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Christopher J. Buontempo

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[email protected]

+1.617.239.8322

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Chris is a corporate attorney who advises companies, investors, and private equity sponsors at the intersection of technology, data, and regulation, with a particular focus on privacy, cybersecurity, and artificial intelligence.

With more than 15 years of experience, Chris is known for helping clients translate complex and rapidly evolving regulatory requirements into practical, business-oriented solutions. He counsels organizations ranging from startups and high-growth companies to global enterprises across the technology, health care, consumer products, financial services, and e-commerce sectors.

A core focus of Chris’s practice is guiding clients through the global privacy and AI regulatory landscape, including compliance with the EU GDPR, the expanding patchwork of US state privacy laws (such as the CCPA), and emerging AI governance regimes. He advises on the design and implementation of scalable compliance programs and has deep experience with sector- and data-specific frameworks, including consumer health data (such as the Washington My Health, My Data Act and similar state laws), biometric data (such as BIPA), children’s and education data (COPPA, FERPA), location-based services, AdTech and tracking technologies, and gaming regulations, including sweepstakes and contests.

Chris is a trusted advisor on the technology, data, and AI aspects of M&A and private equity transactions, representing buyers, sellers, and sponsors in domestic and cross-border deals, including platform acquisitions and add-on investments for private equity sponsors. Chris has developed repeat relationships with sponsors, serving as a go-to advisor across multiple portfolio investments. He works closely with deal teams to assess data assets and technology infrastructure, conduct diligence on privacy and cybersecurity risk, and negotiate transaction terms addressing data rights, AI-related issues, and regulatory exposure. In addition, he drafts and negotiates complex commercial agreements, including SaaS, software licensing, data licensing and sharing arrangements, outsourcing transactions, and strategic technology partnerships. Chris also advises on data commercialization issues, including data brokers, secondary data uses, and regulatory scrutiny of data aggregation and resale.

Beyond transactions, Chris counsels clients on cybersecurity risk management and operational readiness, including incident response planning, vendor and supply chain risk, and the integration of privacy and security considerations into product development and technology procurement. He also conducts privacy audits and risk assessments and advises on the development of policies, procedures, and governance frameworks.

Chris frequently serves as outside general counsel to emerging and middle-market companies, including private equity portfolio companies, advising founders, executive teams, and boards on commercial strategy, contracting, and growth initiatives in data-driven businesses. He regularly supports PE-backed management teams through growth and operational milestones, including post-acquisition integration and preparation for subsequent transactions.

Prior to joining Mintz, Chris held in-house legal leadership roles at a global technology company and a global consumer products organization, where he oversaw legal, privacy, and enterprise risk management functions, giving him a practical understanding of how regulatory requirements impact business operations.

He is an active thought leader who regularly speaks and writes on developments in privacy, cybersecurity, artificial intelligence, and emerging technology law.

viewpoints

Privacy law 101 includes a simple but important basic concept that organizations may only use personal information they collect for what they say they will, and how they say they will.  According to the Federal Trade Commission ("FTC") and the Department of Justice ("DOJ"), Twitter got this wrong - and it is going to cost Twitter $150M as a result. On May 25, 2022, Twitter reached a proposed settlement with the DOJ and the FTC to resolve allegations that Twitter violated the FTC Act and an Order issued by the FTC in 2011 by misrepresenting how it would make use of users’ personal information, including users’ nonpublic contact information. 

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Connecticut Governor Ned Lamont has signed the country’s fifth comprehensive consumer privacy act. Our breakdown below outlines key concepts on how the Connecticut Data Privacy Act (CDPA) will impact businesses, and several notes about how its provisions compare to other US state privacy laws.

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Utah is on the brink of joining California, Colorado, and Virginia to become the fourth state in the US to enact a major comprehensive privacy law.  On February 25, the Utah Senate passed the Utah Consumer Privacy Act (“UCPA”), and on March 2, it was passed by the Utah House. The Mintz privacy team has reviewed the UCPA for answers to business’ most pressing questions about how this new law will affect them if it is enacted.

