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.”

Google: Creating a “dynasty” in online data ad targeting

From the Connected Marketing Week in SF, via ClickZ:  Google is simultaneously attempting to fill the role of ad exchange, ad network, DSP (through its Invite Media acquisition), and media agency…Michael Rubenstein, president of AppNexus and the former head of Google’s ad exchange efforts, said Google has been admirably fair and transparent. But he said that could change.”Google is putting together the pieces to form a dynasty,” he said. “So far they’re behaving pretty well as far as keeping the ecosystem open to everybody, probably because they need to. But we’ll see what happens over time as they accumulate more market power.”

Google’s Mobile Ad Plans–A Key Reason Why No Net Neutrality for Wireless [Follow the Mobile Ad $$$]

Just a quick reminder to network neutrality supporters that Google has made a multi-billion dollar investment in its ability to deliver mobile ads.  That’s a key reason for its “let’s make a digital deal” with Verizon.  For example, in 2007 Google acquired  Doubleclick:“DoubleClick Mobile is an ad delivery system for mobile websites that delivers dynamic, interactive ads to mobile web pages based on specific criteria as determined by you. It supports a wide range of devices and boasts a full management and reporting suite. Now publishers can deploy mobile advertising with the same confidence and control as online display ads…DoubleClick Mobile enables you to manage and report on your mobile advertising campaign through every click. We’ve made it easy to set campaign dates, define mobile specific targeting criteria and get full reports on all mobile campaigns…records information on third-party destination sites…DoubleClick Mobile features support for a variety of ad networks to enable you to sell more of your inventory and maximize possible yield…”

This year Google acquired Admob:  “AdMob offers brand advertisers the ability to reach the addressable mobile audiences. Our innovative ad units will carry your brand messaging onto the top mobile sites. As one of the leading brand mobile advertising marketplaces, we have the products and the people to help you meet your campaign needs…Mobile advertising provides you with targeted access to mobile users, and is easy to buy and measure…AdMob stores and analyzes data from each ad request to serve the most relevant ad possible. AdMob Mobile Metrics offers a snapshot of this data to provide insight into trends in the mobile ecosystem.”

And don’t forget Google Adsense for mobile:  “AdSense for Mobile helps you earn money by displaying relevant Google ads alongside your mobile web pages or within your mobile applications.”  Or YouTube Mobile.

PS:  eMarketer got it right.  The Google/Verizon deal is about preserving mobile as a controlled digital territory: “By 2014, eMarketer expects the number of mobile internet users in the US to reach 142 million, a near tripling of 2008 levels. The total pool of internet users, which includes mobile and wired access, will increase over the same time period from 203 million to 250 million. By 2013, more than half of all US internet users will be accessing the web through a mobile network, either alone or in addition to wired usage.”

Online Ad Lobby Raising $1 Million to Help Fight Against Privacy Safeguards

The Interactive Ad Bureau [Google, CBS, Comcast, NBC, Facebook, Fox, Microsoft, BlogHer and many others] is fundraising to “undertake additional coordinated advocacy at the Federal and state level. IAB is nearly half-way to our goal of raising $1 million in cash…”  Funds will be used to support a campaign that includes “our ongoing advocacy efforts to combat legislation and regulation that could damage the interactive advertising industry.”  IAB calls this its “Consumer Protection and Education Campaign,” because it also includes a goal of a billion online ads (to be donated by marketers) used to “support consumer and business understanding and appreciation of the interactive advertising industry.”

We are sure that there will be many–such as the growing interest of the news media in the issuethat will follow this special interest money–especially as the Congress and FTC focus on protecting consumers online.

Online Advertising and News: How HuffPost Worked with GE

An excerpt from Ad Age’s interview [June 30, 2010] with Greg Coleman, Pres. of Huffington Post.  Coleman described the online news site as a “social media company,” able to “help our marketers beam their messages throughout the internet, across the galaxy, the internet, and the world.”  One of their advertisers is GE.:

Ad Age: Can you give me an example of Huffington Post’s view on social advertising?

