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- [00:00]
Tom Kemp
Foreign.
- [00:13]
Katie McAdams
Welcome to Ad Exchanger Talks, the podcast devoted to examining the issues and trends
- [00:18]
Allison Schiff
in advertising and marketing technology that matter most to you.
- [00:23]
Sarah Sleuth
This episode is sponsored by Basis, the leading intelligent operating system for autonomous advertising. Its enterprise AI solution transforms campaign briefs into strategies and media plans that integrate directly into omnichannel activation.
- [00:50]
Allison Schiff
I'm Allison Schiff. You're listening to Ad Exchanger Talks. And it's time to talk privacy, a topic close to my heart. And who better to do that with than my guest this week? No other than Tom Kemp, Executive Director of Cal Privacy. As in the California Privacy Protection Agency, AdTech has weeds, but so does privacy policy. And we're going to get into them. But first, please save the date for programmatic IO New York. Taking place on September 28th and 29th at the New York Marriott Marquee. We'll bring together all the people you want and need to hear from to explore trends in AI driven media decisioning, ctv, retail media and commerce science signals. If you care about the open web, you'll be there. Podcast listeners get 10% off the price of their ticket when they use the code POD10. So what you waiting for? Tom? Welcome to the podcast.
- [01:42]
Tom Kemp
Great to be here.
- [01:44]
Allison Schiff
All right, so I'm going to do a little bit of a rewind on your resume. So your career path is interesting to me because it doesn't feel like a straight line. You studied computer science and, and history. You started your career at Oracle and co founded a cybersecurity company that served the majority of the Fortune 50. And then you pivoted into privacy advocacy, wrote a book called Containing Big Tech. You co drafted the Delete act in California, and now you're running the only dedicated privacy enforcement agency in the U.S. so when were you red pilled? How did you go from Silicon Valley executive to executive Director of Cal Privacy?
- [02:28]
Tom Kemp
Well, I've never been described as being red pill before, but yeah, you know, when I, when I was CEO of a cybersecurity company, we were oftentimes brought in with some of the larger breaches that were occurring. And it gave me a great appreciation for the massive amount of information that they were that these businesses were storing on each and every one of us. And obviously there is a significant need to ensure that there isn't any unauthorized access occurring. But it really got me thinking about like, well, that's my information that they have. What rights do I have? And I clearly saw that GDPR had passed in Europe, that CCPA was coming online in 2018, and as CEO, we actually had to go through the GDPR compliance process ourselves. And so when in 2020 this ballot initiative happened in California, I was like, geez, I really have to jump on board. And that eventually led to me just doing more and more policy related work, trying to leverage my background in technology in Silicon Valley, and eventually led me to being executive director of Cal Privacy.
- [03:48]
Allison Schiff
Well, I applaud you for not just going and playing a bunch of golf, because that's what most people do after they sell a company. Do you think fact that you used to be a tech executive gives you more compassion and patience for tech companies that might be struggling to comply with privacy regulations or just get a handle on all of this?
- [04:06]
Tom Kemp
Well, it certainly gives me the perspective that it's super important that if you want to deliver privacy to consumers, that you need to make sure that businesses can operationalize and actually implement the obligations put forth under the law. So the fundamental issue that I think every regulator has when it comes to tech is can you balance delivering guardrails and protecting consumers with not stifling innovation? And I think here in California, we've done a pretty good job at this in that we're trying to make sure that consumers here in California can operationalize their privacy rights, while at the same time looking to ensure that businesses can operationalize the obligations. And the good news is, is that here in California, since the CCPA passed, is that California has moved from the fifth largest economy in the world to the fourth largest economy in the world. So I think we've kind of figured it out, but it's an ongoing process to ensure that we have that proper balance between the two.
- [05:21]
Allison Schiff
It would be problematic to come up with air quotes, perfect rules, and then nobody could comply with them.
- [05:27]
Tom Kemp
Absolutely. Yeah. No, we, I mean, I think maybe the one thing is, is that while I haven't walked maybe multiple miles in your listener's shoes, I've certainly walked a few laps having come from the private sector and definitely have an appreciation for making sure that you meet the obligations, but it isn't a undue burden on the actual business itself.
- [06:01]
Allison Schiff
So I want to talk a lot about what's happening at the state level, but before we do, let's talk about the federal picture. So in April, there was a bill introduced in Congress that would be the makings of a federal privacy law. And people have been trying to do that for years and years and years. But if the Secure Data act passes, it would preempt state privacy laws, including California's and all of the other states that have come online since then. And I do know that Cal Privacy sent a letter opposing it. So what's your read on where the federal fight is actually headed? And if a national privacy law finally does pass, that'd be the day. What does a good one actually look like?
