Dapp to control/monetize your data

Consent-based customer data (D)app, using smart contracts to record personal data licenses; compensating people for their data & attention

Privacy/Tech lawyer with 10Y XP in (project relevant) legal issues - consumer privacy; digital marketing; data rights & virtual currencies.

This proposal is an updated proposal from Fund 4 - several responses to questions raised by the community advisors during fund 4 review are included at the bottom of this submission. #thankyouADAcommunity
---
"From data abuse to personal data control and direct compensation" – implementing and developing on top of the Cardano blockchain a smart contract system that (i) gives people back control over their personal information and (2) compensates them for the use of their data and for their attention.

Cardano adoption and impact in the next 6 months - We are currently launching the existing Profila mobile application (iOS/Android) with 5 SME consumer brands in 3 regions (Benelux - Switzerland - Orlando/California), and are expecting +/- 1000-2000 users per month to join (via B2B2C model, as invited by brands). 25.000 expected in 2021; 78.200 expected in 2022. More info under the detailed plan, section 5. Proof of concepts (POCs) to develop under this project submission can be tested with these consumers.

Short summary of the Profila app (as testing ground for the smart contract POCs) - 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. (see "Illustration 1 – Profila for Consumers" attached to this proposal).

Now let's move on to our actual proposal (!):

1. The market explained - the current privacy problem en digital marketing business model
Today's online advertisement model - A big part of the time we spend online (social media and websites), we are being subjected to online advertisement. The advertisement market touches billion of consumers and poses great privacy concerns.
Online advertisement is a lucrative business model, valued at USD 304 billion in 2019 and is expected to reach USD 982.82 billion by 2025. This model is entirely based on collecting as much personal data about you and increasing your screen-time. Every second and click (literally) counts. What is being bought and sold by brands, ad agencies and social media companies is your attention, at a cost-per-view (CPM, per 1000 views) or cost-per-click (CPC) rate (namely each time you click an ad). For example; Facebook's average CPC is USD 1.72 worldwide; and each user clicks on avg. on 12 ads per month. In USA/Canada, Facebook's has an avg. revenue per user around USD 200/year.

Online advertisement's privacy problem - In order to present you with the best add at the right time, social media or ad companies need to sell your attention to the highest bidding business/organisation (we call them "Brands"). They therefore collect a large amount of personal data about you, in order to present Brands with the best possible picture of who you are and what you like. Some of this data is collected directly from you, whereas other information is collected via cookies or other third parties. Most people are not aware of how much data is shared with how many Brands, and how they use it.

The larger privacy problem – you don't know your rights or what you agree to. The same privacy problem in online advertising can be found in your direct relationship with Brands. People interact with digital services and purchase products from Brands globally. With each interaction - regulated by such a privacy policy – you directly share personal data which is used for a certain purpose (e.g. offering you a product and servicing you as a customer). You agree to share your personal data – in most cases – without knowing how a Brand will use it.

In principle, each time your personal data is collected or used by a brand, you are shown a privacy policy or cookie policy you are forced to accept. Thereby, you agree to share your personal data, without knowing how recipients will use it. These legal documents make it almost impossible to understand.

But what can you do if Brands uses your data against your expectations, and how do you keep track of all these legal terms that governs Brands' use of your personal data? You made an online Wholefoods-account to order groceries but you now get 15 newsletters/week, and your social media feed is full of adds from companies like Trader Joe's, to who you never shared your personal data. You have no idea what you agreed to in a privacy policy with Wholefoods, and you do not know why similar companies are contacting you for products you bought from Wholefoods.

Today, you have no control over the use of your personal data. However, people demand more control over their personal data and are willing to take action to gain back ownership of their digital lives, but the resources to put that in motion are lacking.

That is where Profila steps in!

2. Profila today - the existing consumer App – first step towards data control and compensation

"We must work together with web companies to strike a balance that puts a fair level of data control back in the hands of people, including the development of new technology … and exploring alternative revenue models like subscriptions and micropayments" (Tim Berners-Lee, developer of the worldwide web @ CERN).

If you know how to control your data and take action against those who (mis)use it, you can demand the value that is derived from it by asking compensation.

The current Profila App helps people control their data (see 2.1 "data control through privacy rights education and management") and demand compensation for the use of their data (see 2.2 "subscriptions and micropayments".)

