On March 17, 2017, the Federal Trade Commission (FTC) announced that it had reached a $500,000 settlement with Upromise, a membership reward service aimed at families saving for college. The FTC had alleged that Upromise violated a 2012 FTC consent order by failing to make required disclosures about its data collection and use practices and not obtaining third-party assessments as agreed. This settlement illustrates not only the FTC’s continued focus on online data privacy and security issues, but also the Commission’s interest in ensuring that companies adhere to the terms of their settlement agreements.

Background and 2012 Order

Upromise offers a loyalty program that is free to join and provides credit toward college savings plans, or toward paying down student loans for members who make eligible purchases from partner businesses.