- [06:45]
Tom Kemp
Well, certainly Cal Privacy does support a federal privacy law, but the one that we think would be best for not only businesses but for consumers is one that sets a high floor, that does allow states to innovate when it comes to providing additional protections for, for its citizens. Unfortunately, what we've seen especially this go around is that this sets a low national ceiling on privacy rights. And so our concerns are the following. First is that this current proposal strips away rights that people already enjoy today. For example, the opt out preference signal, over 100 million Americans can take advantage of that. And that's becomes a study, a three year study. And I don't know why there needs to be a three year study in that it works and it works well
- [07:49]
Sarah Sleuth
today
- [07:51]
Tom Kemp
in the actual market itself that from a data broker perspective, California and other states have progressed well beyond a registry. There's serious concerns whether or not that would actually get preempted. That's an open question. You know that this legislation doesn't support robust data minimization purpose limitation. It seems to allow dark patterns. There's a weakening of enforcement. I can just kind of go on and on and on. The fundamental issue is that not only does this reduce and eliminate privacy rights that people exist, but, but it doesn't allow states to innovate. And states are the laboratories of democracy and they're closer to what's going on. And then frankly, to be very candid, this whole strawman of a patchwork of privacy laws, look how bad it is. The reality is that the standard, the precedent for national legislation that touches upon or addresses privacy, such as Gram Leach, such as hipaa, do allow states to go over and beyond. And the reality is if you were to actually set a high floor that it's very rare that states go over and beyond. There's only a few states that actually go over beyond when it comes to HIPAA and Grand Leach and those been around for a long period of time. And as I mentioned before that California has found a way to balance innovation as well as privacy rights. Given that we've moved from the fifth largest economy in the world to the fourth largest economy in the world, we have 30 of the top 50 AI companies, et cetera. So to me this is actually not good for consumers. And I think also in the long run it's not good for businesses either as well. So we have voiced our opposition to this and we've been joined recently in a letter from representatives, mainly Attorney Generals from 8, 18 other states as well,
- [09:58]
Allison Schiff
advertising trade organizations and I guess trade organizations in general love the word patchwork. Whenever they go to the Hill or they talk to state reps or state senators, that is the buzzword that always comes up. How could you possibly think that we'd ever be able to comply with this patchwork?
- [10:17]
Tom Kemp
The reality is that when federal legislation has passed that allows states to innovate and that they've set a decent enough floor that's been very rare or very infrequent for states to go over and beyond that. So the actual facts as it relates to other comparable laws that hasn't occurred. The other aspect is, is that if you actually even look at today's existing state laws, they share common bones, that they give people comparable rights, etc. And the reality is that when you focus a lot on patchwork, it really shows that you only care about businesses and you're not thinking about the needs and requirements specific to consumers themselves. And this is clearly reflected in this proposed legislation that the fundamental problem that we have in the United States with our privacy model, this notice and choice, is that exercising privacy rights for consumers is a never ending set of chores. I'm quoting Professor Salaf when he says that. And what we're trying to do here in California is to enable privacy at scale by allowing for first party interactions, an opt out preference signal to enable do not sell and shares at scale. We're doing this for data brokers and third party data through our drop system, etc. And not surprisingly, this proposal at the federal level wipes those away and then that gets, that frustrates customers and makes it near impossible for them to actually meaningful exercise privacy. So we just have a fundamental difference that we're trying to adjust to this notice and choice regimen and, and enable privacy at scale for everyday Americans. This has a different approach as well. So it's not surprising that certain entities would prefer not allowing everyday people to be able to flip a switch and say I don't want my data sold or for data brokers to say I want my data deleted from hundreds of data brokers and not have to spend 20, 30 minutes times 500, 600 data brokers to go through that process.
- [12:48]
Allison Schiff
So let's talk more about drop, which is the delete, request and opt out platform. And let me be perhaps not the first person to applaud you on the wordplay in that acronym. It's very clever, but it's a one stop shop like you said, that lets Californians tell every registered data broker. And registered is an operative word.
- [13:07]
Sarah Sleuth
But.
