Privacy & Information Security Law Blog

On August 8, 2019, the FTC announced that Unrollme Inc. (“Unrollme”), an email management company, agreed to settle allegations the company deceived consumers about how it accesses and uses their personal emails. Unrollme offered users a service whereby the company would help unsubscribe users from unwanted subscription emails. In connection with this service, Unrollme required users to provide the company with access to their email accounts. The FTC alleged that Unrollme falsely told consumers it would not “touch” their personal emails. In fact, the FTC alleged, Unrollme shared its users’ email receipts (“e-receipts”) (i.e., emails sent to consumers following a completed transaction) with its parent company, Slice Technologies, Inc. The FTC’s complaint alleged that the parent company used information from the e-receipts (such as the user’s name, address, and information about products or services the individual purchased) for purposes of its own market research analytics products.

In addition, the FTC alleged that Unrollme made false and deceptive statements to consumers who declined to grant Unrollme permission to access their email account during sign-up to persuade such consumers to grant the company access. The allegedly false and deceptive statements assured users that Unrollme would not “touch” their personal emails, but did not tell consumers that Unrollme would collect their e-receipts and sell that information. According to the FTC, “thousands of consumers changed their minds and signed up for Unrollme in response to these assurances.”

As part of the proposed settlement with the FTC, Unrollme is prohibited from misrepresenting the extent to which it collects, uses, stores or shares information it collects from its users. The company also must notify users who enrolled in the service after viewing one of the allegedly deceptive statements about how it collects and shares e-receipt information. The proposed settlement also would require Unrollme to delete (from its own systems and Slice’s systems) stored e-receipts previously collected from consumers unless Unrollme obtains those individuals’ affirmative, express consent to maintain the e-receipt. The proposed consent agreement was approved in a 5-0 vote by the FTC and will soon be subject to a 30-day public comment period.

On December 17, 2019, the FTC approved the settlement with Unrollme in a 4-1 vote (with Commissioner Rohit Chopra abstaining).