But the settlement is peppered with exceptions to these requirements when Retina-X’s apps are used for so-called “legitimate purposes,” which the FTC seems to think include spying on children or employees. The settlement spells out how Retina-X will have to take “reasonable steps” to ensure that its users “will only use the app to monitor a child or an employee, or another adult who has provided written consent.” This creates huge blind spots in the settlement:

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