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$10,000,000 civil penalty for disclosing personal data without consent

Data Protection Report

that “uses cookies, pixel tags, and other storage and tracking technology to collect or receive information from [Cerebral’s] [w]ebsites and [a]pps based on [consumers’] usage activity.” The complaint alleged that the company’s data handling practices also resulted in unauthorized disclosures of personal information.

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Historic Charges: First Enforcement Action Filed by New York Department of Financial Services Under Cybersecurity Regulation

Data Matters

On July 21, 2020, the New York State Department of Financial Services (NYDFS or the Department) issued a statement of charges and notice of hearing (the Statement) against First American Title Insurance Company (First American) for violations of the Department’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R.