2.1 Data Control through Privacy Rights education and Privacy Rights Management

A first step to data control is knowing your rights in relation to your data and taking action against those who misuse your data.

Numerous national and regional privacy and consumer protection laws (e.g. European General Data Protection Regulation (GDPR); the California Consumer Privacy Act (CCPA); the Brazilian General Data Protection Regulation (LGDP) and many more) grants private individuals – often called "data subjects" – with certain rights in relation to their personal data, that can help you control/manage your data and hold Brands accountable. These rights are often called "data subject rights" or "data rights" and include e.g. the right to information; the right to opt-out, the right to access; the right to be forgotten. The main goal of these rights it to GIVE CONSUMERS CONTROL OVER THEIR PERSONAL DATA.

However, in order to take control, you need to (1) understand your privacy rights (step 1 "education"), and (2) understand how to manage these rights (step 2 "management"). The existing Profila mobile App therefore includes a privacy education and data rights management functionality:

1. Education – 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" (see "Illustration 2 – Profila Privacy App" attached to this proposal).

1. Rights Management – 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.

2.2 Subscriptions and Micropayments

A second step in order to get to data control, is keeping track of your personal data. Where does your personal data reside and who has access to it? This is taken care of by Profila's data subscriptions.

Profila's data subscription contract functionality allows for people to keep track of all the Brands that access and collect your personal data; and ultimately receive a compensation from Brands that subscribe to your data.

Via Profila's web-based Brand dashboard, a Brand can send a "subscription offer" to their existing customers or potential new customers, in which the Brand can detail which of your personal information in your Profila App (one source of truth with your contact details, communication-, product preferences) they ask access to, and in which they propose to you some key contractual terms in relation to your interaction; a.o. (1) the specific data they require, (2) the duration you grant access; (3) the purpose for which the Brand wants to use it; and (4) the compensation you receive in exchange. Our process makes sure the Brand explains the contract terms in understandable language, so the consumer knows what he/she agrees to. Our revenue model is 50/50, meaning that every USD that a Brand pays for accessing your personal data (and showing you its products/services), we share 50/50 with consumers.

(Please see the illustration "Smart contract visual" for the UX shown to the consumer during the subscription process).
If you do not agree to these terms, you remain anonymous and the Brand will never see your personal data. If you do agree to these terms, you essentially click "accept" and both parties conclude a data subscription contract. Payment is made by the brand at intervals throughout the contract terms (usually monthly), on the conditions that the consumers' personal data is kept up to data, and the brand can also access additional data about the consumer's preferences for certain products and services relevant for the brand.

E.g. Wholefoods pays Alice 12 USD/year (1 USD each month) to access her (i) personal data (email, phone) (ii) preferences about food (vegetarian, bio-products, lactose intolerant) and (iii) communication preferences (Alice would like to receive discounts/product info via WhatsApp). This helps to serve her better. If Wholefoods listens to Alice, she will be a happy consumer. Alice gets good products and services and receives a compensation for the use of her personal data by Wholefoods. Each advertisement she watches, Alice gets paid. If Alice wants to know in the future what she agreed to, she can easily verify the terms of her relationship with Wholefoods in her Profila App (under the Wholefoods data subscription). If Alice want's the relationship to stop, she can end the contract and exercise her "right to be forgotten", so that Wholefoods is legally required to delete her personal data.

3. Profila tomorrow – the Catalyst project - implementing privacy right transactions and data subscription contracts on the Cardano blockchain in the form of a smart contract, and using ADA for micropayments

What do we seek to improve via this Challenge?

Issue 1 - "centralized privacy rights' and contract management" - Each privacy right that an individual Profila user sends to a Brand today; as well as each data subscription contract (including the specific terms) that is concluded between an individual Profila user and a Brand today, is only saved/stored by Profila in our IT environment and can only be enforced by Profila or its existence proven by Profila. Profila as a commercial entity is therefore guaranteeing that a privacy right was exercises, or that a data subscription contract exists, what terms it contains, whether terms are abided by (e.g. payments made or request received).

For the privacy rights, Profila needs to monitor if the Brand received the data subject right request and if the Brand – timely – responded to the individual. If there is a dispute because a Brand does not abide by the rights / continues to (ab)use an individual's personal data in breach of the right he/she exercises, Profila as a company will need to be involved as third party to proof that such right was exercises on a specific moment.

