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Washington insiders say that the Obama administration will be more aggressive with actions to protect consumers online. Two consumer advocacy groups, the Center for Digital Democracy and the U.S. Public Interest Research Group, have asked the Federal Trade Commission to investigate behavioral targeting practices aimed at mobile phone users. The day the FTC received the request and one week before the Obama administration took office, four marketing and advertising associations announced their intent to create an enhanced set of self-regulatory principles for online behavioral advertising. The American Association of Advertising Agencies, Association of National Advertisers, Direct Marketing Association and Interactive Advertising Bureau are said to be reviewing the areas for self-regulation set forth in the FTC's proposed self-regulatory principles issued in December 2007. As marketers, our boundaries for targeting campaigns continue to widen as technology improves. We collect more information than ever before. This, along with the fear of federal regulation, may create a trend for more marketers to take on a dual role as a privacy professional. The International Association for Privacy Professionals (IAPP, https://www.privacyassociation.org/) provides privacy education and certification for privacy professionals.

Some consumers say they like the way Internet retailers will suggest new purchases to them based on what they've bought previously. Others feel creeped out when a banner ad seems to know a bit too much about their Web surfing habits. It's called behavioral advertising, and it's central to the business success of all manner of Internet commerce, from bookstores to newspapers. The practice needs regulation, says Rep. Rick Boucher , the Virginia Democrat who chairs the House Energy and Commerce Subcommittee on Communications, Technology and the Internet. Boucher says legislation to protect consumer privacy online will spur people to surf more. But Internet advertising companies are not happy about regulation, especially because Boucher's plan would require, in some cases, that consumers agree in advance before their surfing habits could be tracked. Such an approach "would really be a sea change in the U.S. regulatory framework," says Mike Zaneis, vice president for public policy at the Interactive Advertising Bureau. Virtually all consumer protection laws, he says, permit people to opt out of solicitation, for instance, with a "do not call" registry. For the Internet, Congress has done almost nothing. "To suddenly move toward a draconian opt-in standard," he says, "would really be damaging not just to businesses but consumers." Zaneis, whose group includes such news heavyweights as the New York Times Co. and Conde Nast Publications, says now is not the time to upend Internet companies' business models, right when the economy is in the tank and print advertising is drying up. He argues further that new Web browsers make the issue moot by giving consumers the ability to easily block the electronic "cookies" that track their online movements. The issue promises to be a lobbying extravaganza. Last year, when the Federal Trade Commission (FTC) was developing self-regulatory guidelines for Web companies engaging in behavioral advertising, it

I have an open question for the people who complain about the potential of advertising networks to track your behavior on the Internet: What is a better way? Some might say that all behavioral targeting should simply be banned. But if you don't think that showing Chevy ads to people looking for cars is equivalent to poisoning the peanut butter, we need a middle ground that explains to people what's going on and lets them decide what is acceptable. This is much harder than it sounds: Any one Web page you visit can have a dozen advertisements and invisible bits of code that each send information about you to different companies, each with different ways of using that data. The privacy policy of the site you are looking at - not that anyone reads privacy policies - can't even try to explain this to you, because the site owner doesn't even know what all of its advertisers are doing. I'm coming to the conclusion that each advertisement on a page has to speak for itself. That's implicit in the approach Google is taking for its new behavioral targeting system. It puts the phrase "Ads by Google" on all its advertisements. Click that link and you'll get some limited information about Google's targeting system and an ability to adjust some of the interests that Google is tracking. But Google's approach is presented in a way that glosses over what they are doing and discourages people from reading the disclosure and exercising control, says Joseph Turow, a marketing professor at the Annenberg School for Communication of the University of Pennsylvania. Mr. Turow has developed a plan that is simpler and more comprehensive: Put an icon on each ad that signifies that the ad collects or uses information about users. If you click the icon, you will go to what he calls a "privacy dashboard" that will let you understand exactly what information was used to choose that ad for you. And you'll have the opportunity to edit the information or opt out o