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Colorado has now joined California and Virginia to become the third US state to pass a comprehensive data privacy legislation when Governor Jared Polis signed the Colorado Privacy Act (the “CPA”) into law on July 8, 2021. The new law is set to take effect on July 1, 2023. The CPA borrows in part from the European Union’s General Data Protection Regulation (“GDPR”), but more significantly from both the California Consumer Privacy Act (“CCPA”, including as amended by the California Privacy Rights Act (“CPRA”)), and the Virginia Consumer Data Protection Act (“VCDPA”). Below, we highlight some of the CPA’s key elements and explore how the law compares to the CCPA and VCDPA.
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The Mintz Privacy & Cybersecurity Blog will be providing regular updates of notable pending US state privacy laws.  Following our similar previous updates, this update checks in on the progression of those laws.   The most notable update is that Colorado is set to become the third US state to pass a comprehensive privacy law as the Colorado Privacy Act is on the governor’s desk and is expected to be signed. 
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In a previous update, we provided a comprehensive round-up of several notable pending US state privacy laws. We are checking-in on the progression of some of those laws in this further update. The next installment will update the remaining state laws in progress.
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On Tuesday, Virginia Governor Ralph Northam signed the Consumer Data Protection Act (“CDPA”) into law, making Virginia the second U.S. state after California to pass a comprehensive data privacy law. While not quite as expansive as the GDPR in every respect, the CDPA is a very broad-based privacy law that is on par with the California Consumer Privacy Act. Below, we break down some of its key elements.
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Based on what we are already seeing in terms of the impressive volume of state-level proposed privacy legislation in the early days of 2021, it appears that we may see a big year for US privacy law. Below is a sampling of where things stand in Virginia, Washington, New York, Minnesota, Oklahoma, Utah, and North Dakota.
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An oft-used business management concept is to “hire people smarter than you.” The concept also applies to hiring vendors – hire vendors that are better than you (especially when it comes to information security). Texas-based Ascension Data & Analytics LLC (Ascension), a technology and data analytics company used by the mortgage industry, did not utilize that concept in its vendor hiring process, and as a result, recently entered into a proposed settlement agreement with the Federal Trade Commission (FTC) following charges that it violated the Gramm-Leach-Bliley Act’s (GLBA) Safeguards Rule by failing to ensure that its third-party vendor adequately protected mortgage holder personal information.
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The Home Depot, Inc. (“Home Depot”) recently entered into a multi-state Assurance of Voluntary Compliance with Attorneys General of 46 states and the District of Columbia (the “Settlement”) stemming from a massive 2014 data breach that exposed the payment card information of approximately 40 million Home Depot customers.  In addition to the steep penalty, Home Depot is required to undergo an extensive security overhaul.
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News & Press

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Mintz served as legal counsel to Innovius Capital Management in connection with its role as lead investor in the $46 million Series B financing of xCures, an Oakland-based digital health company developing AI-driven solutions for medical record acquisition and analysis.

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Mintz represented SIMPL Automation, a Massachusetts–based warehouse automation company that develops modular, AI‑powered robotics and automated storage and retrieval systems, in its sale to The Home Depot, the world’s largest home improvement retailer. The transaction enables The Home Depot to accelerate supply chain automation while enhancing speed, efficiency, and delivery capabilities for in-demand products across its distribution network.  

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Mintz advised Vercept, a Seattle-based computer-use AI startup, in its sale to Anthropic, the leading AI safety and research company developing frontier-scale models and best known for its Claude family of large language models (LLMs). 

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Mintz advised Wavecrest Growth Partners on its acquisition of Dealerware, a leading software platform for dealer fleet and mobility program management, connecting over 60,000 vehicles at nearly 2,000 dealerships and OEMs across the US and Canada.

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Mintz advised Charlesbank Capital Partners (Charlesbank), a middle-market private equity firm, on its strategic growth investment in HBox, a leading virtual care platform for specialty practices. 

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Mintz is pleased to have represented Royal Philips, a global leader in health technology, in entering into an agreement to acquire SpectraWAVE, Inc., an innovator in Enhanced Vascular Imaging of coronary arteries, angiography-based physiology assessments, and the use of AI in medical imaging. SpectraWAVE’s intravascular imaging and physiological assessment technologies provide advanced solutions for the treatment of patients with coronary artery disease, affecting more than 300 million people worldwide. 

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Mintz announces the elevation of 12 attorneys to its partnership ranks across the US and Canada, effective January 1, 2026. These promotions build on the firm’s growth in 2025, which included 14 lateral partners spanning the firm’s geographies.

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Mintz advised Cultivo, a leading platform for developing and operating natural assets at scale, on its acquisition of leading carbon grasslands project developer Kateri.

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Mintz represented VMG Partners, a growth equity firm with a two-decade track record of scaling iconic consumer brands, in its partnership with Scenthound, the nation's first and leading dog wellness franchise. VMG’s investment will reinforce Scenthound’s leadership in the pet industry and accelerate its mission of revolutionizing pet care through routine hygiene and wellness.

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Mintz advised Charlesbank Capital Partners, a middle-market private investment firm, on its acquisition of Q6 Cyber, an intelligence and fraud prevention services provider. 

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Mintz represented Breed’s Hill Capital, a multi-family office overseeing approximately $3.5 billion in assets, in its acquisition by Corient, one of the nation’s leading wealth management firms. The transaction enhances Corient’s footprint in New England and advances its ability to deliver personalized fiduciary wealth management services across the region.

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Mintz advised PHLUR, a modern fragrance brand recognized for its emotion-led storytelling and accessible positioning, in its acquisition by TSG Consumer, a leading private equity firm specializing in consumer brands. 

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Mintz represented Quorum Cyber Security, a platform company of Charlesbank Capital Partners, in its acquisition of Kivu Consulting, Inc., a global cybersecurity firm specializing in Incident Response.

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Mintz Associate Christopher Buontempo was quoted in an article published by Society for Human Resource Management (SHRM) Online on security plans, policies, and other privacy measures for businesses to protect data as they manage their newly-remote workforces during the coronavirus (COVID-19) pandemic.
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Events & Speaking