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Access to Facebook Pixel data

Request to:
Facebook Data Requests
Law used:
Data Protection Act, 1988 IE
Status of this request:
Request awaits classification
Summary of Request
Dear Facebook, I wish to get access to any information Facebook has on the presence of any identifier associated directly or not with my account within particular Facebook pixel audiences. In essence, this would allow me to deduce how marketers might be able to target me with Facebook-based advertisements.

Messages in this request

From << Name Not Public >>
Subject Access to Facebook Pixel data [#57]
Date Dec. 15, 2016, 11:03 a.m.
To Facebook Data Requests
Status Awaiting response

Dear Facebook, I wish to get access to any information Facebook has on the presence of any identifier associated directly or not with my account within particular Facebook pixel audiences. In essence, this would allow me to deduce how marketers might be able to target me with Facebook-based advertisements.
[... Show complete request text] Kind Regards, << Name Not Public >>
  1. 8 months agoDec. 15, 2016, 11:03 a.m.: << Name Not Public >> sent a message to Facebook Data Requests.
From Facebook – Facebook Data Requests
Subject Re: Access to Facebook Pixel data [#57]
Date Dec. 15, 2016, 11:06 a.m.
Status Awaiting response

Hi, Thank you for contacting us to make a data request. You can access your data on Facebook in several ways. First, you can access your personal data from your account (ex: on your timeline or in your activity log). Second, we provide a tool that allows you to download a copy of your account data. This tool is available from the Account Settings page. For more information, please visit: https://www.facebook.com/help/4051835... To learn more about your data on Facebook, please read the Data Policy: https://www.facebook.com/about/privacy/ This policy describes: • Categories of data being processed by Facebook • Personal data that Facebook receives from Facebook members • Sources of this info, if known • Reasons for processing this data • Recipients or categories of recipients to whom Facebook members’ personal data may be disclosed To access the self-service download tool from your account: 1. Click the account menu at the top right of any Facebook page 2. Choose Account Settings 3. Click the link at the bottom of the page "Download a copy of your Facebook data" Note: We have several measures in place to ensure the security of your information, and will require you to confirm your identity to complete the process and access your account information. Your downloaded file may contain sensitive information. You should keep it secure and take precautions when storing, sending or uploading it to any other services. You can also access the personal data held in your timeline any time by logging into Facebook. If you can’t access your account or don’t have an account, please follow the link below to complete a form and request your data: https://www.facebook.com/help/contact... You may be required to provide additional information to authenticate your identity. Thanks, The Facebook Data Access Request Team
  1. 8 months agoDec. 15, 2016, 11:06 a.m.: Received an email from Facebook Data Requests.
From Facebook – Facebook Data Requests
Subject Re: Access to Facebook Pixel data [#57]
Date Dec. 15, 2016, 1:27 p.m.
Status Awaiting response

Hi, It looks like you're asking a question that we can't support from here, but that doesn't mean we can't help you. If you're trying to report something, please follow the directions in the link below: https://www.facebook.com/help/1814959... If you're looking for information about Facebook features and how to use them, please visit the Help Center: https://www.facebook.com/help/?ref=CR Thanks, Blair Privacy Operations Facebook -----Original Message---- From: << Name removed >> << Name removed >> <<email address>> To: Facebook Subject: Access to Facebook Pixel data [#57] Dear Facebook, I wish to get access to any information Facebook has on the presence of any identifier associated directly or not with my account within particular Facebook pixel audiences. In essence, this would allow me to deduce how marketers might be able to target me with Facebook-based advertisements. << Name removed >> << Name removed >> <<email address>> Post Address: << Name removed >> << Name removed >> << Address removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically. -----End Original Message-----
  1. 8 months agoDec. 15, 2016, 1:27 p.m.: Received an email from Facebook Data Requests.
From << Name Not Public >>
Subject Re: Re: Access to Facebook Pixel data [#57]
Date Dec. 15, 2016, 1:31 p.m.
To Facebook Data Requests