- [13:07]
Allison Schiff
But to delete their information at once rather than having to just track down hundreds of companies individually, which is not only a nightmare, it's also just kind of impossible. And since it launched in January, you've had and maybe the number is even higher now. The last thing I heard was 300,000 Californians or more than 300,000 Californians have signed up. And it's really remarkable for something that isn't like a viral consumer app. So the fact that there's been so much demand and interest, what is that tell you? And it's my podcast, so I'm allowed to ask leading questions.
- [13:41]
Tom Kemp
No problem. Well, California, the fact that Prop 24 passed with 9.3 million votes, which is a top 10 vote getter of any election in any state in the history of the United States, shows that people want privacy. That happened in 2020. The fact that over 300,000 Californians have signed up for drop and we're still a few months away from deletions and the current trajectory is hopefully by next year there'll be over a million people signing up. And the fact that other states are very eager and we just saw in Connecticut passing something comparable with SB4. And so big tip of the hat to State Senator Moroney and Senate Leader Duff on having that happen and of course to the governor for signing that it shows that people want additional tools and mechanisms to enable their privacy rights because we're facing a world of scale based on AI and you know, large trillion dollar plus technology companies finding all these different ways to collect our information. And, and so there is an imbalance here of power. And so people want to be able to have tools to empower them to control how their personal information is being used in a way that they want to do that. So I think drop as to your point is definitely a data point, that there is a hunger out there for people to take control of their personal information.
- [15:29]
Allison Schiff
And it's also a proof point. Yes. That people care about their privacy and it's not as if they don't care because they don't take action. You'll hear people say that people's actions are belied by what they say. You ask someone if they care about privacy and they'll say yes and then they just opt into everything under the sun or it's completely inconsistent what they do. They'll opt in sometimes, they won't opt in other times. And I think the reason why there's so much inconsistency is because there's not across the board or there hasn't been until recently some operationalized privacy platform. If you make it easier for people and the process makes sense, then they don't have to feel as if they're out of control. They can actually take an action and then ideally see that action translated into reality.
- [16:20]
Tom Kemp
Absolutely. I mean, just think about the number of websites that each and every one of us visit on a daily basis, the number of mobile apps. I mean, you're just, you're, you're researching something or you're looking up something and you visit this website, that website, et cetera. Who has time to scroll to the bottom and do cookie configuration? Right. No one has time or even to even read a privacy policy. It's just, it's too stacked against consumers and they need to participate in a modern economy and which requires access to these online services. And so yes, we need to provide some, not only raise privacy literacy, but we do need to provide tools and technologies. And I think here in California we're leading the way to the point that last year we got, we sponsored AB566 that will require browser vendors to actually add the opt out preference signal into the actual browser itself. And that should enable additional adoption of the global privacy control opt out preference signal. And then of course, we're rolling out the drop system as well.
- [17:37]
Allison Schiff
It's amazing to me, like do not track rides again. But it might work this time. It's been so many years. Well, one more question I want to get into before we take a quick break because I think this might catch a lot of ad exchangers, readers off guard. A significant chunk of the ad tech ecosystem like data onboarders, identity resolution vendors, audience extension platforms, companies like that, I don't believe that they think of themselves as being in the data broker business, but they probably do qualify. Are they wrong? And how do you regulate a digital advertising supply chain where data is going to Change hands like 5, 6, 7, who knows how many times during the course of a single programmatic transaction? That kind of makes me feel like everybody falls under the umbrella.
- [18:28]
Tom Kemp
Well, what we, what we need to do is we just need to look at the law and the regulations and the law itself defines what a data broker is. In the regulations, we provide further clarification of the concept of what a direct relationship is. So everything of course is fact specific. So I would encourage your listeners to read the Delete act to read the drop regulations and carefully look and analyze if they actually do fall under the law and the regs and should be registered as a data broker. The fines are pretty dramatic. I mean, obviously today it's just registration, but failure to register does not get you off the hook for the fact that come this fall, it will be $200 per incident, per day. And so if you decide to blow this off and say, I'm not even going to look, and we find that, in fact, you were a data broker and you have the data of, say, 200,000 Californians that have used drop, the fines would be $40 million a day. And we've been very aggressive about setting up a specific strike force. We've dramatically increased the number of data broker registrations, and we do plan to enforce the delete. You know, look at people, you know, ensuring that they're doing the proper deletions. And we plan to enforce that aspect of the law as well. So definitely, I encourage businesses to read the statute, read the enforcement advisories we put out last year about data broker registration, and take this very seriously.
