The Belgian DPA’s investigation follows complaints against the use of personal data in the real-time bidding (RTB) component of programmatic advertising.
The IAB Europe’s Transparency and Consent Framework (TCF) can be seen popping up all over the regional web, asking users to accept (or reject) ad trackers — with the stated aim of helping publishers comply with the EU’s data protection rules.
It was the ad industry standard’s body’s response to a major update to the bloc’s data protection rules, after the General Data Protection Regulation (GDPR) came into application in May 2018 — tightening standards around consent to process personal data and introducing supersized penalties for non-compliance — thereby cranking up the legal risk for the ad tracking industry.
The IAB Europe introduced the TCF in April 2018, saying at the time that it would “help the digital advertising ecosystem comply with obligations under the GDPR and ePrivacy Directive”.
The framework has been widely adopted, including by adtech giant, Google — which integrated it this August.
Beyond Europe, the IAB has also recently been pushing for a version of the same tool to be used for ‘compliance’ with California’s Consumer Privacy Act.
However the findings by the investigatory division of the Belgian data protection agency cast doubt on all that adoption — suggesting the framework is not fit for purpose.
The inspection service of the Belgium DPA makes a number of findings in a report reviewed by TechCrunch — including that the TCF fails to comply with GDPR principles of transparency, fairness and accountability, and also the lawfulness of processing.
It also finds that the TCF does not provide adequate rules for the processing of special category data (e.g. health information, political affiliation, sexual orientation etc) — yet does process that data.
There are further highly embarrassing findings for the IAB Europe, which the inspectorate found not to have appointed a Data Protection Officer, nor to have a register of its own internal data processing activities.
We’ve reached out to the IAB Europe for comment on the inspectorate’s findings.
A series of complaints against RTB have been filed across Europe over the past two years, starting in the UK and Ireland.
Dr Johnny Ryan, who filed the original RTB complaints — and is now a senior fellow at the Irish Council for Civil Liberties — told TechCrunch: “The TCF was an attempt by the tracking industry to put a veneer or quasi-legality over the massive data breach at the heart of the behavioral advertising and tracking industry and the Belgian DPA is now peeling that veneer off and exposing the illegality.”
Ryan has previously described the RTB issues as “the greatest data breach ever recorded”.
Last month he published another hair-raising dossier of evidence on how extensively and troublingly RTB leaks personal data — with findings including that a data broker used RTB to profile people with the aim of influencing the 2019 Polish Parliamentary Election by targeting LGBTQ+ people. Another data broker was found to be profiling and targeting Internet users in Ireland under categories including “Substance abuse”, “Diabetes,” “Chronic Pain” and “Sleep Disorders”.
In a statement, Ravi Naik, the solicitor who worked on the original RTB complaints, had this to say on the Belgian inspectorate’s findings: “These findings are damning and overdue. As the standard setters, the IAB is responsible for breaches of the GDPR. Their supervisory authority has rightly found that the IAB ‘neglects’ the risks to data subjects. The IAB’s responsibility now is to stop these breaches.”
Following the filing of RTB complaints, the UK’s data watchdog, the ICO, issued a warning about behavioural advertising in June 2019 — urging the industry to take note of the need to comply with data protection standards.
However the regulator has failed to follow up with any enforcement action — unless you count multiple mildly worded blog posts. Most recently it paused its (still ongoing) investigation into the issue because of the pandemic.
In another development last year, Ireland’s DPC opened an investigation into Google’s online Ad Exchange — looking into the lawful basis for its processing of personal data. But that investigation is one of scores that remain open on its desk. And the regulator continues to face criticism over the length of time it’s taking to issue decisions on major cross-border GDPR cases pertaining to big tech.
Jef Ausloos, a postdoc researcher in data privacy at the University of Amsterdam — and one of the complainants in the Belgian case — told TechCrunch the move by the DPA puts pressure on other EU regulators to act, calling out what he described as “their complete, deer-in-the-headlights inaction“.
“I think we’ll see more of this in the coming months/year, i.e. other DPAs sick and tired, taking matters into their own hands — instead of waiting on the Irish,” he added.
“We are happy to finally see a data protection authority having the resolved to take on the online advertisement industry at its roots. This may be the first important step in taking down surveillance capitalism,” Ausloos also said in a statement.