Hi Blair at Facebook Data Requests, Your colleague Alex at Safe Harbor/Privacy Shield compliance sent me your way, repeatedly. You can find for instance an example of his replies here: http://www.personaldata.io/request/da... From my point of view, the constant redirection (and the automated replies) are pure annoyance, and none of my concern. I trust that you will resolve this internally to Facebook, and get me a response through this channel. Sincerely yours << Name removed >> << Name removed >> Request Number: 57 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 8 months agoDec. 15, 2016, 1:31 p.m.: << Name Not Public >> sent a message to Facebook Data Requests.
From << Name Not Public >>
Subject Re: Re: Re: Access to Facebook Pixel data [#57]
Date Jan. 13, 2017, 9:42 a.m.
To Facebook Data Requests

Dear Blair, This is to insist that I still have not received a response to my request. Sincerely yours << Name removed >> << Name removed >> Request Number: 57 Reply To: <<email address>> Post Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 7 months agoJan. 13, 2017, 9:42 a.m.: << Name Not Public >> sent a message to Facebook Data Requests.
On Feb. 1, 2017, 10:42 p.m., Paul-Olivier Dehaye wrote:

I have now filed a direct complaint with the Irish DPC regarding this matter.

On Feb. 1, 2017, 10:50 p.m., Paul-Olivier Dehaye wrote:

I have now filed a direct Safe Harbor complaint with TRUSTe regarding this matter (#49138)

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From Facebook – Facebook Data Requests
Subject Re: Access to Facebook Pixel data [#57]
Date Feb. 7, 2017, 2:45 p.m.
Status Awaiting response

Dear Mr << Name removed >> We understand that you are interested in learning how pixels may be influencing the ads that you see on Facebook. 1. How do Facebook pixels work? You can find a detailed overview of how our advertising products work at: https://www.facebook.com/ads/about/?e.... You can also find technical details about our pixels here: https://www.facebook.com/business/hel... In short, advertisers use Facebook technologies, such as the Facebook pixel, to help them show adverts to people who have visited their website or used their mobile app. Business and organisations can try to reach people who have done things such as: - Viewed a web page that uses a Facebook pixel - Downloaded their mobile app - Made a purchase (or simply added a product to a shopping cart) 2. What ads am I receiving as a result of pixels? Facebook’s ad preferences tool explains the factors that influence the ads that you see and allows you to control the sorts of ads you see on Facebook. Among other things, the ad preference tool specifically identifies those advertisers whose adverts you may be seeing because you have visited a website or app with Facebook technology (including pixels) installed. You can access the ad preferences tool here: https://www.facebook.com/ads/preferences If you scroll down to the “Advertisers you’ve interacted with” tab, and click on “advertisers whose website or app you’ve visited” you will be able to see which advertisers may be targeting you as a result of you interacting with a website or app containing a pixel. We trust this this satisfies your request. If you require further clarification, please do not hesitate to reach out to us again. For your information, you are also entitled to contact the Office of the Irish Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, Ireland with any concerns you may have. On a related note, we have been notified by Truste that you have referred a complaint to them regarding this matter under the Swiss/US Safe Harbor scheme.This complaint relates to matters in relation to which Facebook Ireland Limited ("FB-I") is the data controller and does not involve any data transfers from Switzerland to the United States. Irish law and jurisdiction therefore applies and not the CH/US Safe Harbor framework. Nonetheless, as a matter of courtesy, we will forward this response to Truste for their information, on the basis that it resolves the matter. Yours sincerely, Alex Privacy Operations Facebook -----Original Message---- From: << Name removed >> << Name removed >> <<email address>> To: Facebook Subject: Re: Re: Re: Access to Facebook Pixel data [#57] Dear Blair, This is to insist that I still have not received a response to my request. Sincerely yours << Name removed >> << Name removed >> Request Number: 57 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically. -----End Original Message-----
  1. 6 months, 1 week agoFeb. 7, 2017, 2:45 p.m.: Received an email from Facebook Data Requests.
From << Name Not Public >>
Subject Re: Re: Access to Facebook Pixel data [#57]
Date Feb. 13, 2017, 11:23 a.m.
To Facebook Data Requests