"Despite concerns from some privacy groups and U.S. lawmakers about behavioral advertising, most large advertising networks generally comply with a set of privacy and data-handling standards adopted by the Network Advertising Initiative a year ago, the NAI said in a report released Wednesday." ...NAI, whose members include Google, Yahoo and Advertising.com, should be praised for doing a compliance report after skipping it for several years, said Ari Schwartz, vice president and chief operating officer CDT. However, the group should consider using a third party to audit compliance of its privacy guidelines, instead of having NAI staff do the audits, he said. In addition, while NAI members appear to be following most of the guidelines, some of the privacy safeguards are "weak," including the data retention standard, he said. "There's no maximum for data retention -- they just have to state what their data retention policy is," Schwartz added. The NAI report doesn't lessen the need for new privacy laws, Schwartz said. Several online advertising networks are not members of NAI, and the recent public pressure has led to the NAI updating 8-year-old guidelines last year and issuing a compliance report for the first time in several years, although the group had promised regular reports, he said. "It seems that when there's regulatory pressure, they actually do comply with what they said they were going to do," he said. "We certainly wouldn't want to see any regulatory pressure lifted."

Worth a read. The story changes quite a bit from the top to bottom of the story.

The authorities in Brussels fired a warning shot across the bows of online advertisers today, signalling new rules to combat surfer profiling and breaches of privacy in the interests of commercial gain. In the strongest denunciation of the conduct of online advertisers, Meglena Kuneva, the European commissioner for consumer affairs, argued that personal data has become "the oil of the internet and the new currency of the digital world". She warned that surfers' privacy rights were being abused by the amassing of personal information and its supply to advertisers who targeted individuals who were often unaware of what was happening. "From the point of view of commercial communications the world wide web is turning out to be the world wild west. This could be very damaging," Kuneva told a meeting of industry professionals and analysts in Brussels. "Consumer rights must adapt to technology, not be crushed by it. The current situation with regard to privacy, profiling, and targeting is not satisfactory." The commissioner outlined European laws regulating the protection of privacy, commercial contracts, and countering discrimination, and indicated that the regulations were failing to keep up with the pace of developments on the internet. She called on the online advertising industry to come up with a voluntary code of conduct to protect consumer and privacy rights, but clearly signalled that the EU authorities would probably have to legislate to prevent abuses. The volume of personal data collected on the internet was growing exponentially and was increasingly being used for commercial purposes by tracking surfers' browsing habits, using cookies, and making the information available for individual profiling and targeting of consumers, she said.

More than 50 per cent of internet users say they would be more interested in advertisements if they were tailored to their own interests, according to a new report from Q Interactive. Furthermore, another 50 per cent of respondents said they would view an advertiser favourably if they received personalised ads. Despite a number of obstacles that prevent marketers from obtaining too much personal information, 53 per cent of internet users would rather have free online services and insider information in exchange for relevant targeting data. However, 32 per cent of the respondents said they would accept worse service in exchange for privacy, and 15 per cent would prefer to pay for premium service and view no advertising whatsoever. Last year, a survey from Dynamic Markets on behalf of Coremetrics, found that half of UK consumers were happy for marketers to use behavioural targeting to track their online behaviour.

Likely a bit of bias in the survey, but indicitive that targeted ads are not going away. Like most things digital, doing it safely is important for consumers. - Karl More than 50 per cent of internet users say they would be more interested in advertisements if they were tailored to their own interests, according to a new report from Q Interactive. Furthermore, another 50 per cent of respondents said they would view an advertiser favourably if they received personalised ads. Despite a number of obstacles that prevent marketers from obtaining too much personal information, 53 per cent of internet users would rather have free online services and insider information in exchange for relevant targeting data. However, 32 per cent of the respondents said they would accept worse service in exchange for privacy, and 15 per cent would prefer to pay for premium service and view no advertising whatsoever. Last year, a survey from Dynamic Markets on behalf of Coremetrics, found that half of UK consumers were happy for marketers to use behavioural targeting to track their online behaviour.

Behavioral targeting is not bad as a concept but advertisers would have the public opt-in by default without knowing what is being collected and what it is being used for. On the other hand not many in the public seem very concerned about this subject.

