The Federal Trade Commission (FTC) entered into a proposed settlement with Unrollme Inc. (“Unrollme”), a free private email management service that helps customers manage the flow of subscription messages in their inboxes. The FTC alleged that Unrollme made misleading statements to consumers who may have had concerns about privacy and persuaded them to give their email accounts to the company.
Unrollme provides services that help minimize subscription email clutters by assisting consumers in unsubscribing from unwanted subscription email messages and consolidating wanted subscription messages into one daily email. In order to provide these services, Unrollme needs customers to provide Unrollme with full access to their email accounts so that it can scan the users’ inboxes for subscription emails.
FTC allegations in its complaint regarding Unrollme practices are deeply concerning to say the least. Unrollme provided its parent company, Slice Technologies, Inc. (“Slice”) access to its users’ email messages without notice or consent, to allow Slice to scan and extract data from the users’ electronic receipts (think about your Amazon receipts or other receipts you received from making an online purchase).
These deceptive practices were considered to be in violation of Section 5(a) of the Federal Trade Commission Act, 15 U.S.C. § 45(a).
PROPOSED RESOLUTIONS TO THE FTC COMPLAINT
The settlement prohibits Unrollme from making any misrepresentations to its users about how it accesses, collects, uses, stores or shares users’ data or emails. FTC further requires Unrollme to notify all its users about how it collects and uses data, delete all Unrollme and Slice stored data, and provide the FTC with periodic compliance reports and notices.
AVOIDING POTENTIAL PRIVACY LAWSUITS
This is not the first time that Unrollme activities have been questioned. Last year, in Cooper v. Slice Technologies, Inc., a privacy lawsuit was filed against Unrollme data mining procedures, stating that it did not adequately disclose to consumers the extent of its data mining practices and sold anonymized emails without their consent.
 Cooper v. Slice Technologies, Inc., No. 17-CV-7102 (JPO), 2018 WL 2727888 (S.D.N.Y. June 6, 2018)