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ConsumerFi Podcast: The Benefits of with CEO Andrea Amico

June 1, 2022

Episode 27


Joel is joined by founder and CEO, Andrea Amico, to break down their niche as the first and only technology company focused on identifying and resolving data privacy issues across the automotive ecosystem, how our cars store more private information than most of us can possibly imagine, and how regulatory action and litigation are making services like this more necessary than ever.

Check out their consumer level resources here and their free legal resources here.

you can meet Andea and Joel in person at the National Automotive Finance Association’s 25th Annual Non-Prime Auto Financing Conference this August 30 – September 1, 2021 in Plano, Texas. Register today!

ConsumerFi is presented by Nortridge Software: Loan Software That Accelerates Change.

And special thanks to The National Automotive Finance Association: The only trade association exclusively serving the nonprime auto finance industry.


You’re listening to the consumer FY podcast powered by Northbridge loan software that accelerates dream

[00:00:20] Everybody. Welcome to the podcast. I’m pleased today to be joined by Andrea Mico of privacy for Andrea. Welcome to the podcast.

[00:00:29]Andrea Amico: [00:00:29] Thank you so much, Jim, it’s a pleasure to be here.

[00:00:31] Joel Kennedy: [00:00:31] So Andrea and I met, I want to cut a couple of weeks ago. We, we kind of went a little bit through this privacy for cars thing.

[00:00:38] And I got to tell you that Andrea, from your standpoint, like I want to get into the problem that you’re solving, but there’s just something about the utility of this. To lenders, to recovery folks just really covering your bases and making sure that from a PII standpoint, and as these cars get more and more intelligent that we are [00:01:00] doing the right thing as stewards of the vehicle during certain times, To protect that information and to protect, ultimately protect the consumer.

[00:01:07] And that’s, I mean, I, I should be asking that of you. I went ahead and stole your thunder, but Andrea, why don’t you tell us a little bit about that? The problem that you guys are solving and maybe a little background on the company, uh,

[00:01:19] Andrea Amico: [00:01:19] feel free to steal my tongue or any time. That’s absolutely fine, but yeah, so privacy for cars is as far as they know, I think the first and the only company.

[00:01:30] Focused on creating solutions around the protection of personal information captured by cars, cars capture a lot of personal information. If you have any doubts, just go and find the privacy policy of whichever automaker of the car that you’re driving today and take a read. Um, and you know, sometimes people say cars are like smartphones and wheels, and I would say, you know, cars are.

[00:01:55] Computers on wheels. The reality is that that’s all of this is vastly redacted. [00:02:00] Uh, cars have. Uh, you know, if you sync your phone, people don’t realize this, right? They think if I unhooked my phone, then I’m done. Right. There’s nothing left. That’s not true. When you collect your phone via Bluetooth or via USB nowadays, or wifi, that car will download a meanie copy of your phone.

[00:02:19] Inside it’s electronic guts. You will find the contacts. You will find the text messages, the call logs, the unique identifiers, a bunch of other stuff from that phone. Um, so this is true for cars that were made like 10 years ago, right? When Bluetooth came out, if you have navigation, uh, your home address, where you’ve been all your, you know, all your whereabouts are detailed in logged.

[00:02:42] Inside the car, um, by the way, your car may have your garage. Well, which is not uncommon with vehicles with home addresses. So you can see how that would be a major concern. Um, and there’s a lot of other stuff like with newer vehicles, you can find. I mean, we’ve seen calendar entries. [00:03:00] We have seen, you know, what photos you’re taking with the phone.

[00:03:03] There’s, there’s a lot of that in your car. What files are you downloading on your phone? There’s a lot of that on your phone, on your, on your car. Uh, your nowadays cars have your, you know, are attached to actually a profile of how you drive. They’re attached to a profile of your payment information, because maybe you subscribe to services through your car.

[00:03:22] So there’s, there’s a lot of information that. Financial institutions, which is really who we’re talking about today should really be concerned about because that’s clearly. Personal information that is regulated under a number of legislations, both on the federal and the state level. And so what do we do?

[00:03:41] We, um, we help those companies and, you know, we have a lot of fantastic financial comes. They have partnered with us very early on, um, you know, us bank and bank of America, Wells Fargo, there’s many others, right. That they decided to set up a process. When they sell a vehicle at the auction, those vehicles [00:04:00] are typically repossessed vehicles, as you can imagine, right?