There are still several steps to go before the Belgian DPA takes (any) action on the substance of its inspectorate’s report — with a number of steps outstanding in the regulatory process. We’ve reached out to the Belgian DPA for comment. But, per the complainants, the inspectorate’s findings have been forwarded to the Litigation Chamber, and action is expected in early 2021. Which suggests privacy watchers in the EU might finally get to uphold their rights against the ad tracking industry/data industrial complex.
For publishers the message is a need to change how they monetize their content: Rights-respecting alternatives to creepy ads are possible (e.g. contextual ad targeting which does not use personal data). Some publishers have already found the switch to contextual ads to be a good news story. Subscription business models are also available.
Coming considerably closer to Earth is Spanish startup Hearts Radiant, which says it’s in the “longevity tech” business but is taking a far more grounded and practical approach to addressing ageing. In short it believes it’s nailed a formula for helping people live to a ripe old age.
And — here’s the key — to do so healthily.
So its moonshot isn’t to help people get to a biblical 150 or even 120. It’s about supporting seniors to live well, up to a ‘good innings’ like 95, while (hopefully) retaining their independence and vitality through the application of technology that creates a structured and engaging lifestyle routine which works to combat age-related conditions such as frailty and social isolation.
Gently does it
The startup is coming out of stealth today to disclose a first tranche of pre-seed funding and chat to TechCrunch about its dream of supporting seniors to live a more active, fulfilling and independent life.
The €450k pre-seed round, which is led by JME.vc with participation from Kfund, Seedcamp and NextVentures, will be used for research and continued development of its Rosita Longevity digital coach. The app has been in beta testing in a limited form since January — currently only for Android devices, given seniors tend to have their relatives’ hand-me-down smartphone hardware (but iOS is on the roadmap) — offering livestreamed and on-demand video classes like cardio flamenco and age-appropriate yoga for its target 60+ year-olds.
Rosita’s co-founders are husband and wife team, Juan Cartagena (CEO) and Clara Fernández (CCO), along with CTO David Gil. Their premise is that what humans really need, as they age, is guidance and motivation to stay as active as they can, for as long as they can — and that a digital platform is the best way to make personalized, ‘healthy habit’ forming therapy for seniors widely accessible.
“We believe that we have to be a habit engine,” says Cartagena, offering “health longevity” as another descriptor for the scope of what they’re aiming to achieve.
Fernández is drawing directly on her years of experience as CEO of Balneario de Cofrentes, a family business in Valencia, which she describes as a “longevity school” or camp for seniors — and which the website suggests is a combination of spa/hotel, physical therapy/rehabilitation and education center. There she’s been responsible for overseeing activity and education programs tailored to seniors, offering guided exercise and advice on things like disease avoidance and good nutrition.
“Over the last ten years we have developed a very comprehensive strategy on how to educate, how to create habits in the senior community so that they can increase their healthy lifespan,” she explains. “We have a specific methodology. We start with teaching seniors how to manage their current health situation and we progressively start educating them with lifestyle, prevention of the main diseases, and also education about the latest discoveries in the field of science.”
“I realized that the main way to expand this was taking it online,” she adds on the decision to package the program into a digital coaching app — “where a bigger percentage of the senior population could benefit”.
Lifestyle is a key part of the proposition. But they’re most comfortable with the badge of ‘longevity tech’.
“We are trying not to play in fitness for many reasons,” adds Cartagena. “It’s limited in scope. And we are trying to go beyond that — it’s just the starting point [for reducing frailty] and the issues related to that, including the final ‘disease’ which would be dependence.”
Since the premise underlying the Rosita app hinges on the proven health benefits of regular, moderate exercise as a means of combating a range of age-related conditions — such as muscle mass loss and reduced bone density leading to frailty (which in turn can lead to a fall, a broken hip, and a senior who’s suddenly dependent on personal care) — or, beyond that, as a general bolster for mental and brain health — they are squatting on established (rather than moonshotty) science.
Although they do still need to demonstrate that digitally delivered, personalized programs of lifestyle coaching — featuring familiar but still sometimes clunky technologies like AI and chatbots — can actually help reverse frailty (in the first instance) for seniors participating remotely, with no human physiotherapists on hand to help.
