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GDPR
What it means for app analytics and mobile engagement
Introductions
Your Hosts
Charlie Case
Localytics
Security Program
Manager
Naike Romain
Localytics
Product Marketing
Manager
This
Webinar
What this Webinar Is
● It is an overview of how you can use our suite of services in a compliant manner.
● It is about how we support your GDPR compliance as a Data Processor
What this Webinar Isn’t
● It is not a comprehensive overview of how you become GDPR Compliant
● It is not about how we are GDPR compliant as a Data Controller
● A replacement for working with your own legal counsel
Goal:
● Provide clarity around how you can use Localytics in a GDPR compliant manner.
Agenda
● Overview of GDPR
● Our Role; Your Role
● How Localytics Supports Compliance
● Questions and Discussion
Poll
How GDPR ready are you?
Just getting started Assessment stage
Audit/inventory stage Gap mitigation stage
Compliant
What is your role in GDPR compliance?
Poll
Data Controller Data Processor
Both a Controller and Processor Not quite sure
GDPR Overview
The General
Data
Protection
Regulation
Linked
VS
Linkable
Traditional definition of PII:
Identifying information such as
names, addresses, or
government issued identification
numbers
New definition of PII (PD):
Includes as any identifiers that,
when combined with other data,
may identify an individual.
Information like Advertiser ID’s,
random/unique Identifiers +
behavioral data
Privacy
Principles
● EU citizens have the right to dictate and control
if and how their personal data is used
● Explicit consent must be granted, not assumed
This applies to you. Yes, you.
Our Role,
Your Role
Same Roles, New Responsibilities
Data Subject Data Controller Data Processor
You are the Data Controller
Localytics is the Data Processor
Data Controller
Responsibilities
● Ensuring transparency
● Obtaining and respecting consent
● Collecting only the data
necessary
● Protecting all data collected
● Acting on Right to be forgotten
instructions
● Instructing the Processor
Data Processor
Responsibilities
● Process as instructed
● Transparency to you and your
end-users
● Protect the data you send
● Provide access to your data
● Provide tools to respect consent
● Provide tools to act on requests
to be forgotten
How they
work
together
We Work Together
As a controller it’s your job to instruct your processors
on how to handle your data. In turn, we support your
requirements by giving you the tools to be compliant
Why Should We Care About GDPR
“With great power comes great responsibility”
- Uncle Ben
How Localytics
Supports
Compliance
What Data
Does
Localytics
Process?
Required
● IP Addresses (not stored)
● Install_ID
Configurable
● Advertiser_ID (GAID/IDFA)
● Events/Attributes; Dimensions
● Customer_ID
● First/Last/Full Name
● Email
● Profile Attributes
How
Localytics
Supports
Compliance
● Updated Privacy Policies
● Updated DPA
● Consent
● Right-to-be-Forgotten Methods
- SDK Method setOptedOut
- SDK Method setPrivacyOptedOut (new)
- Server-Side Profile Attribute (new)
- S3 Raw-Log support changes
- Pushed to your S3, use your KMS
Supporting Consent & Right-to-be-Forgotten
Delete Personal Data and Identifiers - 30 days
- Profiles (First/Last/Full Name, Email)
- Customer_ID
- Advertiser_ID
- Unique Identifiers
Effectively Orphan the behavioral data
How are we going to delete end-users?
Keep your
Event and
Profile Data
Separate
*Personal Data shouldn’t be tagged as
events/attributes or Custom Dimensions
What’s Next?
- New Methods and documentation to be
released end of March
- Account Managers, MEC’s and support are
available to assist you.