The Internet contributes about US$300 billion a year to the U.S. economy, and U.S. lawmakers should be careful about tinkering with the advertising-supported Internet content model in the name of privacy, the Interactive Advertising Bureau (IAB) said. An IAB-commissioned study by two Harvard University professors, released Wednesday, found that 1.2 million U.S. residents are directly employed in Internet-related jobs, and another 1.9 million U.S. jobs support those Internet workers. IAB released the study Wednesday, as 30 publishers of small Web sites converged on Washington, D.C., to urge U.S. lawmakers to avoid passing legislation that would harm their ad-supported business models. Chief among those publishers' concern was talk in the U.S. Congress about requiring Web sites to gain opt-in permission from users before tracking their Web habits as a way to deliver personalized advertising to them. Many users wouldn't give the permission, and without offering targeted advertising, many small Web sites could fold, some small publishers said. Small Web publishers and sellers "are the face of small business" in the U.S. in recent years, said Susan Martin, publisher of Ikeafans.com, a home improvement site.

"Consumers are often oblivious to the fact that some businesses share a great deal of their personal information with other businesses who deliver targeted behavioral advertising, says Anzen analysts Megan Brister and Jordan Prokopy. In an e-mail interview with IT Business Edge editor Lora Bentley, Brister and Prokopy say most consumers are just not aware of the business practices of companies that use personal information for profit. The Federal Trade Commission recently held meetings with consumer and privacy advocates, business and government leaders to discuss privacy, regulatory, and business issues of online behavioral advertising. It plans plan to ramp up efforts to protect consumers and possibly push for tougher legislation to protect consumers. One issue, Brister and Prokopy say, is the lack of transparency by companies that engage in behavioral advertising. These companies have been slow to adopt clear data-management policies and even when they do have policies, they are often written in language that is difficult to understand. Fortunately for consumers, some type of regulation appears to be on the way. The FTC appears eager to penalize businesses who lack transparency regardless of whether the consumer actually experienced any real negative effects as a result, Brister and Prokopy say."

You're watching Jon Stewart's "The Daily Show," when suddenly you see a commercial for the Mustang convertible you've been eyeing - with a special promotion from Ford, which knows you just ended your car lease. A button pops up on the screen. You click it with the remote and are asked whether you want more information about the car. You respond "yes." Days later, an information packet arrives at your home, the address on file with your cable company. This is the future of cable TV advertising: personal and targeted. Cable TV operators are taking a page from online advertising behemoths like Google Inc. to bring these so-called "addressable" ads onto the television. "It hasn't really been done on TV before," said Mike Eason, chief data officer of Canoe Ventures, a group formed by the nation's six largest cable operators to launch targeted and interactive ads on a national platform starting this summer. They're betting they can even one-up online ads because they also offer a full-screen experience - a car commercial plays much better on your TV than on your PC. As such, they hope to charge advertisers more. The stakes are high: Cable companies get only a small portion of the $182 billion North American advertising market. Eason said the cable operators, which sell local ads on networks like Comedy Central, get roughly 10 percent of the commercial time on those channels. With targeting, they are hoping to expand that. But they have to tread carefully. Privacy advocates worry the practice opens the door to unwanted tracking of viewing habits so ads can target consumers' likes or dislikes. They also fear it could lead to discrimination, such as poorer households getting ads for the worst auto-financing deals because they are deemed credit risks. "You've got to tell people you're doing it and you've got to give people a way to say no," said Pam Dixon, executive director of World Privacy Forum in Carlsbad, Calif. "Otherwise, it's just not fair."

The Internet Advertising Bureau U.K. has today launched a good practice principles guide for firms that collect and use data for online advertising. The goal is to promote self-regulation of the practice and quell privacy concerns surrounding it. Companies that support the principles include Google, Microsoft Advertising, Platform-A, Yahoo, Specific Media, Audience Science, NebuAd, and Phorm, all of which have been involved in the formation of the principles as members of the IAB's behavioral advertising task force. To complement the guide, the IAB has also launched a consumer-facing site, youronlinechoices.co.uk, designed to educate consumers on how and why their data is being used, and to provide information on how they can opt out of the process if they wish.

