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Neutralidad de red y ofertas zero-rating

by | Nov 8, 2017 | Opinión, Tecnología | 6,404 comments

Neutralidad de red y ofertas zero-rating

Es común ver ofertas de planes móviles con la posibilidad de ocupar determinadas aplicaciones en forma “ilimitada”, esto es, de utilizarlas sin consumir datos de la bolsa que el usuario puede disponer libremente. Por ejemplo, típicamente se otorga el uso de Facebook, Messenger y WhatsApp sin gastar datos de la bolsa, mientras que navegar libremente por internet, o utilizar otras aplicaciones que a su vez consuman datos, sí será descontado de la cuota. Para el consumidor esto puede ser un gran incentivo a contratar el plan, ya que el uso de estas redes sociales es hoy masivo, como es a todas luces evidente. Estas características de los planes son comunes tanto en Chile como a nivel mundial, y también incluyen ofertas de aplicaciones de música y videos, entre otras. Esta práctica se denomina en doctrina “Ofertas Zero-Rating”.

Desde el punto de vista de competencia, las Ofertas Zero-Rating consisten en acuerdos verticales entre actores de mercados interdependientes: desarrolladores de aplicaciones y empresas de telecomunicaciones. Aguas Arriba, está el mercado de desarrolladores de aplicaciones, que compiten dentro de las plataformas (iOS o Android), para poder llegar a los usuarios que utilicen smartphones. Estas aplicaciones son generalmente de acceso gratuito, obteniendo beneficios por publicidad o por el cobro por acceso a características especiales de la app. Aguas abajo, está el mercado de las empresas de telecomunicaciones, las cuales compiten ofreciendo servicios mediante planes de minutos y de datos. Las Ofertas Zero Rating generan incentivos tanto para adquirir esos planes como para descargar las apps incluidas en ellos.

Los principales resquemores respecto a estos acuerdos se derivan de su eventual efecto excluyente. Una empresa de telecomunicaciones con poder de mercado podría excluir arbitrariamente a desarrolladores de apps que no hayan celebrado estos acuerdos. A modo de ejemplo, si tomamos el caso de las aplicaciones de streaming de música, que generan un tráfico de datos significativo, la inclusión en una Oferta Zero-Rating de Spotify afectaría el desenvolvimiento competitivo de Apple Music y Deezer, pues la primera tendría una ventaja relevante por la facilidad que otorga al usuario que contrate el plan, que no vería afectada su cuota de datos, sin perjuicio del uso intensivo que pueda darle. Se ha dicho, además, que el principal efecto anticompetitivo que tendrían estas ofertas sería un fuerte desincentivo a la innovación.

Con todo, la aptitud objetiva de las Ofertas Zero-Rating para infringir la competencia no es una cuestión pacífica. Los mercados de aplicaciones, y en general los mercados digitales, se caracterizan por su gran dinamismo, dado que las barreras de entrada y de salida tienden a ser muy bajas y la sustituibilidad de las aplicaciones puede ser alta (los consumidores pueden tener varias aplicaciones que compitan entre ellas y pueden usar ambas). Por lo mismo, puede ser difícil determinar si alguna de estas app tienen una posición dominante. Al mismo tiempo, el desincentivo a la innovación es a lo menos discutible y muy difícil de determinar. Finalmente, desde el punto de vista de las empresas de telecomunicaciones, puede resultar también muy dificultoso determinar la posición dominante de cada una (recientemente, el TDLC estableció en su Sentencia 154/2016 que aunque Entel, Movistar y Claro tengan alta participación de mercado, de ello no se sigue la posición dominante de cada una de ellas). Al mismo tiempo, no existe claridad respecto a si la conducta de una empresa de telecomunicaciones pueda ser analizada en función de la exclusión de determinadas aplicaciones, o si debería estar enfocada a excluir a otro operador móvil.

Más allá de los eventuales problemas de competencia, las Ofertas Zero Rating pueden analizarse a partir del llamado principio de Neutralidad de Red (Net Neutrality). Este principio consiste en que los proveedores de internet (ISP), sea fija o móvil, deben asegurar un acceso igualitario a la red tanto para los desarrolladores de servicios (páginas web, softwares que utilicen datos o aplicaciones) como para los usuarios de internet. De esta manera, el acceso a la red entre los dos puntos de esta, servicio y consumidor, es “neutral” o “libre”. En otras palabras, no puede discriminarse el uso de internet en función de su contenido. Estas formas de discriminación podrían verse ya sea en forma de impedir el acceso a determinados contenidos, de aumentar o disminuir la velocidad de internet para acceder a algún servicio en vez de otro, o, en el caso de las Ofertas Zero-Rating, de privilegiar el uso de un contenido por sobre otro. La Neutralidad de Red, como puede apreciarse, tiene corolarios en distintas áreas del Derecho, tales como protección de datos personales, regulación de las telecomunicaciones, competencia, e incluso, en último término, aseguramiento de garantías constitucionales.

