The Online Ad industry Must Respect & Protect Adolescent Privacy

Last week, a coalition of child advocacy, health and media groups asked the FTC to develop safeguards for digital marketing that would protect adolescent privacy online. This will be a major focus of the Center for Digital Democracy over the next year or so, building on our work during the 1990’s which led to the passage of the Children’s Online Privacy Protection Act (COPPA). COPPA helps protect the privacy of children under 13 years of age. Adolescents are now a principal focus of the online data collection and targeting system, a process which raises many ethical and health-related issues. We call on responsible online ad industry leaders to work with us to enact meaningful policies that protect adolescent privacy on websites, social networks, online gaming, etc. We are pleased that some major online ad companies have privately said to us that they recognize there is a problem. We will work with them and other responsible digital marketers. Policymakers from both congress and the FTC also recognize adolescent privacy is an important concern. It is a bi-partisan one as well (Senator John McCain was the co-sponsor of COPPA). The time to develop a meaningful framework that respects the autonomy of adolescents, but protects their privacy, is now

Former journalist and now online ad industry lobbyist Randall Rothenberg, in a BusinessWeek commentary, suggests that the call for privacy rules ensuring individuals have control over their data will undermine the Internet. You would think a Madison Ave. trade group could craft more creative PR copy. But the online ad industry’s position is indefensible, since they built a system based on the harvesting of our information without believing they would need to get our permission first. The IAB board should realize it has embarked on a very dangerous campaign here that will undermine credibility for many marketers. Here’s my response submitted to BusinessWeek:
Mr. Rothenberg, as head of the interactive ad trade group lobbying against the call from consumer groups for the government to protect personal privacy online, fails to address the central question regarding online advertising. The call for regulation is designed to ensure individuals control their data while on the Internet or using their mobile phones—not companies such as Google, Microsoft, and AOL. Public interest groups are not opposed to interactive marketing: indeed, we recognize it as a key source of funds for online publishing. But Mr. Rothenberg’s members have created a commercial surveillance system that rivals the NSA—tracking and analyzing our every move while on the Internet, all so we can be encouraged to behave favorably to some marketing message. Responsible ad industry leaders will seriously address the privacy threats created by the interactive marketing apparatus—and not hide behind self-serving claims that unless our privacy is lost, we won’t have a robust digital medium.

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24/7 Real Media working with data miner Claritas for “Lifecycle Media Management” targeting

excerpt from Ad Age: “24/7 Real Media …[W]e offer the most advanced targeting options…Using our Lifecycle Media Management approach, we work with you to determine where your customers are in the lifecycle and then strategically apply the most effective targeting techniques for your needs. Beyond standard content and behavioral targeting, we have compelling targeting techniques involving online and offline consumer research.

  • Search retargeting:
    We enable marketers to target and customize display advertising based on users’ keyword queries on search engines. This allows advertisers to reach and convert the particular customers who are truly interested in their offerings.
  • Geo-demographic targeting:
    By partnering with consumer research expert Claritas, a Nielsen company, we can target and retarget your customers with greater efficiency by analyzing customers’ true marketing profiles, including behaviors and lifestyle, detailed demographic and behavioral data.
  • Mindset Media buys:
    Our partnership with Mindset Media makes it possible for you to target your customer based on psychographics or personality traits…

TARGETING

24/7 offers the most advanced targeting:

  • Lifecycle targeting
  • Search retargeting
  • Retargeting
  • Mindset Media buys
  • Geo-demographic targeting
  • Content channels
  • Behavioral targeting
  • Geographic targeting
  • Demographic targeting
  • Daypart targeting
  • Technographic
  • Keyword/search
  • Branded sites
  • Roadblocking
  • Custom

Attention AOL Privacy Penguins: Here’s some copy–written by Time Warner–that you should tell to users

via the Platform-A, Advertising.com multi-page ads in this week’s Ad Age:

Audience insights guide all Platform-A
solutions. Our sophisticated reporting
allows us to discover the behavioral
profile of the consumers who are most
receptive to your message. This
information helps you find target
audiences, understand their demographic,
psychographic and behavioral
characteristics and, ultimately, decide how
you craft and place your brand’s message.
NETWORK REACH
Platform-A reaches nine out of 10 online
consumers.
TARGETING
Platform-A offers a comprehensive suite
of targeting technologies, including:
Demographic
• Age/gender/household income
• Audience affinity
• Cluster solutions
• Rosters/data match
Contextual
• Via content networks and
sponsorships
Geographic
• Data targeting, destination-based
and regional content
Daypart
Behavioral
Vertical
…Our performance
technology continually learns and refines
ad placement across our network based
on observed and expected performance.
Ads are automatically allocated across our
network based on the highest expected
return for the advertiser and publisher.
We also optimize advertising based on
the behavioral interests that resonate
with an advertiser’s key audience.
Leveraging conversion data—anything
from newsletter sign-ups to event
registrations and online purchases—will
increase brand performance and drive
more response with less waste.”