For the data subscriptions, Profila needs to monitor if money is paid by the Brand, and if personal data and other commercial data by the individuals is filled in/updated. This is a liability for both contracting parties, who would need to trust Profila.
In both cases, we, as a commercial company, would have to actively step in as arbitrator/mediator, and guarantee this level of trust that a transaction took place/contract was concluded + 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.

Issue 2 - "low-value; high volume payments" - The data license fee and any other fees for attention to be paid to users are currently setup using Stripe, which is not entirely ideal for sending very low-amount, high-volume instant payments worldwide. What is Mitsubishi, as a Japanese brand, needs to pay a US consumer on Profila for seeing an add? We would have to bill Mitsubishi 0.40 USD for displaying the add and transfer our US customer 0,20 USD. This takes time, administration, and will include large payment processing fees (compared to the amount transferred). Considering the amount of customers of the Profila App (25.000 expected in 2021; 78.200 expected in 2022), this payout model doesn't scale. We have setup monthly payouts to consumers (in bulk, for several activities with several brands combined) to reduce costs of transferring money, but we would want to be able to instantly pay a consumer.

What do we seek to create in the POCs under this Challenge?

Under the Catalyst project (fund 5), we want to tackle these 2 issues by including smart contracts (which executes themselves and don't require Profila as intermediary monitoring entity) and paying the compensation out via ADA. See "illustration 5 - Profila Catalyst - 2 POC use cases illustrated"

First, we will include the relevant elements of a data subject / privacy right (POC 1) or of a data subscription (POC 2) in an immutable (Cardano) blockchain ledger, so each individual has an audit trail of every such transaction (=privacy right exercised) or interaction with a brand (=data subscription contract) that concerned the use of its personal data.

Data subject rights ledger POC 1– 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.

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. (unlike the "unsubscribe" buttons you click 10x times, with no proof thereof, and with no effect because mails keep on coming).

Subscriptions ledger POC 2 – a ledger of all data license contract you concluded with different Brands, showing every authorization or consent he/she gave to each company for the use of your (personal) data.

Nobody would be able to tamper with this information. If a company misuses your data, you can make them accountable by referring to the ledger entry. You can even use the information in the blockchain 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. This is control.
Second, we want to integrate cryptocurrency payments using ADA, so that people can receive instant micropayments for their personal data and attention if the terms of the smart contract remain fulfilled. Our vision is that by the time the online advertisement market reaches USD 982.82 billion by 2025, every USD of that budget that gets spend via Profila, goes to our users in the form of cryptocurrencies.

What other challenges are ahead in our "Zero-knowledge advertising & insights" development roadmap?

This smart-contract project is only the first step into our broader Cardano technology adoption and integration around zero-knowledge advertising and insights, which all relate to the control of your personal data and your attention by you as an individual. Under the next funds, we want to submit additional project proposals for important features we want to develop as part of this effort:

- step 1 - personal data license smart contract - this is part of the present submission. This will include a ledger for all data license contract concluded between individuals and businesses. under Fund 4 "dapps and integrations", we already submitted this first step in our "zero knowledge advertising and insights" project called "Dapp to control and monetize your data". https://cardano.ideascale.com/a/dtd/Dapp-to-control-monetize-your-data/341501-48088, which we now file again in addition to step 2, "privacy ledger".

- step 2 - privacy ledger - this is part of the present submission. This will include a ledger for all privacy interactions via the privacy rights management platform.

- step 3 (for FUND 6 or later) - zero-knowledge proofs - personalized ads with respect of privacy - using zero-knowledge proofs in order to allow a brand to advertise to the "perfect" consumer (meaning to the exact target audience consumer, which exactly matches the specific offering/message a brand wants to share), without sharing ANY personal data with the brand. This in se means that a brand is doing highly relevant and personalized advertising, and a very high cost of conversion (and low cost of engagement), without the privacy risks that the current surveillance marketing model has (=namely, the model requires large amounts of personal data in order to personalize advertising). We will be able to tell when a consumer wants to see an add from which brand, without having to tell the brand who this consumer actually is. Only when the consumer converts (and actually buys a product or service) on the brand's own system, will the brand have access to his/her personal data.

