Chief Privacy Officer: Todd Ruback Director of Product Management, Privacy: John Shepard

1. DEVELOPING MOBILE
TRUST IN TODAY'S
E-PRIVACY LANDSCAPE
November 19th 2015
PRESENTERS:
Todd Ruback Esq., CIPP-US/E, CIPT
Chief Privacy Officer &
V.P. Legal Affairs
Jon Sheppard
Director of Product Management, Privacy

2. 2
Introductions
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
Jon Sheppard
Director of Product
Management, Privacy
Todd Ruback
Chief Privacy Officer &
VP of Legal Affairs
Todd@Ghostery.com JSheppard@Ghostery.com

3. AT&T
June 2015
Update on Privacy
Legal and Regulatory
Landscape
Todd Ruback Esq., CIPP-US/E, CIPT
Chief Privacy Officer &
V.P. Legal Affairs

4. 4
US Self-Regulatory Program for Online Behavioral Advertising (OBA)
• Mobile enforcement began September 1, 2015 – Accountability agents
are actively monitoring and expect robust enforcement
• Extends DAA’s Principles to mobile websites and apps
• Let’s Break It Down:
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
Ads
If based upon OBA data,
then deploy AdChoices
Icon, when opened goes to
DAA’s AppChoices, the
industry opt-out solution,
listing third parties in ad
with consumer choice
apps
Shared obligation with
third parties to
provide notice of OBA
activity and give
control to consumer

5. 5
Canada & EU Self-Regulatory Programs
Canada
DAAC; enforcement spike by ASC in recent months
• Added complexity of national privacy law, PIPEDA, that also
applies to OBA
• OPC Report – encouraged that Canada websites deploy
AdChoices notice, but expect more.
• ASC fully supports PIPEDA; no daylight between the two.
EU
EDAA; Will soon announce mobile enforcement date
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved

6. 6
What do the Self-Regulatory Programs Apply to?
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• 3 different types of data that might be
collected:
• Cross App Data (CAD) – OK,
unless user opts-out
• Precision Location Data (PLD) –
need affirmative consent
• Personal Directory Data (PDD)-
need affirmative consent
• Control:
• Settings upon download
• Ghostery’s App Notice
• DAA’s AppChoices

7. 7
US State Specific Transparency Laws
States currently affected:
• California (CalOPPA)
• Delaware (DelOPPA)
• New York proposed legislation
Legislation Overview
Requires websites, and apps, to have
comprehensive understanding of invisible
digital activity and disclose it.
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved

8. 8
EU – Safe Harbor / Cross Border Data Transfers
• ECJ invalidated US Safe Harbor Program
• Sky is not falling, although over 4,000 US companies rely on this legal
mechanism to transfer EU personal data to the US
• Chances of Safe Harbor 2.0 – 50/50
• Not clear what it may look like but third party Seal Program is at risk, and
we can expect robust monitoring and enforcement.
• WP29 has given companies until Jan 31, 2016 to put Plan B in place
• Many recommend Standard Contractual Clauses as short term solution
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved

9. 9
EU – General Data Protection Regulation
Last mile of negotiations
• Will have new rights for individuals and obligations by companies
• Will require companies to have demonstrable knowledge of digital activity
–annual audits of sites and apps
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved

10. 10
EU ePrivacy Directive – No Longer Just the Cookie Law
• Applies to websites (and apps and connected devices)
• Often confused with Self-Regulatory Programs for OBA
• Will be reviewed in 2016 after GDPR is completed
• Requirements – Notice & Consent
• Enforcement – regulators have been signaled it applies equally to apps
and IoT but have waited for market solution
• Priority – for children’s apps; sweeps have already happened
• Solution – Ghostery’s App Notice
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved

11. AT&T
June 2015
Getting in Compliance
& The Ghostery App
Notice Solution
Jon Sheppard, Director of
Product Management, Privacy

12. 12
Why is there a need for a different solution for Mobile Apps?
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• Unlike the web:
• Mobile apps are installed and run
locally on the users device.
• Changes to apps can only be made
by updating the apps code and
releasing a new version to the app
Store.
• Apps aren’t cookie based.
• Like the web:
• Mobile apps contain trackers
reporting, OBA, CAD, PLD and PDD
• The list of available app trackers is
growing quickly.

13. 13
Steps to Get into Compliance
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1. Identify your companies mobile apps 2. Work with your mobile developer to
identify the ad tech used by your apps,
and data it collects
3. Implement Ghostery App Notice
UPDATE
• We can help you here if you’re lost!

14. AT&T
June 2015App Notice Demo

15. 15
The Ghostery App Notice Solution Overview
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
• Worked closely with privacy leaders to design and
build.
• Provided by a Software Development Kit (SDK)
• Available in 2 versions depending on your app type:
• Android 4.1 and up
• iOS 7 and up
• Both Explicit and Implied notice formats supported
• Over 50 notice customizable options available to
match your apps requirements, including notice
color and text and size etc.

16. 16
What is an SDK?
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
• A mobile Software Development Kit
(SDK) is a packet of code that allows
developers to easily add new
functionality to their apps.
• SDK’s are often used as shortcuts so
that developers don’t have to write
everything from scratch
• SDK’s frequently include sample code
and supporting technical notes or
documentation
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lacinia ultrices porttitor.
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blandit accumsan.
Pellentesque

17. 17
Installing your SDK
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1. app Developers passed the SDK code via
Github
GITHUB
2. SDK is installed in app by Developer:
• Installation & Companion Guides are provided as well as
sample code.
YOUR APP
3. Customize the color and text of your Notice in
your Site Notice Account.
4. Submit your updated app to the store for your
users to download.
UPDATE

18. 18
Ghostery is the Privacy Compliance Leader
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
• Ghostery globally is the Ad Choices Program leader
• Dominant market share: Preferred Partner of every
major Ad Agency Holding
• Integrated with all key buy and sell-side platforms
• Close relationships with the entire privacy ecosystem
• Technology vendor to DAA
SOME OF OUR INTERGRATION PARTNERS
• Over 290+ clients across
desktop, mobile and video
• Over 3 billion AdChoices
icons served daily
• Over 100 million site
consent notices served daily
• 40 languages supported
GHOSTERY BY THE NUMBERS

19. 19
Schedule Your App Notice Demo
Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
EU SALES
+44 020 7031 8232
NORTH AMERICA SALES
917-791-5550
Sales@Ghostery.com EUSales@Ghostery.com

20. AT&T
June 2015 THANK YOU!