save money for college, used a web browser toolbar to collect consumers' personal information without adequately disclosing the extent of the information it was collecting.

Under the settlement, Upromise must clearly disclose its data collection practices and obtain consumers' consent before installing or re-enabling any such toolbar products. The company must also notify consumers how to disable the data collection tool on their computers, and it is prohibited from making misrepresentations about how the company maintains the privacy and security of consumers' personal information. Upromise must also establish a comprehensive information security program and obtain biennial independent security assessments for the next 20 years.

Click here to read the FTC’s press release about the Final Order.