Google Exec on Behavioral Targeting: “massive benefit for advertisers” [note he didn’t call it “Preference” Marketing!

Online industry reaction to the Wall Street Journal privacy series, and generally, illustrate a basic disconnect in how they view the privacy concerns raised by digital profiling, tracking and targeting.  Leading online marketers frequently claim that behavioral targeting and related data-focused techniques are actually good for the consumer.  The problem, they argue, is that consumers lack basic information about the process.  Presumably, they believe, if we really understood how it worked, we would be relieved.  In truth, of course, the opposite is true.  The more one knows about the processes underlying what the online ad industry claims is a digital marketing “ecosystem,” the more a consumer and citizen should be alarmed.

In the UK, EU and in the U.S., companies like Google and Microsoft are working together on PR campaigns to convince both the public and policymakers all is well with behavioral profiling for marketing.  One Google executive in the UK recently told New Media Age that “The use of behavioural targeting is growing and is a massive benefit for advertisers wishing to serve more relevant ads. It also helps pay for content and services. But there is user confusion about how it works…Lack of understanding is the biggest problem facing behavioural targeting in the UK. There’s a knowledge gap between those who work in the industry and are familiar with terms such as cookies, remarketing and aggregated data, and users who search the web for information and goods. It’s our job, along with the rest of industry, to inform those users about how online advertising works and the choices they have.” 

But in reality, the industry–including Google–has failed to be candid with consumers and policymakers about all the data collection practices that are deployedsuch as by Google subsidiaries Doubleclick, Admob, & Teracent, for example.

Microsoft is also very bullish about behavioral targeting–especially since it’s in a global digital fight with Google to deliver data-enriched ad targeting for the biggest brands.  In the same New Media Age issue [22 July 2010], Zuzanna Gierlinska, head of Microsoft Media Network at Microsoft Advertising explains that:  “We’re not saying you should use targeting – whether that’s behavioural targeting or re-messaging – just to push conversion.  But it can have a strong brand uplift. People come into a channel, see a nice creative with high-impact imagery and then go away. But that message stays with them.”  The article goes on to explain that: It’s this ability to talk to people on an ongoing basis, and give them a better experience, that’s the key to why combining re-messaging and behavioural targeting with a standard brand buy works, argues Gierlinska. For example, with re-messaging, users are already a warm lead, while behavioural targeting tightens the focus on users who are demonstrating an interest… This positive experience benefits both conversion and brand uplift among the target audience. “Targeting benefits everyone,” Gierlinska says. “It benefits the publisher because it’s not wasting impressions or serving ads to just anyone. It benefits the advertiser because it has efficiencies with its media buy. But it’s also really beneficial to the users because they’re getting relevant messaging that’s timely and ideally helping their productivity in what they’re doing online, rather than just being served random messages.”

Much of how the industry addresses the behavioral targeting and its related data mining application are rationalizations [maybe all their therapists are on vacation or Freudians!  Just kidding].  But it reflects a failure by industry leaders to recognize a serious problem that affects the public.  That’s the same kind of `it’s all good for us, regardless of what we do’ behavior that led to the recent–and ongoing–global financial collapse.

Teens and Online Privacy: Empowering Adolescents to Control How Online Marketers Can Stealithily Target Them and Collect Data

Some commentators–and groups funded by online marketers that target teens–are worried that proposals to the FTC and Congress that adolescent privacy be protected will somehow create a system that requires forms of age verification online.  The coalition of leading consumer, child advocacy, health and privacy organizations filing comments at the FTC last week aren’t calling for the parental permission paradigm used by the Children’s Online Privacy Protection Act [COPPA] be extended to teens.  But there are many online commercial services specifically targeting adolescents–that’s their target market.  It’s those sites and services specifically focused on adolescents that we want to have better privacy safeguards.   We want those sites to be governed by an opt-in regime that gives teen users meaningful control of how their information is collected and utilized.  Those sites should be required to engage in the Fair Information Principles known as  “data use minimization.”  Commercial sites targeting adolescents should make its data collection practices fully transparent and under the control by the teen (including a truly accessible privacy policy).  In another words, a privacy safeguard regime that really should be available for everyone.  Teens are ‘ground zero’ for much of digital marketing–for examples see our site: www.digitalads.org [especially the update section].  If you look at the reports on that site, you will see that the most recent scholarly thinking is that brain development in adolescents occurs much later than what was once thought.  They don’t have the ability to effectively understand the intent of highly sophisticated interactive marketing and the corresponding data collection which underlies contemporary digital advertising. That’s why empowering them so they can protect their privacy strengthens their rights.

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.