Online ad industry will probably continue to be a hot-button if FTC Commissioner Jon Leibowitz is named chairman. The Federal Trade Commission may strengthen its focus on online advertising and privacy if, as is expected, current FTC Commissioner Jon Leibowitz is named chairman of the agency. "He would certainly keep privacy and online advertising as a focus of the FTC, so I think [his potential appointment] does matter," said Mike Zaneis, VP of public policy at the Internet Advertising Bureau. Reports indicate Leibowitz will be named as head of the commission, replacing William Kovacic. Kovacic replaced former Chairman Deborah Platt Majoras in March 2008, when she left to join the private sector as VP and general counsel of Procter & Gamble. "A kind of privacy switch is going to go on at the FTC [once the new chairman is named] and they're going to engage in this issue in a much more serious way," said Center for Digital Democracy Executive Director Jeff Chester. "Under a Leibowitz regime we would get the kind of serious industry analysis that so far has been lacking from the Bush era approach." "Leibowitz has been a leader on privacy issues," said Zaneis, who expects a Leibowitz-run FTC to continue along the agency's current path of pushing for industry self-regulation, rather than creating new regulations for online advertisers. As a commissioner, Leibowitz, a Democrat, has not ruled out FTC regulation of things like behavioral targeting. During a two-day FTC forum held in Washington, D.C. in 2007, Leibowitz noted, "The marketplace alone may not be able to solve all problems inherent in behavioral marketing." He revealed his sense of humor, adding, "If we see problems...the commission won't hesitate to bring cases, or even break thumbs."

In the 2002 film Minority Report, video billboards scanned the irises of passing consumers and advertised to them by name. That was science fiction back then, but today's marketers are creating digital signs that can display targeted ads based on information they extract from examining the contours of individual human faces. These smart signs are proliferating in commercial establishments and public places from New York's Times Square to St. Louis area shopping malls. They are a powerful innovation in advertising, but one that raises compelling privacy issues - issues that should be addressed now, before digital signs that monitor our behavior become the new normal. The most common name for this medium is digital signage. Most digital signs are flat-screen TVs that run commercials on a continuous loop in airports, gas stations, and anywhere else marketers think they can get your attention. However, marketers have had difficulty determining exactly who sees the display units, which makes it harder to measure viewership and target ads at specific audiences. The industry's solution? Hidden facial recognition cameras. The tiny cameras can estimate the age, ethnicity and gender of people passing by and can track how long a given person watches the display. The digital sign can then play an advertisement specifically targeted to whomever happens to be watching. Tens of millions of people have already been picked up by digital signage cameras. While camera-driven systems are the most common, the industry is also utilizing mobile phones and radio frequency identification (RFID) for similar purposes. Some companies, for example, embed RFID chips in shopper loyalty cards. Digital kiosks located in stores can read the information on the cards at a distance and then display ads or print coupons based on cardholders' shopping histories. Facial recognition, RFID and mobile phone tracking are powerful tools that should be matched by business practices that protect consu

In the 2002 film Minority Report, video billboards scanned the irises of passing consumers and advertised to them by name. That was science fiction back then, but today's marketers are creating digital signs that can display targeted ads based on information they extract from examining the contours of individual human faces. These smart signs are proliferating in commercial establishments and public places from New York's Times Square to St. Louis area shopping malls. They are a powerful innovation in advertising, but one that raises compelling privacy issues - issues that should be addressed now, before digital signs that monitor our behavior become the new normal. The most common name for this medium is digital signage. Most digital signs are flat-screen TVs that run commercials on a continuous loop in airports, gas stations, and anywhere else marketers think they can get your attention. However, marketers have had difficulty determining exactly who sees the display units, which makes it harder to measure viewership and target ads at specific audiences. The industry's solution? Hidden facial recognition cameras. The tiny cameras can estimate the age, ethnicity and gender of people passing by and can track how long a given person watches the display. The digital sign can then play an advertisement specifically targeted to whomever happens to be watching. Tens of millions of people have already been picked up by digital signage cameras. While camera-driven systems are the most common, the industry is also utilizing mobile phones and radio frequency identification (RFID) for similar purposes. Some companies, for example, embed RFID chips in shopper loyalty cards. Digital kiosks located in stores can read the information on the cards at a distance and then display ads or print coupons based on cardholders' shopping histories. Facial recognition, RFID and mobile phone tracking are powerful tools that should be matched by business practices that protect consu

The Federal Trade Commission, continuing its focus on behavioral advertising practices and online consumer privacy, has hired Harvard researcher Christopher Soghoian as a technical consultant. Soghoian, currently with Harvard's Berkman Center for Internet & Society and a noted researcher and blogger on online privacy, will work with the FTC's Bureau of Consumer Protection, Division of Privacy and Identity Protection. He has been particularly critical about the length of time major Internet service providers and companies keep and use customer data Last month, several marketing and advertising industry associations, including the Direct Marketing Association and the American Association of Advertising Agencies, issued self-regulatory principles to govern the online practices of their members, in an attempt to stave off federal regulation of behaviorally targeted advertising.

