A Behavorial Targeting Example Shows Why Privacy Laws are Required, including a New and More Accurate Definition of Personally Identifiable Information

Interclick, “one of the largest advertising networks in the U.S., reported higher revenues today.  The company says that it collects “non-personally identifiable information (non-PII)” via cookies.  Here’s what Interclick considers, like other online advertisers, non-PII: “On the interCLICK network, we collect non-personally identifiable information (non-PII) such as web sites visited, content viewed, ad interaction, interaction with advertiser websites, IP addresses, search terms used, and other click and browsing behavior. Additionally, we may collect non-PII technical information including IP address, OS, browser type, language settings.

Meanwhile, Interclick’s behavioral targeting “option” for advertisers explains that its: “innovative behavioral targeting filters allow you to target the right individual users at the right time, increasing the effectiveness of your campaigns. With over 350 behavioral categories, interCLICK can get as precise as you want.

We segment users based on observed behaviors into 3 interest levels: slightly, moderately and very. Furthermore we use frequency and recency to classify these interest as short, mid, or long term interests. As the user navigates throughout our network of sites, we continually adjust their profile based on anonymous observations, assuring the accuracy of our profiles.” It offers “Behavioral Segmentswhich allows online advertisers to “Leverage interCLICK’s massive data warehouses to effectively target users who have been determined to exhibit certain behaviors throughout interCLICK’s network. interCLICK offers over 350 different Behavioral Targeting categories/sub-categories.”

Among the segments include financial services including “personal banking seekers, credit card seekers, retirement investing.”   There’s a segment targeting “college seekers,” raising issues related to youth marketing.  Another segment is on “health,” including categories targeting “Diet & Fitness Enthusiasts.”

InterClick is just of many ad networks engaged in such data collection and targeting.  But it illustrates why the online ad industry must be regulated, to protect consumer privacy and welfare.

Author: jeff

Jeff Chester is executive director of the Center for Digital Democracy. A former journalist and filmmaker, Jeff's book on U.S. electronic media politics, entitled "Digital Destiny: New Media and the Future of Democracy" was published by The New Press in January 2007. He is now working on a new book about interactive advertising and the public interest.

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