Category: online lead generation

Facebook Finagling: Getting You to Push the “Like” Button and Opt-In to Third Party Apps, Marketers, and Data Collection

As Facebook builds a larger online marketing and data collection infrastructure around the world, in the U.S.,  India, and in the EU, it’s important regulators, researchers, privacy and consumer protection advocates investigate how it operates its social media marketing business.  Facebook prefers to keep its interactive “marketing to the social graph” ad approach largely out of public view.  For example, last week, noted Inside Facebook, there was this change [our bold]:

“Open Graph-enabled third-party websites can now include Like buttons that create a connection with a Page, not just share an object. Page Likes can be more valuable because they opt a user into receiving updates about the Page in their news feed, and displaying the connection on their profile. Developers don’t need to include any description of what the Like button actually points to, meaning users may be unaware that their click is in fact subscribing and connecting them. The change will help developers convert one-time visitors into members of their Page’s community.”

This is a good illustration of how Facebook (and others) zeal in promoting third party data and financial relationships threatens to further undermine privacy and related consumer protection concerns.

Google Sells To Advertisers: User Profiles for Consumers Looking for Credit Cards [UK]

The new Consumer Financial Protection Board–and the FTC–will have their digital hands full as they begin to investigate the stealth world of online financial marketing.   Disclosure and consumer control has to be built into these applications–but they are not.  Of interest is a trial run by Google in the UK to sell credit cards, part of its move into “comparison” marketing.  According to New Media Age [my emphasis], “Google is testing its own [credit card] comparison product, launched earlier this year.  Currently focused purely on UK credit card providers, it lets users search on Google, click on an interactive ad showing rates from participating advertisers and takes them to a comparison page. Advertisers bid for user profiles that match their target audience and pay on a cost-per-lead basis.”

Take a look at Google’s credit card comparison site; does a consumer know about the advertiser bidding to buy their profile? See also Google similar product selling mortgages here in the U.S.

Google’s new `simplifed’ Privacy Policy: More disclosure and honesty required [updated]

Last week Google announced it was “simplifying and updating” its privacy policies.  As it so often does, the announcement was framed as a `we did for your good’ kind of effort.  “[W]e want to make our policies more transparent and understandable,” it explained, noting that “most privacy policies are still too hard to understand.” But as so often with Google and other online marketers, you have to both read between the digital lines and also analyze what’s really going on.

Google’s revised policy, which takes effect October 3, fails to really explain to consumers/users what’s actually going on.  Like other privacy policies, Google claims that all its data collection is to “provide you with a better experience and to improve the quality of our services.”  But what they really mean–and what the Congress, the FTC and other regulators must require them to disclose–is that they have crafted a wide-ranging system designed to foster personalized data collection and online targeting.  Missing from the revised Privacy Policy (which Google, btw, is pitching to privacy advocates and no doubt others as a  paragon of digital virtue) is any candid disclosure on how its Doubleclick, Admob, Google Display Network, Ad Exchange, Teracent, and other services collect information from and about us.

Google isn’t alone–Facebook, Microsoft, Yahoo and everyone else rely on a purposefully deceptive privacy policy to engage in data collection activities that require disclosure and individual user control.  Google is also reshaping its privacy policy to better capture all the data it can collect across multiple platforms and applications. Here, just for the record, is what Google advertised in Ad Age’s recent Ad Exchange and online advertising guide [excerpt]:  No matter how you define performance, the Google Display Network offers a solution. By bringing more measurability and precision to your advertising, it enables you to create, target and optimize ads based on real-time data, meaning better returns for you.

The Google Display Network helps advertisers and agencies achieve performance at scale by delivering relevant, accountable ads to their target audiences—in more places, more often…Precisely target your audience: The Google Display Network’s technology enables you to find customers based on their interests, sites they visit and when they’re engaging with relevant content via contextual targeting, or show specific messages to users who’ve already visited your site with remarketing…The Google Display Network provides opportunities to advertise in all such environments—feeds, games, mobile, social networks and video streams— enabling you to create an immersive experience for your audience.