- [20:15]
Allison Schiff
I mean, it's beach season, so print out the statute, grab the rules and regs, a beach chair, and pour yourself a Mai Tai and get started. So we're going to take a quick break, but when we're back, we're going to talk about automated decision making. We're going to talk about the fact that you guys recently hired your first chief privacy auditor, which I think is super interesting, and lots of other good stuff, so stick with us. Foreign
- [20:49]
Sarah Sleuth
I'm Sarah Sleuth, editorial director at Ad Exchanger, and I'm with Katie McAdams, the chief marketing and commercial officer at Basis. Welcome, Katie.
- [20:58]
Katie McAdams
Thanks for having me.
- [20:59]
Sarah Sleuth
So Basis has found that media teams today are juggling an average of nine different platforms to run a standard digital campaign. Which makes my head spin because I know when I, like, switch browser tabs or switch products, I'm like, wait, what was I here for again? So how does this impact their AB to be successful as an advertiser?
- [21:21]
Katie McAdams
Sure. So it's a great question. What we find in our research is that our industry is losing anywhere from 80 to $100 billion annually in value leakage from errors, inefficiency and siloed campaigns sitting in all of those different platforms that you're talking about. And advertising is just becoming more and more fragmented, whether it's across teams, channels, tools, finance systems, and now different AI solutions. So that's a lot of context switching for One team in one day.
- [21:50]
Sarah Sleuth
Wow. So what would a connected advertising system look like as an alternative to those nine platforms?
- [21:57]
Katie McAdams
What we find in talking to agencies and brands is that that journey really needs to start with consolidation. And by consolidation, I mean getting all of your media contracts, your campaign plans, your invoices, and your client communications into one place so that you have a single source of truth. And once you have that foundation in place, then something important really starts to happen. You actually have data that is clean and reliable so that your AI can function with it more meaningfully and more predictably. So the brands and agencies that get to this state fastest are not going to be the ones who are bolting on the most AI tools. They're going to be the ones who are able to build that operational foundation first.
- [22:35]
Sarah Sleuth
I like this point that centralization isn't just about, you know, me as the media planner, but also about having more unified data that will then help me with AI, which I'm glad you brought up AI. So tell us a little bit more about how AI is being added on to this connected advertising system.
- [22:54]
Katie McAdams
Sure. So this is where having that solid foundation in place is going to actually help AI become more of a multiplier for your organization and your teams. As an example, Basis has Compass, which is our agentic AI planning tool. It lives right inside our platform and it solves the problem of media teams spending hours and even sometimes days synthesizing media briefs, building frameworks, building media plans, and then creating client ready presentations before a campaign even launches. So Compass actually takes that brief and generates a complete omnichannel strategy across programmatic, search, social and direct in minutes instead of weeks. That strategy then becomes connected and pushed into their media plan, which can then be activated on through the BASIS platform across programmatic, search, social and direct media buys. And what we find is that agencies and brands who are using basis overall are seeing 30 to 40% operational efficiency gains when they operationalize all of those workflows into one place. And that really creates an expansion of capabilities with teams being able to gain back time to focus on strategy creativity and growth.
- [24:01]
Sarah Sleuth
So we have more efficiency through centralization, which then enables more use of AI, which is even more efficient. So really interesting to talk to you, Katie, and thank you to Basis for supporting our podcast.
- [24:13]
Katie McAdams
Thank you.
- [24:24]
Allison Schiff
All right, welcome back. And before we talk about the stuff I teased prior to the break, I want to get into enforcement and you touched on dark patterns briefly, but I want to talk about it in more detail. What exactly are companies still getting wrong when it Comes to dark patterns. And it's very important for companies to understand what this is because there have been recent fines. One against Healthline, the $1.55 million fine, the tractor supply settlement. They both had dark patterns components and I'm sure they won't be the only ones.
- [25:02]
Tom Kemp
Yes, and obviously it goes back. Definitely read the statute and the regulations. But I think the core principle here is walk a mile in the consumer shoes. If the user interface makes exercise of privacy rights hard confusing, if there is clearly some jumping through hoops, it likely is non compliant. And the other thing that I want to bring up is that oftentimes businesses assume that the vendor tools that they purchase kind of magically work out of the box. But Californians requirements such as honoring the GPCO opt out preference signal demand specific configuration and validation for California compliance. So definitely urge businesses to walk through the user experience. And what we see is that business ups is oftentimes forget to honor the GPC signal. Links don't provide meaningful choice cookie banners exist that actually don't affect sharing things of that nature as well. So definitely just like businesses probably thoroughly test the user interface to purchase or buy something online, they should go through a similar robust testing of people wanting to opt out, etc.
