FTC Seeks Input on Privacy and Security Implications of the Internet of Things; FTC Project No. P135405; Commission Staff to Conduct Workshop on November 21, 2013 in Washington, DC #00019 

Submission Number:
00019 
Commenter:
Elliot  Klein
Organization:
XYverify Corp.
Initiative Name:
FTC Seeks Input on Privacy and Security Implications of the Internet of Things; FTC Project No. P135405; Commission Staff to Conduct Workshop on November 21, 2013 in Washington, DC
To: FTC Staff in advance of Nov. 21 Workshop: XYverify Corp. is a New York-based company that provides smart technology to the “Internet of Things” ecosystem. Specifically, we deliver a Proximity to Transact verification service using wireless cell phone carrier and other Internet-connected networks to confirm, "Where you are." Transactional services such as financial services or online e-commerce transactions can match with known "who you are" credentials, independently referenced by the XYverify API and cloud-based platform that can be integrated into Internet of Things authorization or verification process. Our market solution is unique in that we securely report a customer device “Proximity Estimate” simply by reporting that a pre-registered customer that provided his/her advance consent to geo-locate is—or is not—within an approved geo-fence or "smart" physical location zone. The reporting we provide to a pre-authorized third party can simply be thought of as a traffic light response message….Green for geo-fence match, Red for out of geo-fence, or Yellow if it’s very close to the pre-set database based on distance range borders. The approach and solution does not “track” or report the exact location of Internet of Things connected objects. Instead, we deliver this next phase in privacy-aware location-based data masking to customize location validation with customer-set rules and privacy permissions based on advance opt-in use case permission for any transaction or Internet location-based gating or other access process. Accordingly, we believe the Internet of Things privacy approach developed by XYverify represents a new location matching platform and service standard that provides a best practice for location validation reporting. Tokenization can further remove any financial data or personal identifiable information so the XYverify API process will not impact required PCI compliance, risk or exposure of storing credit card numbers or customer names on third party systems. To implement, XYverify obtains in advance customer consent to geo-locate their wireless device for a pre-defined specific fraud mitigation process together with their wireless phone number. We simply report to thumbs up or thumbs down authentication when a transaction request triggers the API to request Proximity to Transact location match of that device in real-time, eliminating transmission or storage of secure customer financial or other private information. Securely matching a customer's wireless carrier phone number or related Internet of Things connected device identifiers with the proximity of a mobile or connected-device in customer’s direct possession, and matching that in real-time to an authorized physical postal mail location address range geo-coordinates—compared by XYverify to be in or outside a permitted geo-fence—is a powerful new and innovative fraud reduction and Internet of Things authentication tool. Location intelligence for Internet of Things connected devices can help confirm device’s distance from any business, merchant, home or other postal address locations to better verify or deny transaction requests—never tracking customer location or capturing personal identifiable data that helps confirm real-time customer's device location match to postal mail address distance rules. The privacy-protected approach is unique and dramatically innovates privacy protection in financial services and future potential Internet of Things transaction reporting and identification requests where 4th factor location-based authentication can be added as part of a multi-factor security process. In summary, we are sharing our privacy-protected approach to customer location-based service reporting for Internet of Things as a potential best practice innovation XYverify is implementing, refining and testing, welcoming your questions, workshop participation or comments. Sincerely, Elliot Klein Founder XYverify Corp. www.xyverify.com elliot at XYverify (dot) com