[00:04:03] Where the auction will go in, remove the data, using our platform and technology. And what we do is that we publish on RYMS, which has, you know, is the central repository of all the data for all the auctions. We publish a record that says, uh, Juul deleted the personal information. Well, we won’t say Joel, but it, it say for this vein.

[00:04:25] A person has the lady, the personal information from this vehicle at this time, this is exactly what happened. Uh, we actually produce a certificate and we back it, we back the certification with a warranty, with a financial warranty. Um, and so that’s what, again, many banks agree on mental financial institutions are using are their official repository of records to show that not only they have a policy.

[00:04:50] But they’ll leave it in greeted every days. And they have the records to the shop. I’m sure you know, us, everything in regulation and compliance, having a policy is a good start. [00:05:00] But unless you have the receipts, you have a lot of exposure, right? So that’s the gap we’re trying to fill is to provide financial institutions with the receipts to prove they’re doing the right

[00:05:09] Joel Kennedy: [00:05:09] thing.

[00:05:11] Let’s say, hypothetically, I recovered a vehicle. I sent it to auction and it’s one of these like random instances where the customer. Does something within a window, like a state window where they can, they can reclaim the car. Okay. So they, they made a payment in full, they paid the full balance. I’ve already deleted all this personal information off of the car to that consumer

[00:05:35] Andrea Amico: [00:05:35] that’s.

[00:05:36] Joel Kennedy: [00:05:36] Is that an issue? I mean, do they, do they get in their car and say, Oh man, you, you, you blew out all my, my, my store to dresses. Like, I mean, is that a problem or is that, is it a, nothing like, have you had any, any interactions with that kind of, and I assume that happens never, but, so

[00:05:53] Andrea Amico: [00:05:53] I was trying to pick it apart.

[00:05:54] Yeah. Yeah. So we see financial institutions having two types of. Policies, uh, when, when they have one, [00:06:00] right? Th the good ones do have a policy. So, uh, well, they do, some of them will decide we’re going to wait until after the period in which the vehicle is redeemable to remove the personal information.

[00:06:12] Others say no, no, no, no, no. We have a fiduciary duty to protect this information. And as soon as we get our hands on the vehicle, we’re going to remove that information because the earlier you do it in the process, the less likely that somebody will actually go be able to access it. That’s right. Because

[00:06:27] Joel Kennedy: [00:06:27] maybe people, people dealing with the vehicle transport, uh, repair, et cetera,

[00:06:32] Andrea Amico: [00:06:32] that potential buyers, right.

[00:06:34] They may go to one option and go and look for vehicles and, you know, maybe they stumbled upon stuff. Right. And so, and so. Some punished institutions again, are taking the position of. It is. Yes, we’re removing it before a time in which the vehicle we’ll be redeemed, but we’re doing that because we’re, we’re being taken most conservative across the most protective approach towards consumers.

[00:06:58] So is it [00:07:00] possible that somebody is going to complain. That they’re equally as being, you know, has forgotten the home address and now they need to reprogram it. You know, humans are humans. Yes, it’s possible. But is there a liability attached to that? And everybody that we talked to, again, I’m not here to give legal advice, but everybody I talk to is telling me this is not a matter of liability because again, you’re taking the most conservative, most protective view towards the customer.

[00:07:27] Joel Kennedy: [00:07:27] Got it on the, on the, um, on the regulatory side, uh, I mean obviously like P personal information kind of spans a number of different regulations. It probably hits things on different States. Are there certain States or jurisdictions where this is more of an issue? Uh, Than that than

[00:07:51] Andrea Amico: [00:07:51] others. Yeah. Great question.

[00:07:53] So, um, first of all, when we started, I know that you’re leaving California, right? So when we started, uh, last [00:08:00] year, uh, many consignments started, uh, with California because CCPA, California, consumer privacy act had just passed. And, uh, during the, the weight of the law, should, there were a number of comments filed exactly on.

[00:08:16] The equal information in case you didn’t know. Right. So the fact that cars collect personal information and the fact that this person information falls under the bounds, the clear bounds of CCPA was very well established since before the law actually came into effect because of all these comments.

