Online Browsing: Can, Should, and May Companies Combine Online and Offline Data to Learn About You?

by MICHELLE GERONIMO

Can, may, and should companies be allowed to combine offline and online data for purposes of targeted advertising and analytics under U.S. privacy law? This article will address this question in three parts. The first section will describe the “can” — how companies combine offline and online data, the types of data combined, and how such data is collected. The second section will address the “should” — benefits to companies and consumers, existing privacy harms, and possible scenarios of harm. Finally, the third section will discuss the “may” — legal requirements that apply under current U.S. law, and any additional protections that may be necessary.

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