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Micky Gramlin
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Micky Gramlin   My Press Releases

A Copy of the Cross-Device Tracking An FTC Staff Report Part 3

Published on 9/24/2017
For additional information  Click Here

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Cross-Device Tracking

An FTC Staff Report

January 2017

Part 3


Pdf file


(A Note: Items 4 through 10 were not listed on the copy of the report )


FTC Report dated January 2017

When FTC staff issued its behavioral advertising report in 2009, the main technology that online advertising companies used to track consumers online was the cookie.

Typically, cookies tracked consumers’ activities across a single browser. Since 2009, new forms of tracking have emerged, such as tracking through Flash cookies and browser history sniffing.

The Commission’s 2015 Cross-Device Tracking Workshop focused on a recent trend in behavioral advertising—the ability to link consumers’ behavior across devices—and built on the Commission’s prior work in this area.

The Commission hosted the Cross-Device Tracking Workshop to explore the implications of this practice for consumers, and to determine how traditional principles, such as transparency, choice, and security apply.

It also examined what self-regulatory organizations and companies were doing in this area. Based on information gathered through the workshop, this report describes:

(1) the ways cross device tracking technologies work;

(2) the benefits and challenges of the practice;

(3) efforts by self regulatory organizations to address cross-device tracking.


Cross-Device Tracking Technology


Through cross-device tracking, companies can associate multiple devices with the same person. While this information serves many purposes, it is particularly useful and valuable to advertisers.

11 For example, a consumer may purchase a pair of shoes on their smartphone after having been served an ad on their work computer. Cross-device tracking can help an advertiser determine that the consumer who made the purchase is the same consumer who saw the ad. Advertisers can use this type of information to measure the success of an ad campaign and avoid inundating consumers with the same ad.

They can also use the information to target ads to a consumer, such as an ad for a belt to match the shoes. As the number of devices consumers use grows, so does the potential extent of cross-device tracking.

To engage in cross-device tracking, companies use a mixture of both “deterministic” and “probabilistic” techniques.

12 Generally, deterministic techniques track consumers across devices through a consumer- identifying characteristic, such as a login.

13 Consumers often take affirmative steps to identify themselves on each device they use, by logging into an account or using an e-mail address, for example.

14 Through that affirmative step, companies can associate a consumer’s activity on one device with activity they observe on other devices associated with that account.

15 Many sites that offer a login also offer functionalities that can be embedded into other sites to track consumers—such as social sharing widgets, analytics code, social network logins, or advertising.

For example, if a consumer logs into the same platform account on a desktop and smartphone, the consumer’s query for blue jeans through that platform on her desktop browser can then inform the ads in a smartphone app that uses the same platform to serve targeted mobile ads.

Companies can also use a probabilistic approach to infer which consumer is using a device, even when a consumer has not logged into a service.

16 A common method of probabilistic tracking is IP address matching.17 When an ad platform places a cookie on a consumer’s browser, the cookie often includes the IP address of the device running the browser. Because devices on the same local network often have the same public IP address, the ad platform might infer that a computer, smartphone, and tablet that use the same public IP address belong to the same household.

As another example, if a consumer’s smartphone uses the same public IP address as her work computer during business hours, and then uses the same public IP address as her home computer during non-business hours, an ad platform might infer that the work computer, smartphone, and home computer belong to the same consumer.

If the platform has access to geolocation information for the three devices, it may be able to ascribe more certainty to this inference. Additionally, a company might infer that a work smartphone and personal smartphone that visit the same unusual combination of websites belong to the same user.

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18 Once a company has linked a consumer’s devices in this manner, when that consumer books airline reservations to Hawaii on her home computer’s browser, for example, she might see ads for hotels in Hawaii on her smartphone or work computer.

Because consumers do not have to be logged in to any service for companies to track them probabilistically, this method of linking might be less apparent to consumers. Consumers generally have a relationship with deterministic platforms, choose to engage with these platforms, and can access the platforms’ policies on data collection and data sharing to learn more about how their information or online behavior could be used.

By contrast, probabilistic tracking companies, like third-party advertising platforms generally, work with businesses out of consumers’ view and rarely have direct consumer relationships.


On the next post,

The Benefits and Challenges


Thank you for stopping by!

Micky Gramlin



Google Starts Tracking To Assess Online Ads

A Copy of the Cross-Device Tracking An FTC Staff Report Part 1

A Copy of the Cross-Device Tracking An FTC Staff Report Part 2

A Copy of the Cross-Device Tracking An FTC Staff Report Part 4




PDF File FTC Cross Tracking

Source for Pictures






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