PS.  Well, Google just also announced what its interactive display ad system can do for marketers.  How come this isn’t in the privacy policy in understandable language and full consumer control? Excerpt:  Advertising with Google used to be all about four lines of text, on Google.com and on our partner sites. No longer. Did you know that, outside of ads alongside search results, more than 40 percent of the ads that we show are now non-text ads? And that doesn’t include the 45 billion ads that our DoubleClick advertising products serve every day across the web.

We get excited by display advertising for a number of reasons…Teracent’s technology can automatically tailor and select the creative elements in an ad, and adjust them based on location, language, weather and even the past performance of ads, to show the optimal ad.  We’re focused on helping advertisers get the best results from their campaigns—by enabling creative branding campaigns, precise targeting, wide reach and effective measurement. Over recent years, we’ve added a ton of new features to YouTube and the Google Display Network, to help advertisers get—and measure—the results they’re after. From remarketing to Campaign Insights to video targeting on YouTube, we’re building tools that are helping advertisers get great results and enabling them to run some of the most amazing ad campaigns the world has ever seen.

Retargeting 3.0–It tracks and observes a consumer, adds new data–and changes its sales pitch

Yesterday, the New York Times ran a front-page story on retargeting--the practice of stealthily tracking an individual user online in order to keep delivering sales pitches–including for health and financial products.  We gave the NYT lots of information, including how so-called “smart” ads technologies are now melded with retargeting–for so-called “Retargeting 3.0.“  [My CDD and USPIRG, btw, asked the FTC to investigate retargeting back in 2007 and to protect consumers].  Here’s some of what we sent to the Times.

From Criteo:“Retargeting allows you to find your previous website visitors across the Internet and display relevant banners to lead them back to your website to complete their transaction. Bringing ready-to-buy users back to your website after they have left should be a key part of your customer acquisition and conversion strategy. Criteo provides a breakthrough dynamic personalised retargeting solution…Criteo has revolutionised retargeting with the most sophisticated form of dynamic personalised retargeting. Over the past decade there has been a slow evolution of retargeting. This third generation of retargeting enables an advertiser to show each lost visitor a unique banner based on his/her very specific past interactions on the advertiser’s website. This new form of retargeting involves on-the-fly, real-time personalised banner creation and has a dramatic impact on campaign performance.”

Retargeting data now incorporates user information from outside demand side platform sources, and can the rights to retargeting you can be sold to the highest bidder via online ad exchanges, such as the one run by Google.

A recent MediaPost panel sums up how retargeting has evolved:
Re-Thinking Re-Targeting 
Re-targeting continues to be the tried and true workhorse of behavioral targeting. Tagging and retrieving someone who has already shown an interest in your business is about as simple a use of the BT model as it gets. But it is not so simple any more, and like everything else in this complex ad economy, re-targeting too is in for a upgrade. Dynamic ad creation driven by recommendation engines offers new opportunities to marketers to be even more effective. Demands for greater accountability, control over placement and clearer attribution press the ad networks and tech providers to provide new levels of transparency. And just like everyone else in the ad economy, re-targeting is working its way through questions about metrics and pricing, do marketers optimize and pay according to clicks, conversions, purchase? And what role does retargeting now play in this larger field of audience creation and the age of the DSP?

Retargeting illustrates how online marketers have deployed armies of digital private detectives to shadow us online.  They watch us closely, take notes, even learn about us, and then appear when we don’t expect it.  Consumers shouldn’t have to confront such digital surveillance.  Retargeting is “Exhibit A” in making the case to lawmakers that consumer privacy online should be protected.

Questions should also be raised about retargeting and consumer protection.  Should I get a better discount because the data collected about me indicates I spend more or live in an expensive neighborhood? Or that because they believe I am a certain ethnicity, I might spend more on certain products.  Retargeting is a non-transparent marketing technique that raises important consumer protection issues about the use of digital advertising.  Consumers require a fair deal online.

