RE: Issue-39: Tracking of Geographic Data

I think we need to separate the concept into 2 separate issues….a)tracking,
whether over time/cross sites and the uses that can lead to AND b)
appending/personalization, using the IP to understand this user works at
IBM, or is at an IP range belonging to Harvard University, or is in this
location – using various IP linked data bases – unrelated to the web
site/server retaining the IP over time.


From: Justin Brookman [] 
Sent: Tuesday, December 20, 2011 3:06 PM
Subject: Re: Issue-39: Tracking of Geographic Data


If an ad network (or some other third-party) uses precise geolocation to
show me an ad (or some other geo-contextual content), but then immediately
deletes that information (or retains for some excepted purpose like ad
reporting but not profiling), that seems to me to be more akin to contextual
advertising than "tracking."  I think I agree with Shane that the
granularity of the location is not relevant to whether the collection and
use of location data is across sites or time.

On the other hand, the precision of the data will determine whether it can
be kept pursuant to one of the exceptions if any of those exceptions require
anonymization/de-identification (since precise geolocation data collected
over time is inherently identifying).  If at the end of this process the
exceptions don't require anonymization, that would be an argument against
the use of precise geolocation by a third-party in response to a DNT header,
as the exceptions would allow for the retention of highly personal data.

Justin Brookman
Director, Consumer Privacy Project
Center for Democracy & Technology
1634 I Street NW, Suite 1100
Washington, DC 20006
tel 202.407.8812
fax 202.637.0969

On 12/20/2011 2:29 PM, Jeffrey Chester wrote: 

Geo-location is part of the third party tracking process and should be
addressed by DNT header.  That can still mean use of IP address but no other
geo-targeting data analysis. 



Jeffrey Chester

Center for Digital Democracy

1621 Connecticut Ave, NW, Suite 550

Washington, DC 20009



On Dec 20, 2011, at 2:07 PM, David Singer wrote:


On Dec 20, 2011, at 9:56 , Kevin Smith wrote:

I know we have talked about it a few times, but perhaps not in the context
of geo, but I still favor the position that an ad server (or other 3rd party
service) can use information collected in the current session to target you.


For instance, if I am visiting New York, I do not have a problem if I see
Broadway ads while I am there.  I don’t mind contextual ads.  If I am
reading up on my favorite basketball team, I expect to see sports related
ads.  Nor do I mind time-related ads.  I do not mind prioritization of
office supplies over movie trailers at 2:00 in the afternoon because an ad
server does not need to know anything about me to make this decision.


Yes, these all use data *from the current transaction*, not anything from
the past.  I think we've discussed this and think it's OK.  You're being
treated as a fresh, new, visitor, and nothing is being remembered.

What may bother me is if I see Broadway ads once I have returned to Utah
(meaning they are remembering all of my locations – assuming I have not in
some other direct way indicated a preference for the theater), or if I see
sports ads while booking a flight, or if the decision to show me office
supplies vs movie trailers was based on watching my many locations and
thereby determining if I am home or at work.


or if you visited a theater site while in New York and went to a risqué
cabaret, and when you get home and go looking for a show to take the family
to, you get shown a lot of ads for risqué cabarets.


David Singer

Multimedia and Software Standards, Apple Inc.



Received on Tuesday, 20 December 2011 20:23:35 UTC