On December 18, the Federal Trade Commission approved a settlement of claims against Alexander Nix, the former CEO of Cambridge Analytica, LLC, and Aleksandr Kogan, an app developer who worked with the company, regarding their roles in allegedly deceiving consumers in order to collect personal information for voter profiling and targeting.

The FTC’s complaint claimed that the individuals used Kogan’s app, GSRApp, to collect Facebook data from app users and their associated Facebook friends. The FTC claimed the app specifically and falsely stated that it would not collect user names or personally identifiable information.

As part of the settlement, the FTC announced that:

Kogan and Nix are prohibited from making false or deceptive statements regarding the extent to which they collect, use, share, or sell personal information, as well as the purposes for which they collect, use, share, or sell such information. In addition, they are required to delete or destroy any personal information collected from consumers via the GSRApp and any related work product that originated from the data.

Previously, the FTC announced an Opinion finding that Cambridge Analytica – which filed for bankruptcy in 2018 – engaged in similar conduct in violation of the FTC Act. That Opinion can be found here.

This FTC settlement serves as a reminder of the potential for enforcement and other actions against the individual operators and executives of companies in the consumer space, and specifically those in the business of collecting consumer data.