[00:08:32] Right? So again, most, most companies started with acting California and they thought it was mainly a. Privacy law issue. Right? So now you have a privacy law in California. There was one just passing Virginia. I’m sure you heard about that. And you know, there’s a there’s right. There’s other States, a handful of States have privacy laws and there’s too many counts.

[00:08:52] 15 to 20 are trying to pass privacy laws this year. Right. But reality is that. [00:09:00] Uh, this is not a privacy law issue from a financial institution standpoint. The main issue that we talked to our customers, where we were, they start to be concerned about. We really need to do something is because most States have data security laws, and most States have data disposal statutes in most of them have reasonable saboteur security and data breach notices.

[00:09:26] Okay. And. And so now you have a situation in which you have laws that were written about electronic information stored in electronic devices. Clearly the laws were written at the time when people were thinking, you know, that is in a server, in a bank or bank, or, you know, you’re laptop bought insurance agent.

[00:09:46] That’s what people were thinking about with the, the laws. But reality is that electronic records, electronic devices fully applied to today’s vehicles. Uh, definitely all the vehicles we see at the auction, right? Uh, for repossessed [00:10:00] vehicles, I can tell you that, um, almost nine out of 10 that we sequence, we do all this on a regular basis, arrive at auctions while containing the personal information.

[00:10:11] And you also have a little bit of a catch 22 here because you have, you know, most OEMs now having their privacy policy written in there that. Yes, cars collect purchase information to spell out the types of personal information. Now you have actually a legal records that, you know, this is definitely information will be found in cars.

[00:10:28] And they also say these, you know, your consumer. Uh, make sure you remove this person information because we cannot guarantee the safety of the visa information when you speak on exchanges hands. Okay. So this was the manufacturer’s way of trying to put the burden on the consumer. And now you find financial institutions.

[00:10:47] They have a portfolio of many different manufacturers. The manufacturer has seen this information needs to be removed. And this vehicle has been taken, you know, in the middle, right. Without, without the [00:11:00] consumer really being given and a chance, even if they wanted to, to remove the personal information.

[00:11:06] Right. And so now you have all these compound effects of CERN. And so you’ll have, you know, regulators are looking into this and are saying, well, you know, this is really not. A good situation. You have, again, very large banks are looked into this with. Uh, you know, again, if you look on our website, you’ll find a long list of bank customers that we serve.

[00:11:31] And all of them have very sophisticated internal legal groups, and they have made the decision that it was a good thing to do, to remove the person information from repossess vehicles. And, you know, I would argue for very good reasons, removing the discussion on regulation. What I would say is that if you personally are uncomfortable with the idea, Then you would unlock your phone and hand it to the first person you meet today.

[00:12:00] [00:12:00] If you’re uncomfortable with that thought with your own self, then, you know, you should be uncomfortable that these may be happening with your current customers. That’s essentially what’s happening today with cars.

[00:12:10] Joel Kennedy: [00:12:10] Andrea, I wonder with, um, IOT really being pervasive within a number of, I mean, I feel like there’s refrigerators that have like monitors on them that you can like reorder food.

[00:12:22] And stuff like, I mean, how many of these devices beyond just cars? Cause I’m sure you’re an enthusiast. I mean, is this data in all of these other things that we encounter that have IOT

[00:12:33] Andrea Amico: [00:12:33] built in many, many, many, many, there is the two fundamental differences between cars and everything else. Ronnie’s let’s talk about what cars are, right.

[00:12:44] Uh, how’s it different from a home speaker or your, you know, your personal phone or whatever, right. So it’s the second, first or second largest purchase of, of an American citizen nowadays. Um, especially nowadays with the things of chipping they’re becoming more and more [00:13:00] expensive, right. It’s also, you know, There’s a lot of studies that show that it’s very hard to be a participating citizen in the economic life and just the civil life of the country without a vehicle.

[00:13:14] Right. And so you can argue, look, the, you bought a smart fridge wasn’t doctor’s orders, right. But he’s going to be very much harder to argue while you really needed a car. And in reality, you need it right. The. There a big difference. And this is really important is that if you buy a smart fridge in order for the smart fridge to show you the recipes and whatever else they do, and all of that is right, the first thing is that you do is that you go through a set of menu and you hook it up with your home wifi or whatever, you know, you go to your home wifi, right?