- Step 4 - digital ID (for FUND 7 or later) - Atala implementation - All digital ID data can be securely stored and encrypted on a user's device, using Cardano 's decentralized public key infrastructure. Each individual can allow organisations access thereto as permissioned by the user; With this integration, we can better guarantee that the correct person is sharing information and is receiving payments.

4. Practical aspects – "show us the money" – costs

Via this submission, we are requesting 42.400 USD funding to develop the 2 POCs:

Step 1 - Creating a first proof of concept (POC) on the Cardano blockchain of a ledger that stores each transaction from the privacy rights management platform, namely when a user X exercised a data subject right Y towards the Brand Z. will require at least a budget of 19.200 USD for a 3-month development project, to be allocated as follows:

- 15 days of senior blockchain developer @ 800 EUR per day – totaling 12.000 USD
- 15 days of web/backend developer @ 240 EUR per day – totaling +/- 3.600 USD
- 15 days of app developer @ 240 EUR per hour – totaling +/- 3.600 USD

Step 2 - Creating a first proof of concept (POC) of a data subscription on the Cardano blockchain, will require at least a budget of 23.200 USD for a 3-month development project, to be allocated as follows:

- 20 days of senior blockchain developer @ 800 EUR per day – totaling 16.000 USD
- 15 days of web/backend developer @ 240 EUR per day – totaling +/- 3.600 USD
- 15 days of app developer @ 240 EUR per hour – totaling +/- 3.600 USD

We are currently already preparing for the development of this solution – which we are trying to pre-finance – because we believe this is a very important functionality in the control of your data. We expect the solution to be ready by the end of Q2 2021, early Q3 2021, so that we can test it with the companies that are now using the Profila app with their consumers.
Who will be the senior blockchain developer? We are currently in tasks with IOHK's professional services department (option 1) and are "seeking" in parallel a blockchain developer in the Catalyst community (=those who are interested, please contact myself or Shawn).

5. Practical aspects – "getting on the road" – GTM; geographical focus; target customer

At the time of the submission of our application to Catalyst Fund 5, the development of our Profila App is finalized and we are onboarding/setting up 5 small and medium enterprises (SME) to trial with their existing consumers. This section explains more about our GTM, ideal location, target customers etc.

(1) Go-to-Market – our Go-to-Market is B2B2C, namely working with brands to invite their existing consumers onto the Profila App, as a new communication channel that is privacy compliant and consumer centric. As part of the onboarding process of these brands, we work together with them to design a promotional campaign via email/social media, via which they invite their best customers to engage with them via Profila. These campaigns will show the benefits of Profila (=individual in control; individual compensated) and will attract the first customers to join this kind of new loyalty program. It is therefore not necessary that all the brands' customers join, but mostly the loyal customers that want to be engaged. We project that for SME companies, around 5% of their existing customer base will join this "new relationship" in the first year/after the promotional campaign. This would be seen as a success.

We have signed up 5x SMEs in 3 regions (see below), who in total have around 500.000 existing customers all combined. Considering that we expect 5% of this customer base to accept the invitation and join Profila, we foresee 25.000 active Profila users in 2021. According to our active brand onboarding efforts, this should grow to 78.000 in 2022 (by adding more brands).

(2) Geographical focus market? We are currently launching the Profila App with 5 SME Brands in 3 regions in Q1/Q2 2021 (Benelux - Switzerland - Orlando/California).

(3) Ideal consumer segment? – privacy-aware and digitally savvy "Millennials" (adults between the ages of 22 and 39 years old), and "brand-loyalists" (consumers that have an affinity with the brand and would like to have a closer 1-1 relationship).
Following a research collaboration we conducted with the University of St. Gallen University of Zurich (Switzerland) to define our go-to-market strategy, we concluded that Millennials are the target consumer audience. Millennials carry out most of their transactions online and are aware of their digital footprint. They are also aware that they have rights to their personal data, but do not yet have an easy tool to control it. Our research also showed that brand-loyalists are more likely to put in the time required to manage their relationship with brands, and to actively tell the brand what content they want to receive, via which channels.

(4) Ideal SME segment? – SME companies in these 3 regions that respect consumer privacy and want a better relationship with their consumers, with a prime focus on SMEs in the following industries: (1) fashion, (2) travel, (3) leisure/recreation.