Dear Alex, You responded to my request with "We understand that you are interested in learning how pixels may be influencing the ads that you see on Facebook." I am interested in this, yes, but my original request was different: "I wish to get access to any information Facebook has on the presence of any identifier associated directly or not with my account within particular Facebook pixel audiences. In essence, this would allow me to deduce how marketers might be able to target me with Facebook-based advertisements." Indeed, I wish to get access to the data itself in order to make inferences myself, not to Facebook's presentation of this data. You also state: "Among other things, the ad preference tool specifically identifies those advertisers whose adverts you may be seeing because you have visited a website or app with Facebook technology (including pixels) installed." This is not a response to my question. Again, I wish to get access to the data itself, not to Facebook's presentation of this data. Indeed, when I go to that part of the site, I get the response "There are no advertisers in this category right now". However, when I go in my settings to the question "Ads based on my use of websites and apps" -> "Can you see online interest-based ads from Facebook?" -> "Show online interest-based ads" and switch that from Off to On, I immediately see, without any other action, the site Buzzfeed Australia added to that list of websites. My understanding is thus that data about my visit to the site Buzzfeed Australia has been collected (possibly through a pixel), but Facebook choses not to present that fact to me unless I authorize it to use that data to customize ads. However, the data is collected regardless of the permissions given to Facebook on reusing that data, and it is well within my access right to get data on that fact directly. In addition, even if I authorize Facebook to customize ad display based on the sites visited, I am only given what I must presume to be a partial list of sites visited and where I have been tracked by a Pixel (maybe a temporal scope is added). I must thus reiterate my request for the Pixel data itself, not Facebook's partial presentation of this data. Sincerely yours << Name removed >> << Name removed >> Request Number: 57 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 6 months agoFeb. 13, 2017, 11:23 a.m.: << Name Not Public >> sent a message to Facebook Data Requests.
On Feb. 13, 2017, 2:17 p.m., Paul-Olivier Dehaye wrote:

Offered essentially the same response to TRUSTe #49138, with additional arguments about TRUSTe jurisidiction.

On Feb. 18, 2017, 10:08 p.m., Paul-Olivier Dehaye wrote:

Got response from the Irish DPC that in light of the fact that there was some progress, I should just ... Read all

On March 14, 2017, 10:59 a.m., Paul-Olivier Dehaye wrote:

I have now filed a request with TRUSTe for a full-on escalation.

On March 14, 2017, 11 a.m., Paul-Olivier Dehaye wrote:

I have now again asked the Irish DPC to consider this issue.

Write a comment
From Facebook – Facebook Data Requests
Subject Re: Access to Facebook Pixel data [#57]
Date March 31, 2017, 5:38 p.m.