Hence some of the funding will go on researching how their bricks-and-mortar ‘longevity school’ program translates to a digital platform. And, more specifically, whether personalised digital coaching for 60+ year olds will yield tangible reductions in frailty (and thus gains in active years) in the same way that in-person group exercises have already been shown to. (One area that certainly merits close study is whether social human contact derived from a purely digital experience vs in-person group therapy makes a difference to treatment outcomes.)
It’s true that no smartphone in the world can transform a bog-standard bathroom into a full on luxury spa. But other elements of the Balneario’s program simply need digitizing and structuring to serve up similar benefits, is the thinking.
The sorts of digital activity programs they’re devising for the app are designed to be fun for seniors as well as beneficial and appropriate for a particular frailty level. Examples of classes currently offered include reduced mobility dance, burpee-free ‘cross fit’, and osteoarthritis-safe karate.
The onboarding process involves an assessment to determine a senior’s frailty level in order that users are offered content at an activity level that’s appropriate for their physical condition.
Long is the road
Cartagena notes they’re working with Dr. José Viña, a professor at the University of Valencia, who is renowned in the longevity field. “He has proven he can revert frailty in the earliest stages by applying a certain methodology to specific muscles with a treatment of exercise-fusion — with some lifestyle habits. Now what has not been proven is whether that is applicable to a remote environment where people do it on their own,” he adds. “And this what we are doing right now. This pre-seed round is basically to take that uncertainty, put that in front of a few thousand [app] users, take that research… and see if in the next 12 months we improve [their frailty level].”
The actual Balneario is closed at the moment, in this health-stricken year of the novel coronavirus, but the plan is to reopen in March 2021 — and then introduce the annual intake to Rosita — garnering ongoing feedback on whether or not it’s steering them toward health-supporting habits.
“It’s all about understanding the customer so well and that’s where the competitive advantage of this company really comes from,” argues Cartagena. “By having 15,000 seniors per year coming to the school, every year we understand the customer very well, their habits, what they do, what they don’t. They come every year so we can ask them what did you do last year?
“That will be for us the way to have a massive focus group — let’s say a sliding window of focus group that we can see for ten days using the product — and we can iterate much faster by seeing not people just through our analytics but people who are using the product in front of us. One hundred or 500 people a day in our resort. And I think that will be a fundamental way in which we can actually build something that people really need and use and care about.”
The current version of the app doesn’t yet include AI-powered personalized coaching. But that’s again where the pre-seed funding comes in. “The initial coach for education and frailty itineraries should be ready in three weeks (together with our iOS app),” says Cartagena. “This solves a pressing problem our users have today.
“The personalized coach (pathologies, followups, context, atomization of exercises, etc) has a lot of logic behind and testing this properly will take more time. We will release that intelligence slowly and we should feel ‘proud’ by Christmas. That will become our Habits Engine. Together with our geroscience research plan, those are the uncertainties to get right with our current funding.”
Targeting chronic pain is another key aim for the app, although he concedes there may be some types of pain they won’t be able to address. The co-founders add that the app is intended to supplement not replace traditional healthcare — pointing out it’s being designed to be more forward-looking; aka that prevention of age-related problems is exactly the strategy to live better for longer.
“Telehealth is more about managing a disease — we’re more about preventing,” adds Fernández. “We’re more about discovering what are the indicators and the tools to make sure that the senior population… understand what it happening to their body, what is going to happen over the next ten years and start to slowly develop those habits so that they can minimize, reduce the evolution, the natural ageing process.”
Cartagena notes they are also working with researchers on developing sensor hardware that could go alongside the app to enhance their ability to predict frailty — suggesting it will allow them to define a wider/more nuanced range of user categories (the first version of the app has three categories but he says they want to be able to offer nine).
Smartphone and sensor hardware combined with AI technology has, for some years now, been enabling a new generation of guided physical therapy apps that seek to offer an alternative to pharmaceutical-based management for chronic pain — such as Kaia Health and Hinge Health, to name two. And of course mindfulness/guided mediation has become a huge app business. While the broader concept of ‘digital health’ has, over the past half decade or so, seen CBT-style therapy programs packaged up to be put on tap in people’s pockets. So there’s nothing inherently strange or exotic about the idea of a longevity coach for seniors.
Albeit, getting the user experience right could well be the biggest challenge. Cartagena says the app’s tone is important — talking in terms of not wanting to be “patronizing” or make seniors feel like Rosita is giving them “homework” — so they really click with the virtual coach and stay engaged.
