The Department of Commerce warned Raging Wire twice to either remove the claims or take steps to recertify its participation in the Privacy Shield program. The company, however, failed to recertify until it was contacted by the FTC in October 2018.
The FTC also alleges that while RagingWire was a participant of the Privacy Shield program, the company failed to comply with the following requirements:
- to verify annually that it had made accurate statements about its Privacy Shield privacy practices
- to maintain a dispute resolution process for consumers who had privacy-related complaints about the company
- to affirm to the Department of Commerce that they will continue to apply the Privacy Shield protections to personal information collected while participating in the program