On June 21, 2019, the Federal Trade Commission entered into a settlement agreement with Unrollme Inc., an on-line services company headquartered in New York, that helps consumers manage subscription emails by consolidating them into one daily email or “Rollup.” According to the complaint, consumers who subscribe to this service agree to allow Unrollme access to the email accounts connected with the subscriptions; the company then provides access to its parent company, Slice Technologies, Inc., which uses an automated crawler to identify user receipts in the inboxes, and then copy and store the receipts and the email messages to which they are attached. Slice uses a parser to extract data from the e-receipts, for anonymization and market research use. The complaint alleges that before May 2017, Unrollme did not state on its website that it would collect, maintain or sell information from the user’s e-receipts. The FTC alleges that consumers who did not initially agree to grant access to their inboxes received various messages encouraging them to grant access, including statements such as “Don’t worry, we won’t touch your personal stuff.” According to the FTC, over 55,000 people changed their minds and granted access to Unrollme after reading such statements or consulting with the company’s customer support services. The complaint alleges that these statements constituted unfair or deceptive acts or practices affecting commerce, in violation of Section 5(a) of the Federal Trade Commission Act, 15 USC § 45(a).
On August 8, 2019, the FTC voted to issue the proposed administrative complaint and to accept the consent agreement. The consent order gives the company ten days to delete from its systems all stored email purchase receipts and other consumer information obtained from the receipts. It also prohibits the company from misrepresenting the extent to which the company accesses, collects, uses, stores, or shares consumer information or emails. The order also requires the company to notify consumers whose email purchase receipts are collected for use in market research. Additional compliance measures imposed by the order include notification and acknowledgment of the order by company personnel for ten years.
The settlement and order will become final after a 30-day public comment period following publication in the Federal Register.