Fernández too emphasizes the goal is to sustain good habits. Ergo, this is a (gentle) marathon not a sprint.
If they can design a safe and engaging experience that seniors don’t find off-putting, tedious or confusing the potential to expand access to therapies, activities and information that can improve people’s quality of life looks huge. Frailty is also only the team’s first focus. As they develop the product and grow usage they want to be able to support their users to form healthy habits that could help stave off neurodegenerative conditions like dementia, for example. Combating loneliness and social isolation is another goal. So there’s a whole range of health plans they’re hoping Rosita will be able to deliver.
“What we’re doing right now is focused especially on frailty — we’re developing the personalized AI coach on top of that — and what we’re going to do is start adding the layers of all the different health plans that we’re going to be establishing off the longevity coach,” says Fernández. “Nutrition, cognitive stimulation, relaxation and breathing, and on top of that we will put all the prevention strategies — and all the classes that we’re preparing for longevity.
“One of the things that we have tested in the clinic that is very important is to educate the user. Not just on what they need to do today — but on what is happening to their ageing process, what is happening to their metabolism, what is happening to their musculoskeletal system. How and why your body is ageing is fundamental so you can make small decisions. By empowering users through education they can understand and relate to why this specific thing that you’re telling them today is useful in the long run.”
“One of the most successful strategies that we have built is creating this whole course on longevity which is what is happening to your body — what science knows today about the field of longevity,” she adds. “And how you can minimize those symptoms. And those things we’re translating completely into the [app].”
Cartagena also points to the risk of a COVID-19 ‘4th wave’ of deaths that could result from seniors becoming more frail than they otherwise would after being forced into a more sedentary existence as a result of lockdown measures and concerns about their risk of exposure to the coronavirus.
Or, in other words, sitting at home on the sofa might help seniors stay free of virus but if abrupt inactivity risks their vitality that too could cut short a healthy lifespan. So tools to help older people stay active are looking more important than ever. And to that end he says the app will remain free throughout the pandemic — envisaging that could stretch into 2022.
The plan for the business model is b2c, likely focused on selling premium content — such as connecting users directly with a therapist to chat through their progress. In the meanwhile they’re relying on VC to get their digital “motivation engine” to market.
Right now they have 5,000 “pre-registrations” for the app and 1,000 seniors actively testing the product (all aged 60 to 80, in Spain). They’ve also just pushed out an update, moving the software out of the ‘early access’ phase — as they progress toward launching their “personalized AI coach for longevity.”
And while Rosita’s coaching is currently only available in Spanish — with the team having recorded “hundreds” of videos so far for different levels and chronic pathologies — the aim is to scale up in Europe (and perhaps beyond), starting with the U.K. market. Which makes English the next natural language for them to build out content.
Today, a startup called Engageli is coming out of stealth with a service that it believes fills that need. A video conferencing tool designed from the ground up more as a digital learning platform, with its own unique take on virtual classrooms, Engageli is aiming first at higher education, and it is launching with $14.5 million in seed funding from a Benchmark partner and others.
If that sounds like a large seed round for a startup that is still only in pilot mode (you can contact the company by email to apply to join the pilot), it might be due in part to who is behind Engageli.
The startup is co-founded by Dan Avida, Serge Plotkin, Daphne Koller and Jamie Nacht Farrell. Avida is a general partner at Opus Capital who in the past co-founded (and sold, to NetApp) an enterprise startup called Decru with Plotkin, who himself is a Stanford emeritus professor. Koller is one of the co-founders of Coursera and also an adjunct professor at Stanford. And Farrell is a former executive from another pair of major online learning companies, Trilogy and 2U.
Avida and Koller, as it happens, are also married, and it was observing their kids in the last school year — when they were both in high school (the oldest is now in her first year at UC Berkeley) — that spurred them to start Engageli.
“The idea for this started in March when our two daughters found themselves in ‘Zoom School.’ One of them watched a lot of Netflix, and the other, well, she really improved her high scores in a lot of games,” he said wryly.
The problem, as he and Koller saw it, was that the format didn’t do a good enough job of connecting with individual students, checking in with them to make sure they were paying attention, understanding, and actually interested in what was being taught.