[00:13:47] So the consumer needs to take some active steps to connect that device. So the network is start exchanging data. That is not the case with cars. Okay. [00:14:00] With cars, you have two situations, older vehicles that had only Bluetooth. You have to do it because Nita says you have to, like every single state in the country has laws that say you cannot use a phone unless you hook it up through the Bluetooth and needs a news as far.

[00:14:16] I’m sorry. National highway traffic safety administration says Bluetooth is a safety device, right? So consumers have to do it because they have no choice. If they want to touch the phone while they’re driving. Right, but most important with newer vehicles that have an embedded cell phone connection, what is happening is that the vehicles come out of the factory with an embedded cell phone.

[00:14:40] You don’t have to do anything actually. Very often consumers have no idea that this car is sending data. As they’re driving back to the OEM, it’s in a bunch of third parties and third parties of the third parties. So it is a lot harder. To argue. Well, dear Joel, you bought the smarter [00:15:00] TV. You decided to hook it up.

[00:15:01] You click on the three. I consent, you know, pop-ups has appear on your TV. So you knew you were very well aware. This was being collected. I think it’s much harder to argue with vehicles.

[00:15:13] Joel Kennedy: [00:15:13] I can see there being so far from the lender standpoint, in order to make sure that they’re being a good steward of PII, that they’re.

[00:15:20] Deploying a strategy using privacy for cars. What about for individual consumers? Is that also a market that you think has an opportunity? Yeah, so we,

[00:15:30] Andrea Amico: [00:15:30] we have always given access to consumers, to our application for free. Right? When I started the company, it really, it wasn’t sorry. As a company was started as a thought seven years ago that, Oh gosh, people leave a lot of personal information that really shouldn’t happen.

[00:15:44] Right. So we always gave access to consumers to this information for free. We continue to do so. We are in the process of creating value propositions for businesses that want to offer privacy services for consumers. For [00:16:00] instance, we started to offer identity theft protections for consumers, right. So do you want to make it part of your.

[00:16:08] Offering that when you finance with company XYZ, we will include an identity theft protection and we will make sure that your data is removed. If the vehicle ends up being repossessed. Absolutely. You can do those kinds of things. And I think, again, if you’re a smart player and utilize what I’m going to have to end up having to do this anyway, you may want to try to figure out how do I make it a positive.

[00:16:36] How do I communicate with consumers? I actually take steps to protect them. Are there any services I can offer to them to give them the peace of mind they’re looking for? We just need a study actually just in California for obvious reasons as you live there. Right? Right. We measured that consumers. We pulled over 500 consumers that bought the, that were 2018 and Newark and typically 85 to 90% of consumers.

[00:17:00] [00:17:00] Are willing to pay for services that give them peace of mind over the privacy of data collected by the cars. And so again, I think that there’s an opportunity here for financial institutions, not only to meet the regulatory requirements and make sure that, you know, they don’t incur into risks that. They may otherwise, but also could to create a value proposition.

[00:17:21] We think it’s a, it’s a, it’s a good thing. If you can get to do both,

[00:17:25] Joel Kennedy: [00:17:25] this is amazing. And I think it’s timely as well. And I know this isn’t an exact corollary, but folks listening. I know there’s, there’s some talk about when. If I’m a, if I’m a lender and I have somebody that I’ve loaned money to, I need to send them a statement and you just to let them know what their balances and when they need to make their, their next payment, we generally will take that information, send it off in a batch file to a mail shop, a separate third-party mail shop, and they can perform the fulfillment.

[00:17:53] And you’re talking about. Hey, Joel, you’ve got a credit card with capital one. Here’s your capital one credit [00:18:00] card statement. It has the capital Corp credit card number, my name, my address, that kind of PII. So now the people at the mail shop I’ve disclosed. There’s a debt. So now they know that Joel Kennedy has a debt with capital one and that violates FCCPA.

[00:18:13] That’s a very. Interesting to me way to kind of go about it, because I think, you know, you’re dealing with mail shops that deal with information. They obviously any email shop worth it’s scratch is going to have policies, data protection, document protection, destruction, all built in. And I think, okay, this is what these people do, right?