Online marketers want to track you–from click to click to “last ad” click

Microsoft and Google, along with many partners, are working to perfect a consumer tracking and analysis system so they can better figure out who gets to share in the growing online ad revenue pie. It’s called “engagement mapping.” Although if you are concerned about privacy, you might want to say, “let’s call the whole thing off.” Here’s an excerpt from the April 14, 2008 Ad Age article:

“The concept appears simple, but the technology is complex: raw log-file data, time-stamped and collected by ad-serving companies like Google’s DoubleClick and Microsoft’s Atlas, along with a short line of code known as a pixel hidden in web pages, keep a record of each time consumers enter or exit a web page, click on a link or ad and enter information in a search box or application. Those data are fed into software platforms designed by companies such as Atlas, Epic Advertising, Media Contacts and Starcom.

“It’s sort of like reading an advertising diary,” said Ben Winkler, VP-interactive media director at New York-based Ingenuity Media Group, which joined Atlas’ project earlier this year. “It’s like you opened a diary where someone wrote, ‘I saw three billboards, I heard a radio ad, saw a few banners ads, and searched through Google to find and buy the product.’ “

Rather than wait for a crisis to tell the advertising client something isn’t working, media buyers can rely on these data to identify when consumers had contact with the ads, even if it’s an hour, day or week later.

“We know the person saw ad No. 4 on Yahoo Finance an hour ago,” said David L. Smith, CEO at Mediasmith, which is participating in Atlas’ and DoubleClick’s tests with advertisers. “Embedded code in the pixels lets us track the pages and things they interact with on the site.”

source: New metrics give `credit where due.’ Laurie Sullivan. Ad Age. April 14, 2008 [sub may be required]

Market researchers tell FTC to give them exemption for consumer data mining

Among the comments filed at the FTC for its staff privacy principles proceeding was one submitted by CMOR (the Council for Marketing and Opinion Research). CMOR, whose motto is “shielding the profession” wants the FTC to make certain that any privacy policy protecting consumers doesn’t restrain the activities of its members. A huge infrastructure of online market research has emerged–tracking our online behaviors and attitudes. The trade group offer’s an incredible self-serving defense of their practices, all so they can push the boundaries of targeted digital marketing. Here are some excerpts from CMOR’s filing:

“…much of the FTC’s specific proposals for self-regulation of online behavioral tracking could have significant negative consequences for the survey and opinion research profession, and strangle many possible new methods of research – methods that could better serve consumer choice and privacy than current methods – before they’ve even been conceived…CMOR notes that research is a multi- million driver of the private economy – and that U.S. government agencies like the FTC are, as a group, the single largest purchaser/user of research from the survey and opinion research profession. CMOR also notes that online behavioral tracking could be a form of
research particularly well-suited to the needs of non-profit entities, political activists, and for-profit businesses that are small or serve niche markets and interests. These parties have an even greater need than most to drill down to small, difficult-to-pinpoint segments of the population. Such research could have profoundly positive benefits for consumers and citizens and such public good is worth preserving…As recently stated by Josh Chasin, Chief Research Officer for the research firm ComScore, researchers must “push the limits of data mining and data base integration and artificial intelligence, in the interest of deploying information technology to meet the needs of people. At the same time, it is incumbent upon us to zealously guard the privacy of the consumers whose lives we touch, even tangentially. I do not believe these two goals are paradoxical.”

CMOR and ComScore may try to convince the FTC to somehow believe that expanding the limits of data mining research will further privacy. But much of the research is about extending the power of micro-targeting in order to create new attitudes and behaviors in individuals (inc. children and adolescents). Researchers can’t be given a free pass to push the limits of data mining in the digital era.

Microsoft-Yahoo/Google-Yahoo M&A: More data about you for targeting

excerpt from Abbey Klaassen of Ad Age’s interview with media execs, including Augustine Fou, senior VP-digital strategy at MRM Worldwide and Nathan Woodman, VP-strategic development at Havas Digital:

MR. FOU: Yahoo has a lot more personal information through its other services for which you registered. So they can cross-target with demographic information … and because Google doesn’t have similar information, Yahoo actually has better proprietary data at this point in time…

MR. KILKES: The power of optimization is that you can test all that stuff. We’ve seen that Yahoo’s registration offering leads to much more engaged audiences vs. what we have see through, say, a Google gadget. That leads us to believe that combining registration data with behavioral is just narrowing the funnel a lot more efficiently for us.”

from: So Much Info, so Much to Test Out. Ad Age. Aril 14, 2008 [sub required]

