Services offered by Google, Facebook, and their kin are not truly free: users contribute to the monetization of the platform. The question is not whether a market can be defined for zero-price services, but rather how this should be done. This short piece assesses whether personal data can be conceptualized as a price, to enable a substitution analysis for zero-price services. To do so, the piece focuses on the notion of price and its role in quantitative substitution analysis (when consumers react to price changes) in the context of personal data. It makes a reflection on the feasibility of conceptualizing personal data as a price. This would require answering two questions: first, is there a relationship of exchange between the user and the platform; second, can reactions to changes in personal data collection be used to assess substitution. The piece then briefly considers a revised SSNIP test with personal data.

By Magali Eben1



Nowadays, all but the staunchest sceptics acknowledge that the services offered by Google, Facebook, and their kin are not truly free. As Vestager put it, “there ain’t no such thing as a free search.”2 The users contribute to the monetization of the platform through the attention and/or data they provide. We have come a long way since a U.S. court, now rather famously, declared that antitrust law “does not concern itself with competition in the provision of free services.”3 If there is a relationship of an eco


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