Consent to Use of Data. Goldenshores Technologies and its subsidiaries and agents may collect, maintain, process and use diagnostic, technical and related information, including but not limited to information about your computer, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Goldenshores Technologies Software, and to verify compliance with the terms of the License. Goldenshores Technologies may use this information, as long as it is in a form that does not personally identify you, to improve our products or to provide services or technologies to you.

[Goldenshores and  Geidl] in connection with the advertising, promotion, offering for sale, sale, or dissemination of any mobile application that collects, transmits, or allows the transmission of geolocation information, in or affecting commerce, shall not collect, transmit, or allow the transmission of such information unless such application:

Clearly and prominently, immediately prior to the initial collection of or transmission of such information, and on a separate screen from, any final "end user license agreement," "privacy policy," "terms of use" page, or similar document, discloses to the consumer the following:

1. That such application collects, transmits, or allows the transmission of, geolocation information;

2. How geolocation information may be used;

3. Why such application is accessing geolocation information; and

4. The identity or specific categories of third parties that receive geolocation information directly or indirectly from such application; and

Obtains affirmative express consent from the consumer to the transmission of such information.

[W]ithin ten (10) days from the date of entry of this Order, shall delete all Covered Information relating to Affected Consumers that is within their possession, custody, or control and was collected at any time prior to the date of entry of this Order. [The FTC specifically defined Covered Information mean everything:]

"Covered Information" shall mean information from or about an individual consumer, including but not limited to:

(a) a first and last name;

(b) a home or other physical address, including street name and name of city or town;

(c) an email address or other online contact information, such as an instant messaging user identifier or a screen name; (d) a telephone number;

(e) a Social Security number;

(f) a driver's license or other state-issued identification number;

(g) a financial institution account number;

(h) credit or debit card information;

(i) a persistent identifier, such as a customer number held in a "cookie," a static Internet Protocol ("IP") address, a mobile device ID, or processor serial number;

(j) precise geolocation data of an individual or mobile device, including but not limited to GPS-based, WiFi-based, or cell-based location information ("geolocation information");

(k) an authentication credential, such as a username and password; or

(l) any other communications or content stored on a consumer's mobile device.

IT IS FURTHER ORDERED that respondent Erik M. Geidl, for a period of ten (10) years after the date of issuance of this order, shall notify the Commission of the discontinuance of his current business or employment, or of his affiliation with any new business or employment. The notice shall include respondent's new business address and telephone number and a description of the nature of the business or employment and his duties and responsibilities. Unless otherwise directed by a representative of the Commission in writing, all notices required by this Part shall be emailed to Debrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin: In the Matter of Goldenshores Technologies, LLC, File No. 132-3087.

• Software developers and vendors must review their privacy policies. The FTC is serious about its enforcement efforts. These enforcement and consumer deception issues can be avoided with proper disclosures.

• Err on the side of more disclosure over less disclosure. Yes, it is true that sometimes this makes the design of user interfaces more complicated and delays the install process. This is particularly true for mobile apps where the screen size adds additional limitations. But, it is better to err on the side of giving more information to consumers, unless, of course, your desire is to enter into a consent agreement with the FTC.

• The consumer's choice to accept or reject the EULA or data sharing must be a 'true' choice. As such, disclosures need to be presented to the consumer either before the app is installed on the device