[00:18:33] They they’re used to managing this, this kind of information, but if this is the, or that we’re going, then, you know, it just seems like, again, The onus always goes on the lender, right? You’re buying from licensed automotive dealers. The CFPB does not touch them. Dodd-Frank doesn’t touch them. The lenders have to police the dealers.

[00:18:52] The lenders have to police the mail shop. The lenders have to police the recovery agents. And this at least on that one portion, [00:19:00] right where you’re looking at it through vehicle recovery, through asset disposal. It is kind of telling when they, if they have this, this policy and they can use privacy for cars when they deploy, are they going super conservative or are they going a little bit more, you know, Just in time.

[00:19:15] I just, I just think it’s fascinating and it’s kind of timely right now. Have you noticed a big pickup lately in terms of interest your product, given the nature of, yeah, that’s what I

[00:19:25] Andrea Amico: [00:19:25] thought. I’m sure you know, that, you know, privacy is probably one of the hottest topics on the Hill and you know, in a bunch of state legislatures again, what is interesting.

[00:19:35] There’s not a lot of bipartisan is going on nowadays, but privacy is one of those. In fact, the last proposal that was put on the floor under the previous administration for privacy was written by five Republican senators. And it was not very far. From where CCPA is cruelly, that’s going to be the lowest possible bar.

[00:19:57] This is going to be set under this administration. In [00:20:00] addition, you have the FTC that has clearly spelled out that they are on a mission to protect consumers, especially not COVID world in which. I think the identity theft numbers went through facility doubled or more than doubled in the last year.

[00:20:15] Right? So it’s a very significant concern of the FTC commissioner Rohit Chopra left, or the FTC is now heading to the CFPB. He is very knowledgeable. All day thing, car specifically, the FTC has published a thing now for guidances on personality to lifting cars. And just to give you some example, you know, attention that associations are paying.

[00:20:38] And I, ADA that I think that they had their conference on regulation just a couple of months ago. They already did promises the number two risk for the dealers after recalls. Rico is a massive issue, right? And the fact that privacy came out of nowhere to become number two, I think is very telly. The other thing your audience may want to consider is we [00:21:00] start to see loss.

[00:21:01] In fact, I know that the first two losses of just being settled, one was against Hertz and one was against the sixth rental car on these specific issues, personal information that. Renters left in cars. I mean, Hertz is in bankruptcy, right? To get a bankruptcy judge to say, we will award the money to settle this lawsuit.

[00:21:23] And it’s going to be ahead of any lenders that has any interest in a bankruptcy. I think it’s. Staggered. It is really a telltale sign, aware the judiciary, not only the regulatory, but the judiciary arm will come out

[00:21:37] Joel Kennedy: [00:21:37] of this. Yeah. So I see, I see the application for the fleet folks. I mean, I can see them having to use it every time a car gets turned in and if they really wanted to be truly protective, which, which kind of gets me to.

[00:21:49] To the question of, you know, where do you think things are going, Andrea? I mean, this is, this is a nice innovation. It obviously has this application with the lenders and with the fleets, et cetera. Like where do you think things are kind of [00:22:00] going in the next couple of years for

[00:22:02] Andrea Amico: [00:22:02] us as a company or in general on the

[00:22:04] Joel Kennedy: [00:22:04] topic?

[00:22:04] Yeah. On the topic general, like, do you see this maybe finding its way as more of a native thing within the vehicles? Maybe at some point, somebody presses a button and it kind of like reboots trying to see do your best Elon Musk impression, you know, tell me where we’re going, where are we going to Mars?

[00:22:20] Are we going to the moon? Where are we going? I

[00:22:22] Andrea Amico: [00:22:22] think that I’m going to be blunt and maybe, you know, maybe it may be a little bit too much, but from my perspective, having also disclosed the cybersecurity flaws to automotive companies. I think if we’re shooting for maybe putting a step in front of the other, wouldn’t be a bad beginning.

[00:22:39] That’s what I think we should be shooting for vehicle technologies today. As far as infotainment system is probably equivalent to what cell phones had 10 to 15 years ago. You know, there are very basic things that you’re used to do on your computer, in your phone that are just light years away from what happens in cars clicks, or you get to see I’m using [00:23:00] it.