"It could be quite a manic Monday for digital advertisers. Privacy advocates are calling Dec. 7 "Pearl Harbor Day" for the Internet advertising industry as the Federal Trade Commission launches its public roundtables on consumer privacy issues. Certainly many members of the public as well as legislators are up in arms over practices such as behavioral tracking and targeting, but a great deal of this anxiety comes down to a lack of knowledge regarding practices. The Interactive Advertising Bureau has been applying preventative measures, including releasing "Self-Regulatory Principles for Online Behavioral Advertising". Its latest effort is the consumer education campaign "Privacy Matters," which will be featured on a broad array of media sites. It's a conciliatory recognition that the industry has released paranoia in the general populace by not clearly explaining the nuts and bolts of targeting and other advances."

As arguments swirl over online privacy, a new survey indicates the issue is a dominant concern for Americans. More than 90 percent of respondents called online privacy a "really" or "somewhat" important issue, according to the survey of more than 1,000 Americans conducted by TRUSTe, an organization that monitors the privacy practices of Web sites of companies like I.B.M., Yahoo and WebMD for a fee. When asked if they were comfortable with behavioral targeting - when advertisers use a person's browsing history or search history to decide which ad to show them - only 28 percent said they were. More than half said they were not. And more than 75 percent of respondents agreed with the statement, "The Internet is not well regulated, and naïve users can easily be taken advantage of." The survey arrives at a fractious time. Debate over behavioral advertising has intensified, with industry groups trying to avoid government intervention by creating their own regulatory standards. Still, some Congressional representatives and the Federal Trade Commission are questioning whether there are enough safeguards around the practice. Last month, the F.T.C. revised its suggestions for behavioral advertising rules for the industry, proposing, among other measures, that sites disclose when they are participating in behavioral advertising and obtain consumers' permission to do so. One F.T.C. commissioner, Jon Leibowitz, warned that if the industry did not respond, intervention would be next. "Put simply, this could be the last clear chance to show that self-regulation can - and will - effectively protect consumers' privacy," Mr. Leibowitz said, or else "it will certainly invite legislation by Congress and a more regulatory approach by our commission." Some technology companies are making changes on their own. Yahoo recently shortened the amount of time it keeps data derived from searches. It is also including a link in some ads that explains how

The Federal Trade Commission (FTC) is getting tough on online viral marketing using blogs and other social networking sites. The proposed rules would make bloggers legally liable if they make untrue statements about products or services. Companies would face sanctions, too, if they use blogs and social networking sites to make untrue claims. "This impacts every industry and almost every single brand in our economy, and that trickles down into social media," Anthony DiResta, an attorney representing several advertising associations, told vnunet.com. The rules have been a long time coming. It's the first revision of the FTC's advertising rules since 1980. New kinds of marketing have sprouted in the last 30 years, but this is the first time the FTC is paying attention to these kinds of advertising practices. Not everyone agrees that this is a good idea. Richard O'Brien, vice-president of the American Association of Advertising Agencies, told the website, "Regulating these developing media too soon may have a chilling effect on blogs and other forms of viral marketing, as bloggers and other viral marketers will be discouraged from publishing content for fear of being held liable for any potentially misleading claim."

The Federal Trade Commission had some sharp words for Internet advertising companies Thursday, saying that they simply are not disclosing how they collect information about users well enough. And the agency threatened that the industry had better get its act together - or else. Or else what? Well, that's a bit harder. The commission has limited ability to issue binding regulations on advertising practices, and the process is cumbersome. But if the agency were to say that its attempt over the last few years to have Internet companies voluntarily bolster their privacy standards has failed, it could encourage Congress to pass online privacy legislation. Indeed, two members of the commission - Pamela Jones Harbour, an independent, and Jon Leibowitz, a Democrat - issued statements saying that while they support the commission's action, they hope for further regulation and possibly legislation on the issue. What the commission issued Thursday was the final version of its principles for online behavioral advertising - that is, ads shown to you based on something you did in the past. The agency issued its first draft of these at the end of 2007 and spent more than a year digesting comments. These principles were meant to spur various Internet groups to create self-regulatory standards for their members. And one group, the Network Advertising Initiative, did publish new rules. The top recommendation was that users should be given clear notice about what information was collected and an easy way to tell sites to stop watching them. "What we observe is that, with rare exception, is not the rule for any Web sites," said Eileen Harrington, the acting director of the commission's bureau of consumer protection, in an interview Thursday. "It is far more commonplace to put the information in the midst of lengthy and hard-to-understand privacy policies."