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BT Watch: Social Networks & Behavorial Targeting: “people, not pages” are tracked

excerpt from interview with Andrew Monfried, founder and CEO of Lotame Solutions]: “One of the biggest challenges is that the industry is trying to apply standard behavioral targeting techniques to the robust arena of user-generated content and social media. Emphasis is still placed on contextual relevance when, in reality, that metric doesn’t take into account true behavior and consumer interests. People are commenting, uploading, posting, viewing videos, and using widgets. The key is to leverage this data in a way that will drive performance. Contextual relevancy doesn’t capture those verbs or actions….One of the most critical things moving forward is understanding that within social media, click-through rates aren’t the most accurate measurement of success. A truly engaged user is more valuable than a click… The industry will need to embrace new ad units as well as leverage behavioral targeting as a new way to distribute content…Our technology gathers tremendous amounts of data inherent to user-generated content, and we use this to build targeted and customizable audiences as well as provide monetization solutions. For example, if a brand wants to target consumers who only like The Grateful Dead, we build that exact audience for them… Lotame allows advertisers to touch people and not pages….

Social Networking Meets Behavioral Targeting. Anna Papadopoulos. clickz. March 26, 2008

Behavioral Targeting firm has assembled “140 million active online shopper profiles”

Behavioral Targeting watch

excerpt: “Behavioral targeting is set to reach $3.8 billion by 2011…one company is claiming to be the first online network that uses consumer purchase and browsing information to determine which ads they are presented with.

“Shopping behaviors associated with a cookie on a user’s machine provide information about their interests, and continuous modeling enables us to identify large populations with similar patterns of purchase behavior,” said aCerno CEO Tom Sperry.

aCerno, a wholly owned subsidiary of database marketing firm i-behavior, reports that it has accumulated 140 million active online shopper profiles. The data can in no way be linked to an individual but instead relies on unique cookie ID numbers placed on a user’s browser.” via BizReport.

“Behold aCerno — the only predictive targeting ad network that drives transactions, propels brand metrics, finds prospects who are in-market for your product or service, and predicts what they are interested in. Your best prospects are delivered flawlessly and efficiently to you.aCerno helps marketers motivate consumers by always putting the right message before their eyes when and where they’re receptive to your message.aCerno understands and capitalizes on the symbiosis among brands, retailers and consumers. Our predictive modeling gleans vital data from this ecosystem to target messages that pique interest and prompt the consumer reaction you seek. With aCerno, online advertising unearths greater market potential by delivering predisposed prospects…aCerno creates custom audiences from this data to suit your brand’s particular needs. Whether your objective requires targeting based on pure product- and shopping-based behaviors, or on more traditional demographics and psychographics – or any combination of them all, aCerno offers unmatched flexibility in built-to-suit audience development.” from: aCerno

More on aCerno, via today’s Clickz. article [excerpt]

aCerno, has been in stealth mode for nearly four years. It collects…information from an association of over 375 major multichannel retailers’ Web sites (that aren’t identified to one another), representing 140 million shoppers. The information is completely private and tagged only with an ID…ACerno clients’ best prospects are identified with modeling and profiling techniques, finding users who look most similar to their best customers. Once these high-value prospects are recognized, aCerno uses its massive advertising network to deliver targeted advertising messages directly to them…The company’s extensive network of high-quality Web sites, publishers, and portals is targeted exclusively at the cookie level with banner ads and rich media to achieve maximum reach within the target audience. The network reaches over 95 percent of the Internet population with more than 80 percent of the impressions served into sites on comScore’s Top 500.

This is predictive analysis; scoring million of cookies against hundreds of variables to create models.”

Newspaper industry tracking user “behavior” without real disclosure, consent

quadrantOne is a consortium of 26 newspaper companies that enable advertisers to, as its release notes, “for the first time, to buy hundreds of well-established and trusted online newspaper and broadcasting sites by placing a single order.” quadrantOne [attention antitrust types!] is jointly owned by Tribune, Gannett, Hearst, and the New York Times.

On Friday, the Newspaper Association of America filed comments at the FTC arguing that the agency’s proposed privacy principles to protect consumers could be a violation of the First Amendment. But perhaps the NAA–and certainly quadrantOne and its members–can explain what the consortium means what it tells potential advertisers that they can be given “[A]ccess to sophisticated audience targeting by context, behavior and demographics.” quadrantOne has, according to its website: “Total number of unique users: Close to 50 Million.”

The newspaper industry should be scrupulously candid about all its data collection and targeting. While we support newspaper efforts to build up online ad revenues, they should do so in the most ethical manner. Embracing meaningful privacy policies that fully disclose prior to collection, and ensuring affirmative user consent, must be incorporated into our concept of liberty and freedom in the digital democracy era.