Mr. Coleman: One example is a terrific project we did with General Electric, where GE has this whole campaign on “healthymagination.” We allowed them to run advertising on anything tagged “wellness” across our site — they were looking for positive health information. We then created a special share bar for GE, and any time you tweeted that article or retweeted that article or shared it, the ad module would go with it. So when you shared it with your friends on Facebook, the GE ad module would go there. When you retweeted it, [you’d get] the hashtag “GE healthymagination.” … We’re trying to come up with the real metrics, but we believe that the reach of the campaign is far greater off of our site, as a result of the social tools on our site.

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

Location Privacy for Mobile Marketing: Time for Congress/FTC/States to Protect Consumers

Last year, CDD and USPIRG filed a complaint on mobile marketing, privacy and deceptive practices at the FTC.  We know that it woke up the commission to the issue–but they are acting too slow.  The recent decision by Apple to expand its data gathering for location ad targeting on the iPhone (and do a about-face on the privacy issue, really) is just one example of why safeguards are required immediately.  As Mobile Marketer explained in an article about what Apple is doing:

“Location is an important element that illustrates the promise of mobile and social,” he said. “Look at the way that the mobile environment is developing—proximity marketing is really the direction that we’re headed [Noah Elkin, senior analyst at eMarketer].

“Being able to marry data about a user’s location and data about a user’s likes and dislikes—being able to present a relevant offer—raises the bar in terms of the relevancy of the advertising messages.”…Apple acquired Placebase and Quattro recently, which gives it a mapping platform and an ad network.

“Collecting user positioning data is the next necessary ingredient for ‘location intelligence,’ which will bridge the gap between these two acquisitions and enable them to deliver a really relevant experience based on place and time,” Mr. Goodman said [Alistair Goodman, CEO of 1020 Placecast].

Meanwhile, companies like Loopt that merge social and mobile marketing techniques are extending how they target consumers, inc. data collection.  Loopt explains in its new “mobile rewards” service for marketers that:

Loopt Star offers retailers a virtual loyalty card, allowing them to connect directly with their customers when they’re out and about, driving foot traffic and encouraging repeat visits. It offers retailers and businesses a unique “cost per visit” business model.

“Hyper-local advertising should be about much more than simply clicking on a banner ad—it should be about connecting with brands and getting rewarded for loyalty. Brands want to turn their existing customers into better ones,” said Sam Altman, co-founder and CEO of Loopt. “Loopt Star enables brands to create customized campaigns that reach their customers in a completely targeted, interactive way that rewards the behaviors they want.”

In addition to brand-specific customized rewards, Loopt Star will also allow the person with the most check-ins at a specific place to become the “Boss” of that location. Leaderboards allow users to compete with their Facebook friends to for the most check in points. Dozens of hidden Achievements will also be available to Loopt Star game players at launch — to be won when certain check-in actions are performed.

Loopt Star adds a key social component by being the first mobile location App based purely on Facebook Connect. Users can share their current location in real-time with all of their friends on Facebook, and alert friends via their Facebook News Feed about special offers they see on Loopt Star that are available to anyone. With its close integration into Facebook, Loopt Star allows Facebook friends stay up to date on where friends are and what they’re doing…

Brands can use Loopt Star to create fun, engaging campaigns that deliver foot traffic, connect with customers, build a strong community and increase their Facebook fan base. Customized brand campaigns can specify:

  • The qualifying retail locations
  • The qualifying time of day, day of week, or time span
  • The qualifying number of check in times
  • Whether they need to check in with friends, and the number of friends
  • Which rewards are available to friends through the Facebook newsfeed (for example, “the next person to check into Joe’s Restaurant today gets free dessert” can appear on the newsfeed to all Facebook friends.)
  • Specific and virtual rewards, such as Achievements, special titles, discount coupons, etc. Special titles allow retailers to offer a custom “Boss” title and graphic to the person who checks in the most at an individual location

Loopt is working directly with top brands to customize all aspects of Loopt Star, from the activity needed to earn the reward, to the type of virtual or real-world reward earned.