PS:  Here’s how Google explains its retargeting service–which in typical Silicon Valley meets George Orwell fashion, it calls “remarketing’ [for the Google Content Network]: “Remarketing is extremely effective because it targets a highly-relevant audience. With it, you can target users who:

  • have visited your website or viewed specific product categories on your site
  • didn’t convert or who abandoned their shopping cart
  • have converted (in order to up- or cross-sell to them)

If you’re already driving traffic to your site through other means, like contextual targeting or your search ads, remarketing is a great complement to those efforts to increase your return-on-investment (ROI).”

and we believe in fair play.  Here’s what Microsoft says its “remessaging” service can do:   “After consumers visit your site, see one of your campaigns or click through on an ad, remessaging offers several ways to continue the conversation and ensure that your message is seen by the people to whom it matters most.  With site remessaging, you can re-engage a consumer to complete a purchase or further engage with your brand. Creative remessaging drives brand perception, awareness, and favorability, and enables advertisers to re-engage audiences who have seen or clicked on an existing campaign. Email remessaging complements email assets such as newsletters by placing tags and accessing the same email recipients to reinforce your message to a loyal audience.”

and Yahoo!:  “…Enhanced Retargeting, which combines standard site retargeting with dynamic ad generation. For example, users who visit an airline website to check offers for flights from SFO-JFK can be served a personalized offer for that specific flight when they visit a page within the Yahoo! Network. In a recent trial, a market-leading online travel company saw a 230% increase in total bookings and a 651% increase in click-through rate when comparing Enhanced Retargeting to their traditional retargeting campaign.  Recognizing the need for more focused audience segmentation and improved control, Yahoo! Search Marketing will offer advertisers Enhanced Targeting capabilities for Sponsored Search and Content Match programs. New features are designed to extend the advertiser’s control over where and when an ad is shown at both the campaign and ad group level, including what time of day and day of the week an advertiser would like campaigns to run (ad scheduling) and what age and gender they’d like to reach (demographic). Advertisers will be able to vary their bids for different segments in order to increase their ability to reach the desired audience.”

“Digital Body Language” & Online Financial Marketing–Can Be Hazardous to Your Privacy and Fiscal Health

For the last several years we have watched with dismay the largely stealth online data collection and targeting apparatus assembled for online financial marketing.  Everything from loans, credit cards, mortgages and insurance is increasingly sold online–an entire system has developed that stealthily `-e-rates’ us, including whether we are considered good prospects for various financial products.  Such “scores” become associated with us–without our knowledge.  Online lead generation is one field that helps financial online marketers and others identify whether we are the kind of person who should be pursued for a loan, for example.  One company explains that the:  “shift to online from face-to-face sales has crippled our ability to see body language when interacting with prospects leaving us less able to connect with prospects to determine their level of interest. The solution? Savvy marketers step in to read prospects’ “digital body language” and use that knowledge to guide the buying process. What web pages did prospects click on? What emails excited their interest? What breadcrumbs are they leaving that show their paths through the buying process?  Digital body language can arm sales people with deep insights into the areas and levels of interest of every prospect. Furthermore, digital body language allows marketers to determine which leads should be passed to sales at all.”

As the FTC and Congress–and we assume state regulators–work to ensure consumer protection in the digital marketing era, online financial services must be at the top of their agenda.

Facebook Places & Data: “Every single action people take…becomes an object in Facebook’s database.” $1.7 billion in ad revenues in 2011

From eMarketer on The Advertising Opportunity in Facebook Places [excerpt]: Facebook’s value as a business comes from all the bits of information it gleans about its users from their daily activities. Every single action people take—whether it’s writing a status update, posting a photo, commenting on a friend’s post, liking a marketer’s message or playing a game—becomes an object in Facebook’s database. Location is a type of data that is very compelling because it provides additional context for the actions people take on Facebook…If ads can be pushed to people in the moment they are engaged with something, rather than waiting until they take action and start a search, the ads become very very powerful.  Location will give Facebook a new way to target and sell advertising… By offering ways for marketers to target Facebook users not only on the online service but also when they are on the go and using Facebook on their mobile phones, it opens up all-new avenues for interaction.

Leaving Your Data in Las Vegas: Facebook, Online Gambling & Privacy [Annals of behavioral tracking and targeting in online casino gaming and the need for safeguards]

The Las Vegas Casino the Golden Nugget has created a social game [take a look] on Facebook where, says DM News, users can “build their own Vegas casinos, including table games such as Blackjack, Video Poker and Roulette. As they earn virtual money, consumers can create their own customized furniture layouts and decorations by purchasing store items, as well as slots, tables and clothing for a consumer’s avatar. Players can also visit their Facebook friends’ casinos and build their avatar.”