(5) Marketing, Website & social media presence – We have focused our 3-year research and development phase (as well as our funding) on the development and testing of our consumer app and brand dashboard and have – on purpose – not made much noise about our project until now. Now that the first product is ready and being tested, we are starting a first marketing campaign on LinkedIn https://www.linkedin.com/company/profilaprivacy (B2B, attracting new companies that want to have a different relationship as described above), we are rebuilding our Website www.profila.com (new version expected end-of-April 2021), and will start a consumer campaign on social media focusing on our ideal customer target (see above).

6. Intellectual Property information (freedom to operate; IP registrations; contracts)

As an intellectual property lawyer, I made sure that all Profila's intellectual property (IP)-assets are documented/protected:

First, we have conducted a thorough freedom to operate study and patent landscape analysis with the Swiss Innovation Agency, to make sure we are free to develop and commercialize our current technology without infringing on third-party rights.

Second, we have filed for the necessary trademarks that protect our logos and trade names in commerce.

In addition, we have a solid contractual framework in place with all of our suppliers, employees, contractors and customers. All parties involved in our day-to-day activities are doing so under a contract, which include the necessary IP transfer-, confidentiality- and non-compete obligations that protect (and collect) our company's intellectual assets. As part of that, every contracted developer has assigned all IP rights to the Profila App to us, which we will also require from developers working on this project.

Finally, we are looking into open sourcing the majority of the technology (code) developed under this project and will assess on an ongoing basis which components would be of interest to the community.

7. Defining success

The 2x POC we are developing (and hope to get funded for) under this first Catalyst (fund 5) submission will add important functionalities to our consumer App – which is being tested on the market during the next 6 months. The POC will also advance our mission and vision to provide people with control of their data and compensation for their attention. Success of the POC would be that we can integrate it into our existing App with one of the 5 SME brands that are testing, and make sure it works with their consumers, and their consumers can get paid via an integrated or linked ADA wallet.

Succes after 3 months - finalizing the POC work to be tested in the App

Succes after 6 months - running targeted trials with the POC in the App with real customers

Succes after 12 months - full deployment of the smart contract POC in the App; covering every interaction that includes privacy rights from every user.

Overview of the work-packages which technical requirements and sprints to be included shortly.

8. Responses to community advisors' reviews under Fund 4

We want to end our proposal by thanking the community (advisors) for their numerous great feedbacks during the review phase of our proposal under Fund 4, where we submitted this first step in our "zero knowledge advertising and insights" project called "Dapp to control and monetize your data". https://cardano.ideascale.com/a/dtd/Dapp-to-control-monetize-your-data/341501-48088

We are very grateful and humbled by the 3,55/5 score we received from the 36 reviewers, who showed they read our proposal in detail and who provided valuable feedback. #thankyouADAcommunity

We wanted to briefly respond to some open questions of those of the 36 who made some reservations.

Adoption GTM

"[…] without seeing a business plan that addresses how the Dapp will scale. How will we get to 78,000 users"? and "[…] how to go from development to millennial adoption"

Profila answer: We have provided more information about our go to marketing in point 5 "Practical aspects – "getting on the road", the first title "Go-To-Market".

Marketing / website low

"[…] there is not much mentioned about the marketing of the project, and the website could do a bit of work, so the team could possibly turn attention to this eventually"; and "More information regarding the onboarding process of marketing channels and how it could be deployed in social media platforms could strengthen a bit more the angle" (CA comments)

Profila answer: Agree! We have been focusing our 3 years R&D time and funds on the product and are just starting with our marketing messaging/social media presence/website revamp. Stay tuned during the next weeks for substantial progress there! You can already follow us on Linked "Profila – Relationships Redefined" - https://www.linkedin.com/company/profilaprivacy and our Website www.profila.com should be updated before the end of the month April 2021.

BAT/brave comparison
"This is interesting solution to a relevant problem, but the proposal is very similar to the Brave/BAT protocol which is well established." (CA comment)

We are definitely BRAVE fans (and have been following them since 2018)! Although there are some similar goals when it comes to the post-cookie advertising market (zero-knowledge), Profila has a different angle in many ways.