Online ad research done by Profs. Goldfarb and Tucker: fails to address how online marketing really works– and also its implications for privacy, consumer protection and civil liberties

Whenever an industry is in political trouble, there is usually research made public that supports its position.  Often, the research is actually funded by the very companies or trade associations involved in the political fight.  The new paper “Privacy Regulation and Online Advertising” just released by Professor Avi Goldfarb [U of Tornoto] and Catherine E. Tucker [MIT], appears designed to discourage Congressional and FTC policymakers from enacting privacy safeguards.  In this case, according to the authors, the paper wasn’t funded by industry.  But in response to my question, Professor Tucker explained that “we have received funding in the past (for other work on internet advertising) from the NET Institute and from a Google/WPP Marketing Research Award. Avi has also received funding Bell Canada.“  The Net Institute’s board, btw, includes employees of Microsoft and Google, among others.

The new report is already being touted as evidence of the cost to online marketers if privacy rules are enacted.  But the study is very problematic–and I believe fails to really analyze how online marketing works.  The authors examined the impact of privacy rules in the EU and claim they have negatively impacted the effectiveness of online ads.  But by only examining banner ads, they miss the point.  Online marketing in both the EU, U.S., and elsewhere is really an integrated system involving an array of applications and techniques [where data is collected and used at all points]–from viral, to online video, social media, neuromarketing, games, mobile, etc.  Indeed, at our CDD we follow the EU market very closely–including collecting data from EU based online marketers, trade associations, case studies, etc.  These reports indicate tremendous success for online ads (and ironically, much of the innovation for online marketing comes out of the UK;  Admap just reported it’s the German marketers in the forefront of neuromarketing).

Given the study’s discussion of the Boucher bill, it’s clear there is a political motivation here.  But the main fault is how the study misses the key questions and ignores how the market really works.  This paper needs to be revised and gets an incomplete!

PS:  Btw, I also told the authors that Leslie Harris of CDT is a woman.  They had her as Mr. Harris.  Perhaps they also need a better fact-checker.

Google to Host Online Ad Lobby as it Campaigns Against Privacy bill

Google is going to help the interactive ad lobby in its campaign to undermine privacy legislation.  The Interactive Advertising Bureau (IAB) plans a DC lobbying blitz on June 14-15, bringing in its cadre of small publishers.   As the IAB explains, “our day of advocacy gets underway as you divide up into teams for individual meetings with members of Congress and their staffs. Each team will be assigned a “chaperone” to help you make your way around the Hill, as well as answer any questions you might have.”

The message the IAB reps will make will undoubtedly be that the Internet way of life as we know it will end if Rep. Boucher’s proposal–or most any other bill protecting privacy–is enacted.  Sort of the Internet meets the film 2012:  all that will be left, if the data stops flowing for targeting, will be a handful of digital survivors.  Google, which serves on the executive committee of the IAB board [along with Microsoft, NBCU, Disney, CBS], plays a key role in the lobbying plans.  The small publisher/lobbyists are to be “guests of honor at a special networking reception and dinner at the Google offices in Washington, D.C.”  Presumably, at the “Cocktail Reception & Dinner – Courtesy of Google,” the troops will be rallied to the `defeat the privacy bill’ cause.  A guest speaker at Google HQ for the event is the IAB CEO Randall Rothenberg.

I know Google uses its facilities to host many meetings;  I have had lunch there and a dinner once at events where Google was discussing its data collection practices.  But Google claims to want to see meaningful national privacy legislation.  Yet they are aiding and abetting the anti-online privacy lobby (which is also leading the effort to undermine the FTC’s role in consumer protection).  The irony here is that Google appears to have successfully convinced Mr. Boucher that its ad preference manager system should be the basis for a safe harbor in the bill.  But Google likely wants to facilitate weakening even Mr. Boucher’s proposal–hence the dinner, drinks and cheer leading that will no doubt be heard across to Capital Hill next month.

Interactive Ad lobby Gives $ to Lawmakers to head-off consumer privacy safeguards….The Google connection

The ever intrepid reporter Kate Kaye from Clickz has reported the following [excerpt]:

The Interactive Advertising Bureau is putting its PAC money where its mouth is – again. As part of its ongoing efforts to influence key lawmakers, the lobbying arm of the online ad industry’s largest membership organization gave Congressman John Dingell, an influential member of the House Energy and Commerce Committee, $1,000 last month. Among the messages the IAB hopes to get across to legislators: behavioral targeting is so pervasive, even their own election campaigns probably use it….

Other recent fundraising events for the congressman include an annual pheasant shoot held in Boonsboro, MD.