En Chile, desde 2010, existe una Ley de Neutralidad de Red (Ley 20.453), la primera dictada a nivel mundial sobre el tema. La normativa establece que los ISP “no podrán arbitrariamente bloquear, interferir, discriminar, entorpecer ni restringir el derecho de cualquier usuario de Internet para utilizar, enviar, recibir u ofrecer cualquier contenido, aplicación o servicio legal a través de Internet, así como cualquier otro tipo de actividad o uso legal realizado a través de la red”. La misma ley establece una suerte de excepción, al permitir que las empresas de telecomunicaciones puedan “tomar las medidas o acciones necesarias para la gestión de tráfico y administración de red, en el exclusivo ámbito de la actividad que les ha sido autorizada, siempre que ello no tenga por objeto realizar acciones que afecten o puedan afectar la libre competencia”. Finalmente, entrega potestades a la Subsecretaría de Telecomunicaciones (SUBTEL) para iniciar un procedimiento sancionatorio contra empresas de telecomunicaciones e ISP que infrinjan esta normativa.

En 2014, SUBTEL ofició a los ISP para que finalizaran sus promociones utilizando Ofertas Zero-Rating para aplicaciones de redes sociales, so pena de ser multados por infringir la nueva normativa. Sin embargo, hasta el día de hoy las ofertas están presentes en prácticamente toda la oferta de planes. En una entrevista el año pasado, el ex subsecretario de telecomunicaciones consideraba que existía una errónea interpretación de la normativa, ya que el concepto de discriminación sólo se debería ver referido a los consumidores. Es decir, sólo en caso que se impida el acceso en forma discriminatoria a un consumidor, la SUBTEL podría sancionar. En caso de que exista discriminación a nivel de aplicaciones o de empresas de telecomunicaciones, el eventual conflicto debe ser resuelto en sede de competencia. De esta manera, existiría en principio un deber de coordinación entre la SUBTEL, la FNE, y eventualmente el SERNAC, para poder enfrentar las problemáticas relativas a las ofertas Zero-Rating, fiscalizando el comportamiento tanto desde el lado de los consumidores como de las empresas de telecomunicaciones.

La pregunta es, entonces, determinar si las Ofertas Zero Rating pueden constituir una infracción a la Ley de Neutralidad de Red, y desde qué punto de vista pueden perseguirse estas conductas: en forma de sanción ex ante, o en forma del deber general de resguardo de los mercados como sanción ex post.

Desde la perspectiva de la ley de Neutralidad de Red, las Ofertas Zero-Rating son una forma de efectuar preferencias, y de establecer limitaciones al tráfico de datos. El alcance de esta prohibición de discriminación debe comprender tanto a desarrolladores de aplicaciones como a los consumidores finales, pues de lo contrario la regulación no es efectiva: si vemos únicamente el punto de vista de los desarrolladores de aplicaciones, la discriminación sería más bien un problema de competencia entre aplicaciones. A su vez, si miramos únicamente el punto de vista de los consumidores, estas ofertas no serían en principio problemáticas, en tanto permiten el uso ilimitado de aplicaciones de uso generalmente masivo.

La regulación de neutralidad de red mira a ambos mercados en forma interconectada e interdependiente para asegurar, paradójicamente, la no interferencia entre ambos puntos de la red: No condicionar el acceso a la red al uso de determinados contenidos, ni el uso de determinados contenidos al acceso a la red. Con esto se evita que un tercero pueda interferir en la selección libre de contenidos que el usuario pueda realizar.

El problema de la interpretación de la SUBTEL sobre las Ofertas Zero Rating radica en que separa artificialmente el ámbito de protección del acceso a la red y del acceso a los contenidos. Tratarlos separadamente genera los problemas propios de cada ámbito de regulación, impidiendo hacer efectiva la opción institucional por la no discriminación. La interpretación de SUBTEL convierte la Neutralidad de Red, para el caso de las Ofertas Zero-Rating, en una mera declaración.

Manuel Abarca M., Ayudante de investigación RegCom

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