Brave doesn't use third party cookie tracking and uses also zero-knowledge proofs to show you "relevant" adds (if you choose to), but this relevance is based on – again – your (web browsing) activity on the brave browser. Just as in normal advertisement via other browsers, there is no context around why / and Brave doesn't really know you + can't do anything outside of its own browser. If I – as a 30-year-old Belgian lawyer – search the internet for "glitter dog toys" because my client wants to know if there are competitors on the market, Brave might think I am a dog owner who wants to buy toys.
As we detailed in our proposal: our consumer app focuses on creating meaningful relationships with brands/companies that you as an individual choose, and where you define the parameters of the relationship, namely when can they (directly) contact you, via which channels (e.g. Profila app, e-mail, post, phone), and what content you want to receive from them as well as the frequency thereof. We are merely a facilitator of this new 1-1 relationship but provide tools to empower consumers.
The competitive landscape illustration in our slide deck attached shows that our mobile application for consumers is an over the top (OTT) opportunity in people-centric customer communications across four markets (of which some include Brave's market, see Brave logo in column 1 and 3 of the slide "competitive landscape" in the PDF pitch deck attached to this proposal), namely:

(i) individual privacy rights management and education,
(ii) personal data and insights marketplace,
(iii) advertising and customer content, and
(iv) customer communication.

We are working on a plugin for browsers to help enforce each person's preferences and relationship with certain brands as defined in the consumer App.

No Cardano mention on website

"team […] available on the website*. However, ADA / Cardano is not mentioned even once […] I get a feeling that you wanted to do this anyway and now you jumped on the opportunity to finance the developer's work via Project Catalyst" (CA comment)

Profila answer: We have heard Dor on the weekly townhalls talk numerous times about "how to engage entrepreneurs to join Catalyst", and under Fund 5, there is even a challenge "Proposer Outreach", describing "How can we encourage entrepreneurs from outside the Cardano ecosystem to submit proposals to Catalyst in the next two funds?". If we want to get more entrepreneurs to the space, why would you penalize us for joining? (https://cardano.ideascale.com/a/campaign-home/25943).
We are entrepreneurs that fell in love with IOHK technology and are determined to integrate them into our existing solution and build further on top of it!

Data protection laws and compliance

"The proposal doesn't mention the several Data Protection Legislation frameworks that exist worldwide and how they would navigate this and ensure they operate within the legal framework" (CA comment)

Profila answer: As a privacy lawyer with work experience in Europe, Switzerland, and the United States, I am well aware of international privacy legislation and all of its ins-and-outs. First, our App is privacy compliant with GDPR as a best-practice and high standard privacy law. Second, the data subscription process is merely a way for consumer and brands to interact in a more transparent way, with control by the consumer. It is the brand's responsibility to provide clear and complaint information to the consumer about the processing of personal data in the jurisdiction they find themselves, and its for the consumer to accept his. Profila will not act as a public authority/enforcer/privacy agency to control the privacy terms of their relationship, nor will Profila monitor the brand's privacy obligations under local law. It is the brand's responsibility to collect and use personal data within its legal framework.

If you have any specific privacy questions, I would be more than happy to elaborate.

Budget low for a big project which might require multiple funding rounds

"The budget and timeline seem way too low"; "I do believe however that the plan and budget for the task described is not sufficient" and "The only "risk" would be that the funding is currently dependent on 4 rounds of funding from Project Catalyst, however, the amount asked for is reasonable and the team is looking for other avenues of funding as well" and "only thing to keep in mind is that it's a long-term project which might take multiple rounds of funding. (CA comments)

Profila answer: we agree that our aspirations are big, but we also understand that its necessary to start small and test out what works. It is therefore that we started this phased approach to file parts of our solution in steps. We believe that the current budget will allow us to develop these POCs. If it turns out the need additional funds, we will refile a submission explaining the use of the first funds and why we require more.

9. Additional links about Profila and the team

Profila website

https://www.profila.com

Profila LinkedIn

https://www.linkedin.com/company/profilaprivacy

Proposer LinkedIn – Michiel Van Roey (Privacy lawyer and general counsel)

https://www.linkedin.com/in/michielvanroey/

Proposer LinkedIn – Shawn Jensen (CEO)

https://www.linkedin.com/in/shawnj/

Proposer Linkedin - Luke Bragg (head of product)

https://www.linkedin.com/in/lucasbragg/

Proposer Linkedin - Ipek Sahiner (product engineer)

https://www.linkedin.com/in/ipeksahinerschlecht/

Proposer LinkedIn - Mikko Kotila (product and tech advisor)

https://www.linkedin.com/in/mikkokotila/