Please describe your proposed solution.
Existing Catalyst funded projects - Profila has already received funding by the Cardano community for 4 project workstreams (privacy - data sharing via NFTs - digital ID - tokenization/gamification) - during fund 5, 6, 7 and 8 of Project Catalyst. We thank the Cardano community for their trust and support.
All our projects are aimed at giving people back control over their personal data, control over brand content they see, and provide people with compensation for their data and attention. The project workstreams we are developing are the following:
1. Privacy - titled: Control your data - privacy ledger (funds 5 and 8); and Company privacy ledger (GDPR & CCPA)(fund 8)
2. Data sharing via NFT: NFT for customer feedback/content (fund 6); and (d)app to control your data (fund 6)
3. DID - Control your data (vault) via PRISM (funds 6 and 8)
4. Tokenization/Gamification - anonymity and data control with ZKT (funds 7 and 8).
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Privacy workstream projects
This current proposal under fund 9 called "Profila privacy ledger - 3dP access", is a continuation of the earlier privacy metadata ledger we build and delivered under fund 5, and are further extending under fund 8.
- Fund 5 - privacy metadata ledger - first POC to add metadata about a data right exercised by an individual to the blockchain (testnet) - project closeout video available above
- Fund 8 - privacy ledger part 2 - improvements to the testnet POC
- Fund 8 - company privacy ledger - allowing brands/companies also to access the ledger and log their responses to your legal request, providing them with immutable proof they responded adequately and in time
Now under fund 9, we will allow both parties who are part of the legal request (people - brands) to allow third parties to access to the metadata ledger entry (and the off-chain stored personal data linked to the metadata entry), by giving them a temporary private/public key pair. A third party can be a lawyer or even a judge (in case of a dispute about how personal data was misused), but also a governmental agency or data privacy authority (e.g. in case you want to complain to a privacy authority that a company didn't adequately or timely respond to your legal request). It is important for the purpose of legal proof, that third parties can access this information to validate whether or not a data subject right was exercised, what its content was, whether the brand responded in time and with adequate information.
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Detailed solution
<u>"From data abuse to personal data control" – implementing and developing on top of Cardano a metadata store to that give people control over their personal information and demonstrate when an individual exercised a data subject right.</u>
Short summary of the Profila app (as testing ground for the metadata ledger POC) - Profila is a platform (consisting of both a mobile IOS and Android application for individuals and a web-based dashboard for companies, organizations, governments and other legal entities, we call "Brands") that enables individuals to communicate with various organizations in their lives, privately, one-to-one, and without supervision or surveillance. Organizations can be either private or public entities.
Consumers can manage their digital life in one location. They can sort all their personal information, product preferences and communication preferences and communicate with all the organizations they want to interact with in the same easy way (instead of on each individual organization's platform each time). The entire tool is design for people to (1) gain control over their personal data; (2) choose to ethically share (or not) they personal data with organisations, and (3) get compensated if they do.
We invite you to read our pitch deck and check out our product demo (both in PDF attached to this proposal), which will show you more details about our product, market, go to market, team, business model, traction, partnership, funds and grants received. Our product demo shows you the app that exists today and explains the most important features.
Before going into the proposal, the concept of "data subject rights" needs some explanation.
1. The concept of data subject rights as a legal tool for individuals to start controlling their data
A first step to data control is knowing your rights in relation to your data and taking action against those who misuse your data. This can be done via "data subject rights", as explained briefly below.
Numerous national and regional privacy or consumer protection laws, regulations and jurisprudence provide private individuals – often called "data subjects" – with certain rights in relation to their personal data. Under certain conditions, these rights can be enforced against businesses that process personal data.
These rights are often called "data subject rights" or "data rights" and may include e.g.
- right to information - the right to be informed about how a business uses your personal data
- right to opt out - people can ask businesses to stop selling their personal information or using it for business benefit;
- right to access – ask access to personal data that is being processed by a business (e.g. ; hen you want to know just how much data a company has about you);
- right to be forgotten – ask a business to delete your personal data (e.g. when you don't want to receive any products anymore, and definitely no more marketing messages);
- right to rectification – ask a business to rectify personal information about you that is inaccurate or incomplete (e.g. they have your old address or there is a typo in your name);
We can find these rights in the European General Data Protection Regulation (GDPR); the California Consumer Privacy Act (CCPA); the Brazilian General Data Protection Regulation (LGDP) and many more.
The main goal of these rights it to GIVE CONSUMERS CONTROL OVER THEIR PERSONAL DATA. These laws (GDRP, CCPA; LGDP) include many obligations for companies; namely to (i) inform consumers of these rights; (ii) to help them exercise these rights; (iii) to timely respond to these rights, mostly within a reasonable period of 15 to 30 days; and (iv) to do this all in a transparent way, and no cost to the individual.
2. Privacy rights today – problems – lack of education and management
Today, you have no control over the use of your personal data. In order to control your data, you need to know what happens to it, and you need to be able to take action against those who misuse it. This is where DSRs come in very handy, as they can be used by each individual to (1) become aware of what personal data is collected; how it is used (=information) and – once you have this information – to (2) tell businesses what to do (different) (e.g. rectify; delete; opt out).
However, do you know what your rights are and how you need to exercise them? Today, there is no tool available that lets you learn about your rights and provide you with an easy way to exercise them. Some local websites of data protection authorities provide you with information and templates, but require you to download lengthy word documents, fill out 10-15 elements in these documents, upload them, send them by email or post to the Brand in question. This process is only available for those people who actually know what a data protection authority is (=what?), and who are willing to spend some hours to get the template filled out and send.
That is where Profila comes in.
3. Profila today - the existing consumer App – first step towards data control via privacy education and data rights management
The current Profila App has a consumer-friendly privacy education and data rights management dashboard (see "illustration 2 – Profila Privacy App").