Dear Mr << Name removed >> Thank you for your email. We are sorry if you feel our previous response did not fully answer your questions. While we are sincerely trying to give you the information you are looking for, it is true that we are having a little difficulty in understand precisely what it is you would like us to provide. As we have explained to you previously, under Irish and EU law, the right of access allows people to request a copy of their personal data and to clarify a number of points about how their data is being used. For example, people can ask a controller to clarify the purposes of the processing, the categories of data that are being processed and the recipients or categories of recipients of the data. However, the right of access does not give people a right to raise general queries about the ways in which a company processes personal data. As a result, to the extent your questions relate to the technical operation of Facebook pixel, that type of information provision is not envisaged by section 4 of the Irish Data Protection Acts / Article 10 of Directive 95/46/EC. That said, we strive to be open about how our products work and appreciate your interest in our platform. We note your emphasis that your request is for "the pixel data itself". If this means you would like to be provided with any data that Facebook may have received as a result of the use of the Facebook pixel on third party websites which you have visited, it is not technically feasible for us to provide such information to you. It therefore falls outside of the scope of section 4 of the Irish Data Protection Acts. In our previous response to you we sought to give you information which we thought you might find useful regarding how Facebook pixels work. What we also tried to explain is that, in order to promote transparency and inform our users, we have carefully architected a system which enables users to find out which adverts they currently have the potential to see as a result of websites or apps they've used. The list you refer to in your email - which any user can access by selecting "Yes" to the option in their advert settings to see "Adverts based on your use of websites and apps" - provides a complete list of those advertisers. The system as architected does not capture information regarding adverts you may previously have had the potential to see as a result of websites or apps you may have used, and that information is not stored in readily accessible form (and so, again, falls outside the scope of section 4 of the Irish Data Protection Acts). The information we make available in this way - and corresponding ability for users to elect not to see adverts based on their use of third party websites and apps - is provided to our users as a matter of best practice, in the interests of transparency, and in order to empower our users. Regarding the separate matter of your continued reference of requests to Truste, as we have explained to you previously, Facebook Ireland Limited is the data controller regarding your use of the Facebook Service. As a result it is the entity which is responsible for responding to questions such as this. Your query is not directed to issues regarding data transfers to Facebook, Inc.; nor is this a matter that Facebook, Inc. would be in a position to assist you with, given it is not the data controller for the Facebook Service outside of the United States and Canada. Therefore, this is not a case which has any connection to the CH/US Safe Harbor scheme; and, correspondingly, Truste. As we have also explained previously, should you have any continuing concerns about this matter, you are entitled to contact Facebook Ireland's regulator with exclusive jurisdiction over issues such as this: the Office of the Irish Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, Ireland. We will forward this response to both the Irish Data Protection Commissioner and Truste, for their information. Yours sincerely, Alex Privacy Operations Facebook -----Original Message---- From: << Name removed >> << Name removed >> <<email address>> To: Facebook Subject: Re: Re: Access to Facebook Pixel data [#57] Dear Alex, You responded to my request with "We understand that you are interested in learning how pixels may be influencing the ads that you see on Facebook." I am interested in this, yes, but my original request was different: "I wish to get access to any information Facebook has on the presence of any identifier associated directly or not with my account within particular Facebook pixel audiences. In essence, this would allow me to deduce how marketers might be able to target me with Facebook-based advertisements." Indeed, I wish to get access to the data itself in order to make inferences myself, not to Facebook's presentation of this data. You also state: "Among other things, the ad preference tool specifically identifies those advertisers whose adverts you may be seeing because you have visited a website or app with Facebook technology (including pixels) installed." This is not a response to my question. Again, I wish to get access to the data itself, not to Facebook's presentation of this data. Indeed, when I go to that part of the site, I get the response "There are no advertisers in this category right now". However, when I go in my settings to the question "Ads based on my use of websites and apps" -> "Can you see online interest-based ads from Facebook?" -> "Show online interest-based ads" and switch that from Off to On, I immediately see, without any other action, the site Buzzfeed Australia added to that list of websites. My understanding is thus that data about my visit to the site Buzzfeed Australia has been collected (possibly through a pixel), but Facebook choses not to present that fact to me unless I authorize it to use that data to customize ads. However, the data is collected regardless of the permissions given to Facebook on reusing that data, and it is well within my access right to get data on that fact directly. In addition, even if I authorize Facebook to customize ad display based on the sites visited, I am only given what I must presume to be a partial list of sites visited and where I have been tracked by a Pixel (maybe a temporal scope is added). I must thus reiterate my request for the Pixel data itself, not Facebook's partial presentation of this data. Sincerely yours << Name removed >> << Name removed >> Request Number: 57 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically. -----End Original Message-----
  1. 4 months, 2 weeks agoMarch 31, 2017, 5:38 p.m.: Received an email from Facebook Data Requests.
From << Name Not Public >>
Subject Re: Re: Access to Facebook Pixel data [#57]
Date April 10, 2017, 12:38 p.m.
To Facebook Data Requests