“It doesn’t hurt that Google also has a major office in his congressional district,” added Zaneis. Dingell represents Michigan’s 15th district, home to Google’s Ann Arbor office, which coincidentally houses Google’s political ad sales team…The IAB PAC contributed to Boucher’s reelection campaign in 2009, and to other House Internet Subcommittee members including Mike Rogers and John Shimkus.

IAB Lobby Gives to Lawmaker to Influence Behavioral Ad Policy.  Kate Kaye, ClickZ, Apr 22, 2010

Google & WPP Fund Academics to Help Expand Online Marketing Clout, including data collection

When drug companies fund pharmaceutical research at universities, questions on conflict and ethical behavior are raised.  So too when online marketers fund academic research designed to help Google and the largest advertisers better understand “how online media influences consumer behavior, attitudes and decision making.” Here are the new grants Google and ad giant WPP gave to 11 research projects:

  1. Michael Smith and Rahul Telang, Carnegie Mellon: Channels and Conflict: Efficient Marketing Strategies for Internet Digital Distribution Channels.
  2. Chrysanthos Dellarocas, Boston University and William Rand, University of Maryland: Media, Aggregators and the Link Economy: An Analytical and Empirical Examination of the Future of Content.
  3. Anita Elberse, Harvard University and Kenneth Wilbur, Duke University: What Is The Right Mix Between Offline And Online Advertising? A Study Of The Entertainment Industry.
  4. Arun Sundararajan, NYU and Gal Oestreicher-Singer, Tel Aviv University: The Breadth Of Contagion Of The Oprah Effect: Measuring The Impact Of Offline Media Events On Online Sales.
  5. Yakov Bart, Miklos Sarvary, Andrew Stephen, INSEAD: Consumer Responses To Mobile Location-Based Advertising.
  6. V Kumar, Vikram Bhaskaran and Rohan Mirchandani, Georgia State University: Measuring the Total Value of a Customer through Own Purchases and Word of Mouth Referrals: A Field Study in India.
  7. Alan Montgomery and Kinshuk Jerath, Carnegie Mellon: Predicting Purchase Conversion From Keyword Search Using Associative Networks.
  8. Shawndra Hill, University of Pennsylvania and Anand Venkataraman, 33Across: Collective Inference For Social Network-Based Online Advertising.
  9. Anindya Ghose, NYU: Modeling The Dynamics Of Consumer Behavior In Mobile Advertising And Mobile Social Networks.
  10. Jane Raymond, Bangor University: The Importance Of Relevance: Cognitive Science Research On Distraction By Advertisement On The Internet.
  11. Koen Pauwels, Dartmouth, Oliver Rutz, Yale, Shuba Srinivasan, Boston University and Randolph Bucklin, UCLA: Are Audience-Based Online Metrics Leading Indicators Of Brand Performance?  …
    Clients of WPP and Google may volunteer to provide case studies and data for research being conducted by award recipients. The specific study topics will dictate which clients and client data will be of most value to the research. The Program Committee will assist in identifying the most beneficial client contributions. The program sponsors (WPP & Google) will engage clients to solicit and secure their involvement.

Google Paper on “Opt-in Dystopias”: Doesn’t Reflect What Google Actually is doing with data

The Google Policy blog promoted a paper by two Google employees on the opt-in/opt-out policy debate.  The paper is worth reading, but its use is limited because it doesn’t reflect the actual online marketing data collection process.  Here’s what I just wrote on the Google site:

The authors need to revise their paper based on the goals and actual practices with online marketing and data collection done by Google and its affiliates. While it’s true that the binary opt-in, opt-out debate is unfortunately narrow, it is used to address far-reaching data collection and targeting strategies implemented by Google and other online marketers. The authors, for example, should examine Google’s use of neuromarketing for its YouTube advertising products; or the role of purposefully developed “immersive” multimedia tied to data collection by DoubleClick. They should analyze Google’s advertising goals, including what it promises to the largest pharmaceutical and financial advertisers, for example. Or examine the growing role of merging offline and online data collection tied to a specific user cookie to be auctioned off that is now routinely used in online ad exchanges (Google owns one such exchange). They should also reflect on how Google–when rushing to catch up with Facebook in the social media marketing business–launched its Buzz product without a careful analysis of its impact on data collection. Google’s researchers on privacy, in other words, would be more credible if they carefully analyzed how their own company uses–and plans to use–data. This issue deserves a robust debate–and we know the authors are sincere in their interest to make an important contribution. But they should also have been candid that Google is fighting off policy proposals from privacy advocates that would empower a user/citizen by allowing them to protect their privacy–including using opt-in.  The failure to have global policies that protect privacy is the high social and political cost the public should not have to bear.