FTC To Host Workshop on Cross-Device Tracking Nov. 16 #00055

Submission Number:
00055
Commenter:
Jon Fisse
Organization:
Atomite, Inc.
State:
New Jersey
Initiative Name:
FTC To Host Workshop on Cross-Device Tracking Nov. 16
The FTC's three core consumer privacy principles (i.e., privacy by design, transparency for consumers in how data is collected and used, and usable choice) should be inherent in marketing practices regardless of the device upon which a consumer consumes content. In addition, given the speed at which both technological innovation and changes in consumer behavior occur, as long as the FTC's core principles serve as the basis for current and future marketing solutions, the marketing industry should be free to operate without the guiding hand of government regulation (e.g., mandatory 'do not track' or 'opt-in- requirements). An argument can be made that, to date, the marketing industry has fallen short in terms of deploying satisfactory consumer privacy protection solutions (e.g., AdChoices is voluntary and requires the consumer to jump through too many hoops to be effective). The gap between the FTC's consumer privacy principles and deficiencies in current market-based solutions can be filled when marketers, publishers and digital ad networks conclude that its in their enlightened collective self-interest to embrace a solution that offers consumers bona fide transparency, choice and meaningful compensation for the use of their information for marketing purposes and do so in a manner that is intuitive, comprehensive and auditable. Atomite's TransPrivacy... offerings, which were designed specifically to enable wireless carriers to embrace the FTC's consumer privacy principles, are one such solution. Atomite's o?erings reward consumers who opt-in and permission Atomite wireless carrier licensees to use their anonymized personal information (API) for marketing purposes. These customers earn a?nity points (Privacy Points...) redeemable for valuable goods and services (e.g., free GBs of data; early mobile device upgrades; iTunes; Net?ix trial periods; and fully-paid or discounted dining, shopping, entertainment, travel, merchandise and gift card o?ers). Through the use of an intuitive user interface, the customers have full control over what information is shared, with whom, for what purposes and for how long. Atomite conducts digital audits of its licensees' deployment of Atomite's TransPrivacy... o?erings to ensure that its wireless carrier licensees are respecting consumer-re?ected choices regarding the use of their API for marketing purposes, thereby enhancing the licensees' trust and goodwill with both customers and relevant governmental authorities. In sum, the FTC has offered the marketing industry and its stakeholders, including wireless carriers, a blueprint for how to re-purpose consumer API for marketing purposes in a manner that is fair and equitable to those consumers. Atomite's TransPrivacy... o?erings operationalize the FTC blueprint in a commercially viable manner which generates a true 'win-win-win' for wireless carriers and their subscribers and marketing partners. Jon Fisse Founder Atomite, Inc. jfisse@atomite.net