It’s also about data collection:  “That is about data collection, as well as rewarding people who are playing the game,” [said a Nugget representative].  The game’s developer explained that it “will examine targeted behavioral gameplay data to help advertisers and to provide consumers with more compelling experiences.”

As Congress debates legislation that would okay online gambling, one of the key issues should be privacy.  What happens when a consumer is identified by a online casino or a Facebook that they gamble?  How does that get used in their online behavioral targeting profile, along with health and financial information?  Should we even permit the behavioral tracking of any user who engages with online casinos?  There are a host of privacy and consumer protection issues about leaving your data in Las Vegas–or with online marketers such as Facebook.

Ad Lobby Research Says Vast Majority of Online Ads Involve Behavioral Profiling & Targeting

The online ad industry lobbying group–the Interactive Advertising Bureau [IAB]–has revealed results from its own research that show the widespread use of behavioral targeting.  In a post on its criticisms of privacy legislation introduced by Chairman Bobby Rush, the IAB explains that:

“In an IAB survey of ad agencies conducted earlier this year, we found that 80% or more of digital advertising campaigns were touched by behavioral targeting in some way.”

That means the majority of what consumers do online–including when they deal with sensitive transactions involving their finance, health or other family matters–are being closely tracked and profiled.  In addition, the IAB attacks the important civil rights provisions in both the Boucher/Stearns and Rush bills.  That provision would ensure that data collection about a consumers racial, ethnic or sexual orientation would be better under the control of the individual.   You would think that the IAB leadership, including Google, NBC, CBS, and Disney, would support a policy that would restrict the potential use of online racial profiling.  But the IAB claims these provisions protecting multicultural and other consumers “could constrain multicultural marketing and media…These types of services provide great benefits to their audiences and the proposed restrictions would actually harm the very group of people they seek to protect.”  That’s an irresponsible position.  We should be able to protect civil rights and promote diverse online publishing.
The IAB’s claims that behavioral targeting is anonymous doesn’t hold up to the facts, as well.  The time for action by both the FTC and Congress has arrived.

Online Ad Lobby and Chamber Celebrate Victory over Consumer Protection & FTC

Yesterday, the online ad lobby [IAB, ANA, DMA]–working with Chamber of Commerce–scored a major political victory by forcing the Financial reform bill conference committee to drop proposed provisions that would have strengthened the FTC.  Under the House bill, the FTC would have been given the same kind of regulatory authority most federal agencies have [APA rulemaking].  Marketers and advertisers are celebrating their win, because it keeps the FTC on a weakened and short political leash.  While consumer protection is significantly expanded because of the CFPB and new financial rules, the FTC is to remain largely hamstrung.  The online marketing and advertising lobby [including ANA, DMA–see below] were afraid that the newly invigorated FTC under Pres. Obama would require the industry to protect privacy online and also become more accountable to consumers engaged in e-commerce.   I heard IAB and Chamber are dancing in the streets! Congressmen Barney Frank, Henry Waxman and Sen. Rockefeller deserve praise for working hard to protect consumers, including their proposal on the FTC.

Here’s what two of the ad groups placed on their sites about the FTC issue:

Progress on FTC Enforcement Provisions in Wall Street Reform Conference

June 23, 2010

The marketing and media community has made substantial progress on defeating the broad expansion of FTC powers that is included in the House version of the Wall Street reform bill.  But we still need your assistance to keep these provisions out of the final bill.

Yesterday the Senate conferees presented an offer on the bill that rejected the new FTC powers that are in the House version.  Chairman Dodd indicated that while he may support changes in the Magnuson Moss rulemaking process, there is no Senate provision and these issues are too complex and important to be resolved in the context of the Wall Street reform bill.  Conferees hope to finish the conference this week so the final bill can be cleared for the President’s signature next month.

The House conferees may still continue to push for these provisions, so it is very important that marketers contact the Senate conferees to express our appreciation for their support and to urge them to remain strongly opposed to these new powers for the FTC in this bill.  Contact information for the Senate conferees is located here and our letter to Senate conferees is available here.  Please let the Senators know if you have plants or operations in their states.

