The FTC has taken the position that, under particular conditions, IP addresses can make up personally identifiable information. Especially in the FTC’s 2013 changes to the Kids’s Online Privacy and Protection Act, the FTC defined “private information” to contain “constant identifiers,” such as IP addresses, but only when such constant identifiers are accustomed to track users over time and across sites or online services.

An IP address is an address for a device online, which exists to enable information to be delivered to that computer or apparatus or a computer. A person’s IP address can shift often and one IP address can have several users that are unique. For instance, an internet service provider may have a block of . IP addresses and 20,000 customers 10,000 Not all customers are connected at the exact same time, empowering the internet service provider to put an IP address to device or a computer when it connects, and reassign that same IP address to an alternate computer or device when the first computer or device disconnects. These are usually known as dynamic IP addresses. Thus, one IP address may be assigned to apparatus or multiple computers possessed by different users over any number of time.

Furthermore, social media firms like Twitter or Facebook may have the capacity to recognize individuals with whom they have an established relationship via IP addresses. Additionally, some service providers use just static IP addresses, which can offer added info and are exceptional to an user, including an user’s place. In any scenario where the IP address can be joined with other information to recognize a particular user, the IP address would probably be addressed as personally identifiable information under both the present definition and the evaluation Ms. Rich said.

Ms. Rich followed up her conversation with a blog post on the FTC’s site. Her place focused not only on IP addresses, but on the use of all constant identifiers, especially in the area of cross apparatus tracking, and sought to clarify her remarks at the NAI Summit. Especially, she said if you’re gathering constant identifiers, be cautious about making blanket statements to individuals assuring them that you do’t gather any private information is anonymous. And as you evaluate the threats to the data you gather, contemplate all your data, not just the data associated with a person ’s name or email address.” See “Keeping Up with the Online Advertising Industry, April 21, 2016 ”.

Cross apparatus tracking and on-Line tracking has been, and will continue to be a place that is rapid evolving. Ms. Rich’s opinions and recent blog post do’t justify any immediate changes but function as a friendly reminder that site publishers and ad servers should always evaluate what information they’re gathering and how they’re using it, and should provide notice and choice to consumers involving interestestablished marketing and tracking over time and across sites.