AI personalization is now a discoverable theory in the next class action.
Tokto records every model decision, every agentic AI interaction, every customer prompt, and every vendor AI call that touches a transaction, ready for the FTC, the state AG, the card brand, opposing counsel, and the carrier.
The state AG opens a TDPSA-class enforcement on your personalization stack. Plaintiffs' bar files a parallel class action on BIPA. The legal team has dashboards from four vendors. None tie a model decision to a customer, a channel, a consent capture, and a rate at the moment it fired.
- Every model decision tied to a customer, a transaction, a channel, a consent capture, and a disclosure in force.
- A complete record for the FTC, the state AG, the card brand, opposing counsel, and the carrier on the same evidence.
- Policy at the model: no personalization outside disclosure, no biometric capture without state-by-state consent, no PCI without scope.
- Defensibility under FTC enforcement, AG action, class certification, and card-brand sanction at the same time.
- An FTC investigation into personalization. The brand cannot produce a per-customer consent and model decision record.
- A class certifies on BIPA against a sales-floor AI feature. The brand cannot prove state-by-state consent.
- A vendor-deployed AI tool produces a brand-unsafe output that goes to a customer. The board hears it from the press.
- A facial-recognition feature ships against the FTC's Rite Aid playbook. The order template already exists.
Tokto governs the AI surface of the retailer. Personalization engines, agentic support, merchandising co-pilots, vendor scoring models, ambient sales-floor AI — all become records at the moment they fire. The record carries the customer, the channel, the transaction, the consent, and the disclosure language active that day. The GC controls one trail, not seven dashboards.
When the FTC opens a Section 5 personalization inquiry, when an AG opens a BIPA enforcement, when the card brand asks how cardholder data was governed in an agentic flow, the record is the same record. The GC answers in days, not quarters.