ANA took part in a very important meeting yesterday with Senate Commerce Committee Chairman Jay Rockefeller on these issues.  We argued that these issues are very important to the entire marketing community and deserve careful consideration outside of the context of the Wall Street reform bill.  The Chairman strongly indicated that he will continue to push for changes in the Magnuson Moss rulemaking procedures this year.

If you have any questions about this matter, please contact Dan Jaffe (djaffe@ana.net) or Keith Scarborough (kscarborough@ana.net) in ANA’s Washington, DC office at (202) 296-1883.

http://www.ana.net/advocacy/content/2418

DMA Asks Financial Reform Conferees to Keep FTC Expansion Out of ‘Restoring American Financial Stability Act’

June 10, 2010 — The Direct Marketing Association (DMA) today was joined by 47 other trade associations and business coalitions in sending a letter to each of the conferees on H.R. 4173, the “Restoring American Financial Stability Act” (RAFSA), urging them to keep language that would dramatically expand the powers of the Federal Trade Commission (FTC) out of the final bill.

As the House and Senate conferees work to reconcile their versions of the financial regulatory legislation, the associations — which represent hundreds of thousands of US companies from a wide array of industry segments — expressed strong opposition to provisions in the House version of the bill that would expand the FTC’s rulemaking and enforcement authority over virtually every sector of the American economy.

“The balance struck in the Senate bill is the right one,” said Linda Woolley, DMA’s executive vice president, government affairs.  “That bill makes the most sense in the context of financial reform legislation, maintaining the FTC’s existing jurisdiction without expanding its rulemaking and enforcement authority over industries and sectors that had nothing to do with the financial crisis.  Issues of FTC expansion deserve their own due consideration and debate in the more appropriate context of an FTC reauthorization, as has been done in the past.”

DMA and the other associations strongly believe that granting the FTC broad new authority is not a necessary or relevant response to the causes of the recent recession and, therefore, asked the conferees to oppose the inclusion of any provisions that would expand FTC authority, rather than making changes to the Commission that would have a fundamental impact on the entire business community and the broader American economy.

For more information please visit www.dmaaction.org.
http://www.the-dma.org/cgi/dispannouncements?article=1449

Google says it’s “at the forefront of a revolution in Marketing”– that includes for the health industry.

One of the areas requiring online privacy and consumer safeguards is the health and medical area.  As CDD told the FDA, the use of behavioral data profiling & targeting, immersive multi-media techniques, social marketing [via stealth-like influencer and word-of-mouth tactics, and brand channels, such as on YouTube, raise a host of concerns.  I don’t believe one’s largely private concerns about a health condition or remedy should automatically be fodder for digital marketing.  To see how important the health online marketing is to Google (and others), here’s an excerpt from a “Consumer Packaged Goods or Healthcare Industry Marketing Manager job opening:

Google is at the forefront of a revolution in Marketing – a shift from traditional Marketing tactics to new online, mobile and social strategies. Google’s advertising platforms provide savvy advertisers with multichannel marketing opportunities, linking online marketing to brand impact and offline sales.

Consumer Packaged Goods or Healthcare Industry Marketing Manager position shapes Google’s point of view on the changing advertising landscape. This leader will uncover, understand and explain the impact of evolving online media to industries that have traditionally relied more on offline media, such as healthcare, CPG, restaurants, education and more. This is a unique opportunity to set Google marketing strategy within our Emerging Industries practice and advise Fortune 1000 advertisers on cutting edge marketing strategies. You will arm the Google salesforce with marketing programs that establish fresh thinking in the industry and deepen engagement with clients…

Responsibilities:

  • Ideate, develop, and execute marketing campaigns that drive Google’s advertising business.
  • Develop thought-leadership materials, client/executive presentations, case studies and other content designed to accelerate our business momentum and better engage Google’s customers.
  • Develop compelling positioning and messaging for Google’s advertising solutions targeted to companies in industries relatively new to online marketing, such as healthcare and CPG
  • Partner with Google’s market research team to identify, execute and package compelling market research that supports Google’s value proposition to large advertisers in these industries.
  • Evangelize Google’s value proposition, best practices and perspectives to our customers and our industry peers via events, webinars, and other direct client communications channels.