[00:23:00] Or my wife is using it. Right. And we get different preferences and all of that. Right. With cars, whoever has the keys, the car thinks is the rightful owner of the information is stored in there. So we are down to basics. So when we see innovation, I surely expected, and I sure hope that reality is that also the average car in the United States is 11 years old.

[00:23:20] And so whatever change happens, it takes a decade to get only half the cars been taken care of. So I think unfortunately, you know, be pragmatic. If you’re a financial institution you’re dealing with a portfolio of vehicles. I think hoping that there’s going to be a technological magic one will be waived somewhere.

[00:23:38] They care. The problem is just not realistic.

[00:23:42] Joel Kennedy: [00:23:42] Well, this is, this is a welcome innovation and, um, it, it, it fits in nicely in the space. I think it’s a good time, Andrea, for folks listening, you know, can you give them a couple of details for, you know, if they want to learn more about privacy for cars, or maybe, maybe talk to you or someone from your team.

[00:23:59] Andrea Amico: [00:23:59] Yeah, [00:24:00] sure. Go to privacy for cars. Dot com is spelled privacy. Number four, cars with an S you can contact us through there as a consumer. You know, each of us are individuals who own cars and, you know, if you’re planning to sell your cars or just download the app, it’s free. You don’t know how to delete your information, take care of yourself.

[00:24:17] So you also have an idea of how it works accurately. There’s a, some, a bunch of bells and whistles that we have for business accounts we don’t have for, for consumers. The other thing that is helpful is on our website. We just compiled a couple of awesome resources there under legal, and there is a page under there that has workshops.

[00:24:37] We have recorded so far as we had a workshop that we recorded with the national association finance conference last year, it’s there, we just did the presentation for the national association with your council is going to be there in the next couple of weeks. And there’s a great resource, which is this laws by geography.

[00:24:54] We’re very proud of the effort. It is the first. Mapping of how [00:25:00] different laws applies in different States. Because again, if you are a lender in Colorado, or if you’re a lender in Maine or your lender in Alabama, You may have different things. And so we literally have a map United States, you click on the state is going to take you to your section there.

[00:25:16] It’s going to tell you, Oh, these States has four laws. You need to be thinking about whether it takes you straight to the opposite to the language, but it also, we provide a high level language summary of what does the law says in short, how does these applies to we call data? Well, there are some reasonable, next steps that you shouldn’t be taking and this way, you know, um, cause sooner or later the discussion always ended to the general counsel’s office or some external counsel.

[00:25:40] Right. So it’s good to be informed about what is the lay of the land. And sometimes by the way, these laws are very counter-intuitive. You know, when I talk to people, they thought, Oh, well this is a thing about progressive, you know, very progressive States like California and. That’s actually not what’s happening.

[00:25:58] Like there’s a, there’s a lot of [00:26:00] very conservative States that have very strong laws on data security. That again, you need to

[00:26:05] Joel Kennedy: [00:26:05] be aware of. Andrea. Thank you so much for joining us today. And your, you guys, you guys are going to be at the national automotive finance association conference in, in Plano, this, this, uh, this summer, correct?

[00:26:17] Andrea Amico: [00:26:17] Absolutely. Plan to move forward to that very much.

[00:26:21] Joel Kennedy: [00:26:21] There’s another crack at the Apple. If you can’t get ahold of Andrea, which I do encourage you to check out the website and reach out all the details for getting in touch with anybody on your team or on the website, right? Andrea.

[00:26:31] Andrea Amico: [00:26:31] Uh, yes, absolutely. You can reach us there in a million different ways.

[00:26:34] Contact us is a big button on the top, right? So you can, you can get ahold of me very

[00:26:39] Joel Kennedy: [00:26:39] easily. Perfect. If you, if you, if you want to meet, if you want to meet, uh, some folks in person, which I’m obviously excited to get back on the circuit, the national automotive finance conference is in Plano. Again, it’s in August.

[00:26:50] I apologize. I don’t have the exact dates, but Andrea, thank you so much for joining us. Today

[00:26:55] Andrea Amico: [00:26:55] I look forward to seeing you in planar.

[00:26:57] Joel Kennedy: [00:26:57] Likewise, the consumer [00:27:00] fi podcast has been brought to you by Northbridge loan software. That accelerates change. We’d also like to thank the national automotive finance association, the only trade association, exclusively serving the non-prime auto financing industry.

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