Tasks to
Consider
- Audit/Assess data - Classify Personal Data
- Implement latest SDK v5.1
- Implement Consent Solicitation using
setOptedOut
- Implement ‘Forget Me’ Setting using
setPrivacyOptedOut / Privacy Delete Attribute
- Sign DPA with your processors
- Migrate S3 - If applicable
Questions & Discussion

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What GDPR Means for App Analytics and Mobile Engagement

  • 1. GDPR What it means for app analytics and mobile engagement
  • 2. Introductions Your Hosts Charlie Case Localytics Security Program Manager Naike Romain Localytics Product Marketing Manager
  • 3. This Webinar What this Webinar Is ● It is an overview of how you can use our suite of services in a compliant manner. ● It is about how we support your GDPR compliance as a Data Processor What this Webinar Isn’t ● It is not a comprehensive overview of how you become GDPR Compliant ● It is not about how we are GDPR compliant as a Data Controller ● A replacement for working with your own legal counsel Goal: ● Provide clarity around how you can use Localytics in a GDPR compliant manner.
  • 4. Agenda ● Overview of GDPR ● Our Role; Your Role ● How Localytics Supports Compliance ● Questions and Discussion
  • 5. Poll How GDPR ready are you? Just getting started Assessment stage Audit/inventory stage Gap mitigation stage Compliant
  • 6. What is your role in GDPR compliance? Poll Data Controller Data Processor Both a Controller and Processor Not quite sure
  • 9. Linked VS Linkable Traditional definition of PII: Identifying information such as names, addresses, or government issued identification numbers New definition of PII (PD): Includes as any identifiers that, when combined with other data, may identify an individual. Information like Advertiser ID’s, random/unique Identifiers + behavioral data
  • 10. Privacy Principles ● EU citizens have the right to dictate and control if and how their personal data is used ● Explicit consent must be granted, not assumed
  • 11. This applies to you. Yes, you.
  • 13. Same Roles, New Responsibilities Data Subject Data Controller Data Processor
  • 14. You are the Data Controller Localytics is the Data Processor
  • 15. Data Controller Responsibilities ● Ensuring transparency ● Obtaining and respecting consent ● Collecting only the data necessary ● Protecting all data collected ● Acting on Right to be forgotten instructions ● Instructing the Processor Data Processor Responsibilities ● Process as instructed ● Transparency to you and your end-users ● Protect the data you send ● Provide access to your data ● Provide tools to respect consent ● Provide tools to act on requests to be forgotten How they work together
  • 16. We Work Together As a controller it’s your job to instruct your processors on how to handle your data. In turn, we support your requirements by giving you the tools to be compliant
  • 17. Why Should We Care About GDPR “With great power comes great responsibility” - Uncle Ben
  • 19. What Data Does Localytics Process? Required ● IP Addresses (not stored) ● Install_ID Configurable ● Advertiser_ID (GAID/IDFA) ● Events/Attributes; Dimensions ● Customer_ID ● First/Last/Full Name ● Email ● Profile Attributes
  • 20. How Localytics Supports Compliance ● Updated Privacy Policies ● Updated DPA ● Consent ● Right-to-be-Forgotten Methods
  • 21. - SDK Method setOptedOut - SDK Method setPrivacyOptedOut (new) - Server-Side Profile Attribute (new) - S3 Raw-Log support changes - Pushed to your S3, use your KMS Supporting Consent & Right-to-be-Forgotten
  • 22. Delete Personal Data and Identifiers - 30 days - Profiles (First/Last/Full Name, Email) - Customer_ID - Advertiser_ID - Unique Identifiers Effectively Orphan the behavioral data How are we going to delete end-users?
  • 23. Keep your Event and Profile Data Separate *Personal Data shouldn’t be tagged as events/attributes or Custom Dimensions
  • 24. What’s Next? - New Methods and documentation to be released end of March - Account Managers, MEC’s and support are available to assist you.
  • 25. Tasks to Consider - Audit/Assess data - Classify Personal Data - Implement latest SDK v5.1 - Implement Consent Solicitation using setOptedOut - Implement ‘Forget Me’ Setting using setPrivacyOptedOut / Privacy Delete Attribute - Sign DPA with your processors - Migrate S3 - If applicable