- [26:33]
Allison Schiff
It's wild to me how often companies forget about that aspect of things. They forget about the fact that a human being will be on the other end and experiencing their flow. I mean it's, it's actually quite easy, right? I mean you could probably just pull in someone off the street, sit them down at a computer and say what do you think of this? And that's enough to get a good sense. And there's something else I don't think the industry fully appreciates yet, which is that you don't have to wait for a consumer to complain because Cal Privacy has a dedicated technology team and you guys use automated tools to scan public facing websites for compliance and you're looking actively to see whether opt out mechanisms are working, whether companies are honoring the GPC signal. So a company could be under, I don't know if I want to use the word investigation. I don't know what the under scrutiny and not know it. I mean does the industry understand how exposed it is?
- [27:30]
Tom Kemp
Well, clearly it's important for us to enforce the law. And the goal of what we focused on is to make sure that consumers can actually take advantage of their privacy rights. And so we're very concerned about businesses that put blockers up either purposely or you know, through lack of testing. And as well, as maybe misconfiguration of third party tools, etc. Look, I'm not going to go into the tactics that we actually use, but it's not just us looking at this. There's actually a multi state investigatory sweep of GPC that we announced last September with not only us, but the Attorney General, California, Connecticut and Colorado. So it's not just California that cares about things like gpc, it's other states as well. And to be candid, those are the low hanging fruit. Right. And so, and if I certainly would recommend to your listeners to read not only our enforcement actions, but the California Attorney General and they kind of share the common themes where people were thwarted in their rights to exercise control over their personal information. And so clearly there should be a focus of businesses to make sure that consumers are not blocked in doing that.
- [29:14]
Allison Schiff
People have so much reading to do. You've given them so many assignments. I'd argue too that it's not even low hanging fruit. Like the fruit has already like fallen off the tree. Like you just have to pick up the fruit. It's come on. And you I wanted to bring up. And you already did the, the joint enforcement sweep with other states because that is very common. I mean, if there's an issue in one state and a regulator wants advice or wants to compare notes, they literally just pick up the phone and call their compatriot in another state. There's so much collaboration happening behind the scenes. So you really can't just, you can't ignore the fact that there's so much information sharing. And you have to be, you have to be worried about that, I think.
- [30:03]
Tom Kemp
Well, certainly we've helped form the consortium of privacy regulators that now has the attorney generals from 10 states and US that have active phone conversations, sharing of best practices and tips. Again, as I mentioned before, these privacy laws at the state level share common bones. And I don't know of an example of an enforcement action that we've done or another state has done that the other state wouldn't do. Right. So there is kind of a harmonization not only of the privacy rights, but there's consistency in enforcement actions as well. And so to your point, yes, there is active collaboration between states in this area, which means that there will be continued enforcement actions that happen.
- [31:01]
Allison Schiff
And just switching gears, I want to get into the new rules governing automated decision making which cover any technology that uses computation to replace human judgment in ways that affect consumers, which feels quite broad. But there is a carve out which says that serving ads to A consumer doesn't necessarily qualify in and of itself, but it's a brave new world. What about AI powered audience segmentation or predictive programmatic bidding? There's dynamic creative optimization, making real time decisions about what message to show someone. So I don't think that you would have an answer to this. It's more of a like a philosophical question at this point in terms of where the line gets drawn and how do companies get ready when compliance kicks in? I think next year. Right.
- [31:51]
Tom Kemp
Well, clearly that there is our regulations associated with automated decision making and. But we also have regulations for risk assessments that have actually already kicked in. Right. And in the future you will actually have to provide the agency attestations. Furthermore, there's the cybersecurity audits and that also have kicked in and businesses based on their revenue size will have to provide certifications that they've gone through it. So it's not only admt and maybe there is, as you mentioned there, there may be a carve out specifically to AD serving, but that doesn't get you off the hook for risk assessment cybersecurity audits. Specific. I want to bring up a few things specific to automated decision making. First and foremost, the regulations are technology neutral. So you don't necessarily have to be using AI for your admt. It doesn't matter what the underlying technology is if it is making automated decision making. To your point, the automated decision making that we do have specifically involves significant decisions in the areas of loans, education, housing, healthcare and education. And again, each business needs to decide, you know, whether the ADMT regulations apply to them. And again, it's technology neutral. But there's other aspects of our regulations that while it may not apply to them as it relates to automated decision making, there are other aspects of our regulations that would apply, like risk assessment and cybersecurity that are equally as important as well.
