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Jenna Zhang

Jenna Zhang advises clients across industries on data privacy, cybersecurity, and emerging technologies. 

Jenna partners with clients to ensure their compliance with the rapidly evolving federal and state privacy and cybersecurity laws. She supports clients in designing new products and services, drafting privacy notices and terms of use, responding to cyber and data security incidents, and evaluating privacy and cybersecurity risks in corporate transactions. In particular, she advises clients on substantive requirements relating to children’s and student privacy, including COPPA, FERPA, age-appropriate design code laws, and social media laws.

As part of her practice, Jenna regularly represents clients in data privacy investigations and enforcement actions brought by the Federal Trade Commission and state attorneys general. She also supports clients in proactive engagement with regulators and policymakers to ensure their perspectives are heard.

Jenna also maintains an active pro bono practice with a focus on supporting families in adoptions, guardianships, and immigration matters.

Recently, California Governor Gavin Newsom signed a sweeping set of laws related to minors’ privacy and safety, including new laws that restrict covered platforms from providing certain features to users under 16, impose a duty of care on social media platforms, revise the state’s Age-Appropriate Design Code, modify the state’s age-assurance requirements governing age signals, and impose safety requirements on AI chatbots. This blog summarizes the key takeaways from these new laws.

Continue Reading California Enacts Several Minors’ Privacy and Safety Laws

On August 19, 2026, Connecticut Attorney General William Tong announced a $275,000 settlement with online tax preparation company TaxAct over allegations that the company improperly disclosed taxpayer information to advertising partners through third-party tracking technologies on its website. The Attorney General alleged that, between January 2018 and December 2022, TaxAct used third-party tracking technologies for analytics and marketing purposes and, in doing so, disclosed detailed taxpayer information without informing consumers.

The settlement is notable because it highlights regulatory scrutiny over the disclosure of financial information, and also because it imposes extensive governance, monitoring, and auditing requirements on TaxAct relating to the use of third-party tracking technologies. In addition, the settlement does not specify what law was allegedly violated.

Continue Reading Connecticut Attorney General Settles with TaxAct Over Sharing Taxpayer Data

On July 28, 2026, the New York Office of the Attorney General released final rules (the “Rules”) implementing the Stop Addictive Feeds Exploitation (SAFE) for Kids Act, which goes into effect on January 25, 2027.

The SAFE for Kids Act requires online “addictive social media platforms,” which are defined as websites, online services, and applications that offer an “addictive feed” as a significant portion of their services, to restrict providing an “addictive feed” and nighttime notifications for minor users unless they obtain verifiable parental consent.

Continue Reading New York Publishes Final SAFE For Kids Act Rules

On November 21, 2025, California Attorney General Rob Bonta announced a $1.4 million settlement with Jam City, Inc. (“Jam City”), a mobile app gaming company, for alleged violations of the California Consumer Privacy Act (“CCPA”) and Unfair Competition Law (“UCL”). The Jam City settlement marks Attorney General Bonta’s sixth settlement obtained under the CCPA and reflects a continued focus on how businesses present opt-out rights mechanisms to California consumers, including minors.

Continue Reading California AG Announces $1.4 Million Settlement with Mobile App Gaming Developer Over CCPA Violations

On October 30, 2025, California Attorney General Bonta announced a $530,000 settlement related to allegations that Sling TV, an internet-based live TV service, violated the California Consumer Privacy Act (“CCPA”) and the California Unfair Competition Law. This is the first enforcement action arising from the California Department of Justice’s (“DOJ”) investigative sweep of streaming services and connected TVs, which was announced in January 2024.

Continue Reading California Attorney General Announces $530,000 CCPA Settlement with Sling TV

Last week, the Global Privacy Enforcement Network (“GPEN”)—a global network of over 30 national data protection authorities—announced the launch of its annual privacy sweep. The purpose of the sweep is to examine how websites and mobile applications commonly used by children handle minors’ personal information. Members of GPEN include regulators who have long prioritized protections for children and teens, such as the Federal Trade Commission (“FTC”), the California Attorney General, the California Privacy Protection Agency, the UK Information Commissioner’s Office, the French Commission Nationale de l’Informatique et des Libertés (“CNIL”), and the Irish Data Protection Commission.

Continue Reading Global Privacy Regulators Launch Enforcement Sweep Focused on Children’s Data Protection

Recently, California Governor Gavin Newsom signed into law several privacy and related proposals, including new laws governing browser opt-out preference signals, social media account deletion, data brokers, reproductive and health services, age signals for app stores, social media “black box warning” labels for minors, and companion chatbots. This blog summarizes the statutes’ key takeaways.

Continue Reading California Enacts New Privacy Laws

On September 20, 2024, California Governor Newsom signed into law SB 976, the Protecting Our Kids from Social Media Addiction Act (the “Act”). The Act defines and prohibits an “addictive internet-based service or platform” from providing an “addictive feed” to a minor unless the platform has previously obtained verifiable parental consent. The Act will take effect on January 1, 2025, and the California Attorney General will promulgate regulations on age assurance and parental consent by January 1, 2027. This post summarizes the law’s key provisions. The law includes several technical definitions and exceptions, which are explained at the end of this post.

Continue Reading California Passes Law to Protect Minors from “Addictive Feeds”

This year has brought significant movement and trends in minors’ privacy legislation on both the state and federal levels. We recap the notable developments below.

Comprehensive Consumer Privacy Legislation

Individual states have continued to enact their own comprehensive consumer privacy legislation this year. All of the state comprehensive consumer privacy laws passed this year incorporate the Children’s Online Privacy Protection Act (“COPPA”) through parental consent and sensitive data processing requirements. Notably, New Hampshire, New Jersey, and Maryland impose additional restrictions on the processing of minors’ personal data for targeted advertising, sales, and profiling. New Hampshire’s legislation prohibits processing of personal data for sales or targeted data “where the controller has actual knowledge or willfully disregards that the consumer is at least 13 and under 16.” Similarly, New Jersey’s comprehensive privacy legislation prohibits processing of personal data for sales, targeted ads, or profiling “where the controller has actual knowledge or willfully disregards that the consumer is at least 13 and under 17.” Maryland contains an outright prohibition on the sale or processing of personal data for targeted advertising “if the controller knew or should have known that the consumer is under 18.”

AADC and COPPA-Style Laws

States have continued to introduce Age Appropriate Design Codes (“AADC”), adding to the sweeping trend that emerged last year. Maryland’s new AADC law is similar to California’s AADC law, but departs notably by not requiring covered entities to implement age-gating and modifying the scope of covered entities to services that are “reasonably likely to be accessed by children.” The DPIA requirement in Maryland’s law focuses on “data management or processing practices” of the online product and specifies the harm that should be evaluated.

Continue Reading State and Federal Developments in Minors’ Privacy in 2024