Dear Facebook, I reiterate that I am merely asking for the underlying data (as you are required by law), and not a view you have provided over this data (which you say is "a matter of best practice, in the interests of transparency, and in order to empower our users"). It seems, in parts of your response, that you have understood this distinction by now. I still think however that the view you provide falls short in many ways of your legal obligations. You refer to carefully engineered systems, but what you write about those systems shows that they are deficient in their very design. You implicitly acknowledge that the data I am seeking is stored on your servers, but argue that this data is out of reach under the Access clause. If you allow me to collate your sentences together to get to the core of your argument , you say: 1) "we have carefully architected a system which enables users to find out which adverts they *currently* have the *potential* to see as a result of websites or apps they've used" (emphasis mine) 2) "it is not technically feasible for us to provide such information to you. It therefore falls outside of the scope of section 4 of the Irish Data Protection Acts." This is not how the law works. Your system should be designed in such a way to enable access to data you store. The Access right can be limited due to technical considerations, but always by balancing this right against rights and fundamental freedoms of the data subject(s). Your argument leaves little room for further discussion. For this reason I will now ask TRUSTe to escalate the matter. Request Number: 57 Reply To: <<email address>> Post Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 4 months, 1 week agoApril 10, 2017, 12:38 p.m.: << Name Not Public >> sent a message to Facebook Data Requests.
On April 10, 2017, 12:40 p.m., Paul-Olivier Dehaye wrote:

I have now insisted with TRUSTe that I really wanted an arbitration procedure to be opened up.

Write a comment
From Facebook – Facebook Data Requests
Subject Re: Access to Facebook Pixel data [#57]
Date May 2, 2017, 7:59 p.m.

Dear Mr << Name removed >> Thank you for your further inquiry in this matter. Where the provision of information would involve disproportionate effort on the part of a data controller, there is an exemption from the general right of access for data subjects (see section 4(9)(a) of the Irish Data Protection Acts 1988 and 2003 and Recital 40 of Directive 95/46/EC). As we have explained to you previously, our systems enable us to inform you which adverts you currently have the potential to see as a result of websites or apps you have used. We also provide you with a wealth of other information and controls over advertising on Facebook. As examples, we have previously referred you to the following links: https://www.facebook.com/about/ads https://www.facebook.com/settings?tab... https://www.facebook.com/ads/preferences https://www.facebook.com/business/hel... The additional data you are seeking is not retained in a form that can feasibly be accessed on a per user level and (particularly once the above factors are taken into account) we consider it would require disproportionate effort to locate it and provide it to you. We hope you found this response helpful, however please let us know if we can be of further assistance. Yours sincerely, Alex Privacy Operations Facebook Ireland -----Original Message---- From: << Name removed >> << Name removed >> <<email address>> To: Facebook Subject: Re: Re: Access to Facebook Pixel data [#57] Dear Facebook, I reiterate that I am merely asking for the underlying data (as you are required by law), and not a view you have provided over this data (which you say is "a matter of best practice, in the interests of transparency, and in order to empower our users"). It seems, in parts of your response, that you have understood this distinction by now. I still think however that the view you provide falls short in many ways of your legal obligations. You refer to carefully engineered systems, but what you write about those systems shows that they are deficient in their very design. You implicitly acknowledge that the data I am seeking is stored on your servers, but argue that this data is out of reach under the Access clause. If you allow me to collate your sentences together to get to the core of your argument , you say: 1) "we have carefully architected a system which enables users to find out which adverts they *currently* have the *potential* to see as a result of websites or apps they've used" (emphasis mine) 2) "it is not technically feasible for us to provide such information to you. It therefore falls outside of the scope of section 4 of the Irish Data Protection Acts." This is not how the law works. Your system should be designed in such a way to enable access to data you store. The Access right can be limited due to technical considerations, but always by balancing this right against rights and fundamental freedoms of the data subject(s). Your argument leaves little room for further discussion. For this reason I will now ask TRUSTe to escalate the matter. Request Number: 57 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically. -----End Original Message-----
  1. 3 months, 2 weeks agoMay 2, 2017, 7:59 p.m.: Received an email from Facebook Data Requests.