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Processing data is already a liability. The compute power isn't free. The storage isn't free. The engineering time isn't free. It's just that it produces more value than what it costs or people wouldn't do it.

I believe this project was in response to the EU's Digital Services Act ("DSA"). Now IANAL but it always struck me as ambiguous as to what constitutes "personalization". Like, can your data be used to train an ML system? What if identity is scrubbed from that data? What if it's aggregated in some way so there's no individual user activity at all?

It also raises questions about every aspect of product behavior. Let's say you see a video post on your news feed. You get shown a snippet of the comments. Usually this is from friends but maybe it's just a comment that we thought might interest you. Is that personalization? What about a shared link where a snippet is shown from the article?

Also, the DSA seems to apply to on-site contextual personalization. What about off-site? Is that covered? Is there a separate law for that? Can I use derived demographics from a display ad pixel but not what pages you've liked and what groups you participate in on site?

Can I use your friends' activity to customize your experience?

The list goes on.

I'm a fan of clear legislation. If the goal is, for example, to allow opt out of personalized ads based on contextual on-site behaviour, we should enumerate what applications (eg feed ads) are covered and what information you're allowed to use if someone opts out.




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