"Meta does not appear to clearly and conspicuously describe the data it collects about individuals. It does not have simple, descriptive URLs for these pages—in fact, any single privacy-related document on a Meta website could link to dozens or over 100 other pages and pop-ups that Meta purports provide additional information. Both of these points raise the question of whether Meta is deviating from practices the FTC has indicated are legally required.
Further, the FTC Act prevents deceptive practices in general—defined by FTC policy as “involving a material representation, omission, or practice that is likely to mislead a consumer acting reasonably in the circumstances.” If any number of pages on the Meta website that claim to provide consumers with information about privacy do not, in fact, provide and present said information in a reasonable manner (or, really, at all), it likewise raises the question of whether Meta might be violating the FTC Act by deceptively designing the layout of its privacy policy information.
Lawmakers working on privacy bills should not forget that substance and layout are important for privacy policies, to avoid these kinds of bad practices that bury information from consumers and regulators, further limit consumers’ ability to consent, and threaten individuals’ ability to exercise their privacy rights."
https://www.techpolicy.press/metas-privacy-policies-designed-badly-by-design/
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