“The reason teachers and schools are using conferencing systems is because that was what was out there,” he said. But, based on the team’s collective experiences across past e-learning efforts at places like Coursera — which built infrastructure to run university courses for mass audiences online — and Trilogy and 2U (which are now one company that covers both online learning for universities and boot camps), “we thought we could build a better system from the ground up.”
Even though the idea was inspired by what the pair saw playing out with their high school-attending children, Engageli made the decision to focus first on higher education because that was where it was getting the most interest from would-be customers to pilot the service. But also, Avida believes that because higher ed not already has a big market for remote learning, it represents a more significant opportunity.
“K-12 schools will eventually go back to normal,” he said, “but we’re of the opinion that higher education will be a blend with more and more online learning,” one of the reasons also for the founding of the likes of Coursera, Trilogy and 2U. “Younger kids need face-to-face contact, but in college, many students are now juggling work, family and studying, and online can be much more convenient.”
Also there is a very practical selling point to providing better tools to university classrooms: “People pay those tuitions to have access to professors and other students, and this is a way to provide that in a remote world,” he said.
As it appears now, Engageli lets teachers build and run both synchronous (live) and asynchronous (recorded) lessons, giving students and teachers the option to catch up or replace a live lesson if necessary.
The startup’s idea is also to make it as easy to integrate into existing workflows as possible: no need to install special desktop or mobile apps, as the platform works in all major browsers, and Avida notes that it’s also designed to integrate with the software systems that many universities are already using to organise their educational content and track students’ progress. (Making the barrier to entry low is not a bad idea also considering that many institutions are already using other products, making them more entrenched and increasing the challenges of getting them to migrate to something else.)
But perhaps Engageli’s most unique feature is how it views the virtual classroom.
The platform lets teachers create “tables” where students sit together in smaller groups, where they can work together. With tables, the idea is that either an instructor — or in the case of large classes as you might get with university seminars, teaching assistants assigned to tables — can engage with students in a more personalised way.
When a class is delivered asynchronously (that is, recorded), it means that students sitting at a table can still partly be involved in a “live” experience where they can talk about the work with others in their groups. The tables are also opened up before a class starts, and students can go from one to the other to chat with others before the class begins.
On top of the tools that Engageli has built to record and consume lessons, it’s also building a set of analytics that lets professors (or their assistants) monitor how well audio and video and working both for themselves as we as for their audience, and also collect other kinds of “engagement” information, which could come in the form of getting people to ask or answer questions or take polls and other interactive media.
Together, these features create better feedback to make sure that everyone is getting as much out of the remote experience as possible.
Education has not always been one of the buzziest areas in the world of startups — it’s been something of a boring cousin to more headline-grabbing segments like social media, or those taking on giants like Amazon and Google.
But the pandemic has thrown a spotlight on the opportunities in the field, both to fill a sudden surge of demand for remote learning tools, and to create more innovative approaches to doing so, as Engageli is doing here.
Just yesterday, Kahoot — a platform for building and using gamified learning apps — raised $215 million from SoftBank; and other recent rounds have included Outschool (which raised $45 million and is now profitable), Homer (raised $50 million from an impressive group of strategic backers), Unacademy (raised $150 million) and the Indian juggernaut Byju’s (most recently picking up $500 million from Silver Lake).
On top of the recent spotlight on education, it’s also been interesting to see the proliferation of startups that are also coming out of the woodwork to provide new takes on videoconferencing.
Last week, a startup called Headroom — also started by already-successful entrepreneurs — launched with an AI-driven alternative to Zoom and the rest providing not just automatic transcriptions of conversations, but automatically generated highlights and insights into how engaging your webinars and other video content really was.
Apps like Headroom and Engageli are just the tip of the iceberg, with other innovative approaches also stepping out and raising significant funding. The big question will be whether they will get much attention and time from would-be customers who are already “happy enough” with what they already use.
But in a tech world that thrives on the concept of disruption and companies creating businesses out of simply being better approaches to entrenched markets, it’s a bet worth making.
“Dan, Serge and Daphne have repeatedly built fast-growing, extremely successful companies. I am so fortunate to be working with them again,” said Alex Balkanski, a partner at Benchmark who is investing individually, in a statement. “Investing in a company linked to education is incredibly important to me on a personal level, and Engageli has the potential to enable a truly transformative learning experience.”
Updated to clarify that Balkanski is investing privately, not through Benchmark.