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<u>Education</u> – the App has 9 basic modules about your privacy rights, explaining to you in understandable terms and with examples "what is personal data", "what is a controller/processor", "what are your rights", what is e.g. "your right to be forgotten" (including GDPR in Europe, CCPA in California, LGDP in Brazil). They are tools that can be used by consumers to control their data.
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<u>Rights Management</u> – the App then has a dashboard which allows you to manage your rights, e.g. use your "right to object" to tell Wholefoods to stop sending daily emails, or your "right to be forgotten" to ask Wholefoods to erase all personal data they hold about you. Profila has reduced this legally difficult process of exercising data subject rights to an easy 3-click step process, where you can (1) choose a company logo (recipient of the right); (2) click on one of the 8 data subject rights, and (3) include an identifier (email; phone). Profila then forwards an official legal template to the business. According to the law that applies to your relationship with this company (which is determined based on your country of residence/nationality), the company will be legally required to respond to you within 15-30 days.
4. Profila tomorrow – the Catalyst project - implementing DSR transaction metadata on Cardano, to demonstrate/prove that a DSR was exercised
What do we seek to improve via this privacy workstream (under funds 5 - 8)?
Issue - "centralized DSR management" - Each data subject right (DSR) that is exercised by an individual using Profila (including the specific terms like which DSR, data, company recipient, specific content and request), is only saved by Profila in our IT environment, and can only be enforced by Profila or its existence proven by Profila. Profila is therefore guaranteeing that the legal request/transaction happened, what terms it contains, whether terms are abided by (e.g. did the business actually respond to the request in time, as they are legally obligated to do).
This is a liability for both contracting parties, who would need to trust Profila. Profila, as a commercial company, would have to actively step in as arbitrator/mediator, and guarantee this level of trust that a transaction took place + terms thereof. However, we only want to provide consumers with the tools to control their data. The trust and consensus that a transaction took place or contract was made needs to come from the community of users.
Under earlier Catalyst projects (fund 5/8), we tackled this issue by making available on Cardano a ledger for all privacy interactions that you as an individual exercised via the Profila privacy rights management platform: each user that exercises a data subject right with a brand will be able to easily access each such request, including the brands' response. We also are making a similar ledger for companies so they can access all metadata about their responses to these requests by customers.
E.g. You exercises your right to object to the processing of direct marketing messages to Wholefoods, after receiving 15 mails per week with advertising. If several months after this request, Wholefoods doesn't abide by this request and again starts using your personal data to send you direct marketing messages, you can use the ledger entry as immutable proof of the right you exercised. This way, you can show Wholefoods they breached your right and hold them accountable (unlike the "unsubscribe" buttons you click 10x times, with no proof thereof, and with no effect because mails keep on coming). You can even use the information in the ledger to file a complaint at a national data protection authority, showing them what you agreed to, and how the company actually (mis)used your data. You will be able to check forever, every legal right you send to a business concerning the use of your (personal) data. Nobody would be able to tamper with this information. This is control.
This current proposal under fund 9 called "Profila privacy ledger - 3dP access", is a continuation of the earlier privacy metadata ledger we build and delivered under fund 5, and are further extending under fund 8.
- Fund 5 - privacy metadata ledger - first POC to add metadata about a data right exercised by an individual to the blockchain (testnet) - project closeout video available above
- Fund 8 - privacy ledger part 2 - improvements to the testnet POC
- Fund 8 - company privacy ledger - allowing brands/companies also to access the ledger and log their responses to your legal request, providing them with immutable proof they responded adequately and in time
Now under fund 9, we will allow both parties who are part of the legal request (people - brands) to allow third parties access to the metadata ledger entry (and the off-chain stored personal data linked to the metadata entry), by giving them a temporary private/public key pair. A third party can be a lawyer or even a judge (in case of a dispute about how personal data was misused), but also a governmental agency or data privacy authority (e.g. in case you want to complain to a privacy authority that a company didn't adequately or timely respond to your legal request).
Please describe how your proposed solution will address the Challenge that you have submitted it in.
"What dapps, products and integrations can be implemented to bring impactful use cases to Cardano ecosystem that help drive more adoption?"
The solution is a distributed product and integrates with the Cardano blockchain by adding metadata each time an individual exercises a right.
Each individual in the world has the right to exercise them and currently there is no form of proof that this happened. The impact of this proposal on Cardano could be very large if we can make our solution public. This is also why under this proposal we will now start talking to regulators to explain them the advantages. Privacy regulators might be able to help us reach a lot of people.
What are the main risks that could prevent you from delivering the project successfully and please explain how you will mitigate each risk?
As we already delivered the first part of this POC under fund 5 (see video above), we know how to further develop this privacy ledger.
The only risk of not delivering this project would be the bankruptcy of our company (Profila GmbH) during this bear market. However, we have raised sufficient funds before May 2022 to survive for the next 12 months.
Our “grants and partnerships” slide shows some of the research, institutional and governmental relationships we have build up over the last years. We have the necessary funding and technical partners to successfully manage multiple projects on Cardano, together with our team of almost 20 people. Our development partnership with Mlabs (blockchain developers) and Steppechange (Adtech/Data developers) as well as our relationship with IOHK’s professional development team complement our own CTO/dev team in the technical deliverables. Our long term research partnerships with the University of Luzern (privacy - NLP/ML) and University of Madrid (adtech, digital identity, zero knowledge advertising) give us access to 2 teams of +5 experienced professors/researchers who are working on a monthly basis on our projects. Our funding slide in the deck also shows we have obtained sufficient funding – apart from the +1 million USD grants – to survive as a company during these uncertain times in the market. We will definitely be able to make good on our promise to the Cardano community to deliver.