Seller’s privacy policies and transferring PII
- The court—following the appointment of a consumer privacy ombudsman, proper notice and a hearing—approves the transaction, finding that no showing was made that the transfer would violate applicable law.
Draft privacy policies with the future in mind
Avoiding the pitfalls
In order to avoid costly legal challenges and to facilitate the transfer of business assets that include PII, businesses should pay careful attention to privacy policies. Ultimately, it pays to think ahead when drafting privacy policies and to be diligent when reviewing them for a proposed purchase or sale of assets that include personal information—particularly in the bankruptcy context.