Visit the Amazon.com site to buy a book online and your welcome page will include recommendations for other books you might enjoy, including the latest from your favorite authors, all based on your history of purchases. Most customers appreciate these suggestions, much the way they would recommendations by a local librarian. But, what if you visited an investment site, only to find advertising messages suggesting therapies for your recently diagnosed heart condition? Chances are that you would experience what Fran Maier calls the "creepiness" factor, a sense that someone has been snooping into a part of your life that should remain private. Maier is the Executive Director of TrustE, a nonprofit that sets guidelines for online privacy and awards a seal of approval to companies meeting those guidelines. She was a speaker at the recent Supernova conference, an annual technology event in San Francisco organized by Wharton legal studies and business ethics professor Kevin Werbach in collaboration with Wharton. Creepiness Factor The creepiness factor is a risk inherent in so-called behavioral targeting. This practice is based on marketers anonymously observing a user's behavior on the Internet and compiling a personal profile based on interests and behavior -- sites visited, searches conducted, articles read, even emails written and received. Based on their profiles, users receive advertising targeted specifically to them, regardless of where they travel on the web. Consumer advocates worry that online data collection and tracking is going too far. Marketing executives counter that consumers benefit from seeing advertising relevant to their interests and contend that relinquishing some personal data is a reasonable trade-off for free access to Internet content, much of it supported by advertising.

"Faced with increasing pressure from Washington, the Interactive Advertising Bureau launched a public service campaign on Thursday aimed at educating consumers about behavioral targeting. The online campaign, created pro bono by WPP's Schematic, features rich media banner ads with copy like "Advertising is creepy" and "Hey, this banner can tell where you live. Mind if we come over and sell you stuff?" More than one dozen publishers -- including Microsoft, Google's YouTube, and AOL -- have committed to donate a combined 500 million impressions for the initiative. The campaign comes as policymakers are questioning whether data collection by marketers violates consumers' privacy. Rep. Rick Boucher (D-Va.) has said he plans to introduce a bill that could require Web companies to notify users about online ad targeting, and in some circumstances, obtain their explicit consent. In addition, the Federal Trade Commission has criticized the industry for using dense privacy policies to inform people about behavioral targeting, or tracking people online and sending them ads based on sites visited. In a meeting with reporters Thursday morning, IAB President and CEO Randall Rothenberg said one goal of the campaign is to address regulators' concerns that consumers don't understand behavioral advertising. "

The advertiser's dream of sending a particular commercial to a specific consumer is one step closer to reality as Cablevision Systems plans to announce the largest project yet using targeted advertising on television. Beginning with 500,000 homes in Brooklyn, the Bronx and some New Jersey areas, Cablevision will use its targeting technology to route ads to specific households based on data about income, ethnicity, gender or whether the homeowner has children or pets. The technology requires no hardware or installation in a subscriber's home, so viewers may not realize they are seeing ads different from a neighbor's. But during the same show, a 50-something male may see an ad for, say, high-end speakers from Best Buy, while his neighbors with children may see one for a Best Buy video game. "We have, as an industry, been talking about this since the beginning of time," said Matt Seiler, the global chief executive of the media firm Universal McCann, a part of the Interpublic Group. "Now we've got it in 500,000 households. This is real." The potential of customized ads worries some privacy advocates, despite the assurance of cable companies that they maintain anonymity about the households. "We don't have an objection to advertising that is targeted to demographics," said Marc Rotenberg, the executive director of the Electronic Privacy Information Center, a civil liberties group in Washington. But, he said, there is a need to show "that they can't be reverse-engineered to find the names of individuals that were watching particular shows." Cablevision says it segments its subscribers only by demographics, so that an advertiser can divide ads among various groups: General Motors, for example, could send an ad for a Cadillac Escalade to high-income houses, a Chevrolet to low-income houses, and one in Spanish to Hispanic consumers. Cablevision matches households to demographic data to divide its customers, using the data-collection compa