For example, Loopt Star users can check into any bar in the United States with two Facebook friends, and everyone instantly earns five free songs from leading popular music recording artists. (To see the songs available to win, go to http://www.amplified.com/loopt.)

 

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.

Facebook: Ads, Data, and Dollars–its revenue comes from targeting “on users’ real life data”

Facebook execs frequently claim they don’t share their users personal information with advertisers.  They also always add that Facebook isn’t really that interested in advertising revenues.  But that’s not correct, as the Facebook Quarterly Business Review: Q1 2010 reflects.  Facebook, now cash positive, was said to earn somewhere between $600-700 million in revenues last year–up dramatically from the $150 million generated in 2007. The Quarterly estimates that Facebook should earn over $1 billion in 2010.  How?  “By growing multiple revenue sources, mostly around advertising,” it explains. Facebook is expected to earn some $350 million alone in 2010 from selling its ad services to big brands, with more growth expected.  In the last year, Facebook has “invested heavily in expanding its brand advertising efforts by opening up offices in Paris, Madrid, Milan, Hamburg, Sydney, Stockholm, Toronto and Los Angeles.”  The report says that Facebook will eventually earn some $20 billion a year, with a huge increase coming from big brand advertisers.

So-called performance advertising on Facebook [from social games, for example] is expected to bring in between $500-600 million this year.  There will also be additional revenues from Facebook’s virtual currency [and soon from mobile and location based marketing as well].

Facebook’s users aren’t informed about the datamining that occurs on what they post and communicate, including to their social networks.  We believe these systems require transparency and mechanisms of user control. And FTC and Congressional action.

Boucher/Stearns Privacy Bill: Fails to Ensure Data Collection Minimization and Forces Consumers to rely on Digital ‘fine’ Print

Yesterday, Reps. Rich Boucher and Clifford Stearns released a “discussion” draft for what they intend to become a new law addressing privacy online.  Mr. Boucher, whom I and a number of consumer and privacy representatives met with in March, is sincere in his desire to address online privacy.  But the bill’s overall orientation maintain (and really nurtures) the intense and pervasive data collection, online profiling, and targeting status quo.  Instead of focusing the goal of the bill on data minimization, a important Fair Information Principle, it really enables the maximization of information collection on consumers.

The bill does make several important contributions, including acknowledging that racial/ethnic and sexual orientation must be considered  “sensitive” information requiring higher safeguards [I played a role in urging Congressional leaders to include racial/ethnic data in the sensitive category].  By acknowledging that a “unique persistent identifier” should be classified as personal information, the draft bill follows what policymakers in the EU have crafted (and the FTC staff has already largely suggested).

But by primarily relying on so-called “notice and choice”–namely privacy policies–the bill fails to protect online users.  There is a growing consensus, backed by research, that privacy policies are inadequate.  The reliance by Mr. Boucher on Google’s ad preference manager system, which allows users to opt-out of more specific ad targeting categories, doesn’t address the key question:  how can we ensure less information is collected and used about each of us.  Nor does the bill protect sensitive information involving health and finance, where it permits a huge loophole that will continue online data practices involving our interactions online with financial and health related sites and services].  Adolescents are left unprotected in the bill–one of its most glaring omissions.

The bill doesn’t really empower the FTC to act effectively in this area, in our opinion.  Under the Boucher/Stearns bill, consumers will still have to rely on digital fine print–written in invisible ink–to protect privacy.  This is not a debate on ensuring online ad revenues for free content–we all support that.  It’s about defining reasonable rules of the online road that balances citizen and consumer rights with the interests of those who collect our data–whether they be commercial or government.