While things like "We are committed to being transparent and open" don't 
necessarily mean much on their own, I disagree that they don't hold water 
at all. A privacy policy is *a company's promise to its users*, and any 
statement in a privacy policy is a promise...a *legal* promise (in other 
words, it's a unilateral contract). So when a company says, in a privacy 
policy, "We are committed to being transparent and open," that's actually a 
promise it's making, and it can find itself in trouble if it comes out, 
later, that its actions have not been transparent and open.

This has been made very clear in the recent *FTC v. Wyndham Hotels* decision, 
where Wyndham's privacy policy promised that it cared a lot about its 
guests' privacy, and used "industry standard practices" to secure personal 
information, and made all reasonable efforts to protect privacy, etc etc. 
But they had unpatched systems, systems with default admin passwords, and 
all kinds of terrible security practices, so over the course of two years 
they were hacked three times (but still left their systems unpatched). The 
FTC went after them for unfair and deceptive business practices, saying, 
look, if you've *promised* that you use industry standard practices to 
protect personal information, and you're clearly not using industry 
standard practices or taking reasonable efforts to protect your systems 
from intrusion, then your promise is deceptive. You can't just lie.

I know this is a bit of a tangent to go into on this forum over something 
minor like the promise to be transparent and open, but I think it's worth 
considering that as we look at terms of service and privacy policies, we're 
looking at *promises*. Enforceable promises. Sometimes they're promises the 
user is making to the company, but sometimes they're promises the company 
is making to the user. They're not just puffery. Puffery goes elsewhere.

Hannah

On Tuesday, May 20, 2014 7:38:28 AM UTC-7, Hugo Roy wrote:
>
> ↪ 2014-05-19 lun. 14:34, Alex Martin <[email protected] <javascript:>>: 
> > http://www.mozilla.org/en-US/privacy/ 
> > 
> > QUOTE: We are committed to being transparent and open. 
> > VERDICT: I think that's good. 
>
> I think that such commitments don’t hold much water. 
>
>
>

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