- [33:45]
Allison Schiff
And as we come close to the end, there are a couple of other themes from recent enforcements I want to call out, but particularly the GM settlement. It was the largest CCPA penalty ever, 12.75 million. But I think it's notable for a reason beyond its size, really for what it was about. Because it was the first major case that was focused on data minimization and purpose limitation. GM was collecting and sharing data for reasons that consumers weren't told about. They kept the data for too long. They collected what they didn't need. That feels like a new frontier for enforcement. Not just did you honor the opt out, but should you even have been collecting this data in the first place and keeping it around.
- [34:30]
Tom Kemp
Yeah, I mean, clearly, you know, if you historically look at the enforcement actions that have been taken by the Attorney General and Cal Privacy, it's very much been focused on the exercise of privacy rights and entities putting up blockers to facilitate that. And now that we kind of have set a set of precedents and clear have a set of enforcement advisories as well as people can actually read the settlement agreements, it makes perfect sense that we can now explore other aspects of the law. And in this particular case, because it really cut very. It was kind of a kitchen table situation in which people are concerned about the misuse of their sensitive information. They are worried about that. Would data that's being collected be used against them in driving up pricing or other aspects as well? So, yeah, I think to your point, this certainly represents kind of an evolution of where things are going from an enforcement perspective. It also showed the collaboration between us and the Attorney General and even local district attorneys. It clearly is the greatest or the largest to date. CCPA Fine as well. So, yeah, there's a lot that you can draw from that. But I do think you're kind of. Your core statement rings true.
- [36:14]
Allison Schiff
So, penultimate question. You recently hired your first chief privacy auditor, Sabrina Boynson Boysen. Sabrina Boysen Ross. She came from Meta's privacy and AI policy team. So does she know where all the bodies are buried? She's seen some things.
- [36:34]
Tom Kemp
Well, we certainly hire qualified people. In the past, she worked doing privacy for other Silicon Valley technology companies. And what this represents is a clear signal that what we're going just like the evolution that you saw with like the General Motors enforcement action that we are now. And this was actually called forth in the statute. This position, you know, was built into Prop 24 and explicitly called out. This means that we're also going to start looking a lot more at compliance as opposed to just purely violations. And so it is the further evolution of where we're we're heading. And obviously we're looking to hire the best people to do this. And we feel really happy that Sabrina joined and she's building out the team. And as I publicly said, that there will be audits of businesses occurring this calendar year. And so we've, we've got that happening as we speak.
- [37:52]
Allison Schiff
So time flies when you're nerding out on privacy. My last question would be, I mean, if you could share a message with the average ad exchanger, reader or listener, in this case as a regulator who came from industry, what would it be?
- [38:09]
Tom Kemp
Well, a couple things. I mean, first of all, we do have an open door policy and we're trying to get out into the privacy ecosystem and community and want to make sure that there's open lines of communication. And we even just recently came out with requests for public comments about potentially future regulations as well. And if you look at the nature of the regulations, it's not part of the regulations were how can we streamline things further for you? And so that is an area of interest that we have. If there are things that people are getting tripped up in terms of implementing obligations, please let us know. When we asked how can we reduce friction, it was not only about reduced friction for consumers, but how can we reduce friction for businesses implementing dsa, ours and other and also same thing with notices, right? How could we what can we do to ensure that the whole privacy notice regime is is easier for businesses to address meet, et cetera. So I think the key thing for your readers are, is that we certainly want to listen to you. We want to get your feedback and input. We just recently had that public comment, but it's okay to reach out if you have comments and suggestions, et cetera. And then the other thing that I want to bring forth is that again, walk a mile in the shoe of an average consumer. And what we find is that people have kind of forgotten to do that. They do a great job of optimizing their technology, the purchase process, et cetera, but they don't apply that same type of focus to enabling consumers to exercise their privacy. And so that's my other thing that I want to really harp upon as well.
- [40:08]
Allison Schiff
In that vein, I like replacing the word consumer with person, consumers with people, because consumers are people and consumer is kind of an abstraction. So I'm with you.
- [40:24]
Tom Kemp
That's right.
- [40:25]
Sarah Sleuth
Foreign. This episode was sponsored by basis, the leading intelligent operating system for autonomous advertising. Its enterprise AI solution transforms campaign briefs into strategies and media plans that integrate directly into omnichannel activation. Learn more@basis.com.