Category: interactive advertising

Mobile Privacy & Marketing Watch: Protecting Hispanics

One of the areas my group and USPIRG asked the Federal Trade Commission to address in our complaint filed this week was mobile marketing to Hispanic-Americans.  An entire marketing infrastructure has evolved to target this important group; many questions remain about what they are being offered and how the mobile marketing has been structured. As Media Post explained yesterday in an article on the Hispanic mobile market: “…because they lag behind the general population for Internet access, many will first go online via their cell phones. In fact, they significantly over-index when consuming mobile content. According to comScore m:metrics, 71% of Hispanics consume content on cell phones compared to the market average of 48%. In addition, Hispanics tend to notice and respond well to ads on cell phones. Nielsen’s recent “Mobile Advertising Report” highlighted that Hispanic data users are more likely to recall seeing ads on mobile phones (41% compared with 30% of non-Hispanics) and more likely to have responded (22% vs. 13%).”

One mobile marketing company that is now also focused on the Hispanic market promises potential advertisers that it “utilizes advanced profiling capabilities that are inherent to the platform’s automated learning engine – meaning that the platform learns from previous customer interactions to automatically and organically build up profiles of users and their individual preferences. Each subsequent campaign is then automatically optimized (no human interaction is required!) in order to deliver the most personalized message possible that is based 100% on the user’s profile.”

We are not opposed to mobile marketing.  But systems of data collection, profiling, and targeting must be transparent, disclosed, and controllable (a real opt-in) by the users.

Google, YouTube, and DoubleClick Cookies Placed on Users of YouTube’s new Congress Channels, Says Computer Scientist

Columbia U computer professor Steven M. Bellovin has an important post on the privacy issues raised by YouTube’s new House and Senate channels.  He writes [excerpt, our emphasis] that:

“I opened a fresh web browser, with no cookies stored, and went directly to the House site. Just from that page, I ended up with cookies from YouTube, Google, and DoubleClick, another Google subsidiary. Why should Google know which members of Congress I’m interested in? Do they plan to correlate political viewing preferences with, say, searches I do on guns, hybrid cars, religion, privacy, etc.?

The incoming executive branch has made the same mistake: President-Elect Obama’s videos on Change.gov are also hosted on (among others) YouTube. Nor does the privacy policy say anything at all about 3rd-party cookies.”

Video channels providing the public access to members of Congress and the new Administration should be in the forefront of privacy protection-and not serve as a data collection shill for any company.  Nor should one company be permitted to shape broadband video access to federal officials.

Google Lobbying: Why Congress Should Not Use the new YouTube Senate and House Video Hubs

Google is taking a lobbying tactic developed in part by CSPAN years ago–offer members of Congress a free service so they can be seen by the public.  That kind of electronic or digital campaign contribution helps insure that Congress will think twice about biting (or regulating) the video hand that feeds.  Google’s new YouTube Senate and House Hub channels raise a number of concerns and policy questions.

For example, what happens to the user data as people click on the Congressional YouTube channels?  Does Google get to collect, analyze and use such data for its growing political online advertising business?  Beyond privacy, should Congress be endorsing a private for-profit venture as the principal access point voters and constituents need to use?  Does the use of YouTube create a potential conflict of interest for members of Congress who will need to regulate Google–on such things as competition (the DoJ recently described Google as a monopoly); privacy, consumer protection, etc (remember, Google sells all kinds of ads for mortgages, credit cards, junk food, health remedies, etc.).

It’s not a coincidence perhaps that Google’s YouTube congressional channel announcement comes at the same time the company is expanding its online ad business for politics.  As Ad Age reports this week,“The end of an election season usually means dismantling the campaign apparatus until the next cycle. But not at Google; not this year…Rather than packing it all away until 2010, it’s hoping to build a year-round political-advertising business one House seat and hot-button issue at a time.  “There are 500,000 elected officials in the U.S. With the advances we’ve made in geo-targeting, we think this will be part of every political campaign in the country, as well as issue campaigns,” said Peter Greenberger, Google’s director of election and issue advocacy…Google doesn’t yet offer targeting based on congressional districts, but with ZIP code and city targeting, politicians and advocacy groups can cobble together a reasonable approximation of a congressional district.”

The in-coming Obama Administration has had the support of Google’s CEO, and company officials have played a role in the transition.  But the new administration should develop a digital outreach approach to the public which is public–and non-commercial–in nature.  It shouldn’t show any favoritism, even if Google is the leading search and video service.  It should be a change.org--not a government via dot com.

see: “Election  is Over, but Google Still Chasing Political Spending.”  Michael Learmonth.  Advertising Age.  January 12, 2009.

Ad agency has “profiled more than one-third of the world’s online population”

Developments in advertising, data collection, consumer analysis and targeting must be transparent and accountable to the public.  In a profile of Havas Digital, OMMA Magazine notes that [our emphasis]:

“Havas has created a dynamic online ad trading system that separates audiences from publishing content, and it makes user profile and unique cookie data king, rather than the inventory a publisher serves.  The core of Havas Digital’s virtual brand network is its Artemis database management and reporting system, which has already profiled more than one-third of the world’s online population. That and the agency’s Adnetik system help deliver customized roi analytics for media buying.”  “Artemis is the central piece of our media buying offering,” Kasper [Adam Kaspar, a senior VP] says. “Its importance has only grown as the technology has improved.”Coupled with proprietary algorithms, that database has allowed the agency to develop systems that draw on data from third parties, including clients, publishers and networks, that helps it understand which audiences command the most value at a particular time for specific brands.”

Artemis is a “marketing data warehouse.”  Yahoo is using the service, including for its already data-enabled Right Media Exchange.  Havas describes Artemis as “our proprietary marketing decision support system – a secure warehouse for all your marketing data, plus reporting tools that help make sense of it all.  Unlike some of the less sophisticated reports advertisers may receive from ad-servers, for instance, Artemis® provides detailed reporting right down to the user level.”

The FTC, EU, Congress and others will need to need to investigate the growing role consumer data plays in targeting us on and offline.  We don’t need private ministries of information tracking the global public.

Google Helps Sell Pizza for Papa John’s, Pizza Hut, and Domino’s

Google does many important things.  But it’s an ad company, including helping these three companies build their direct selling online.  Here’s an excerpt from the trade publication QSR:

“We’ve been working with the big three pizza companies over the last three to four years to develop online ordering, and it has become a significant sales engine for them,” says Sam Sebastian, director of local and business-to-business markets at search engine giant Google. “It’s such a competitive space.”

Online ordering typically accounts for anywhere from five to 20 percent of a national pizza chain’s business, Sebastian says. To entice customers to use their service over that of the competition, chains are turning to online search advertising, banner and click-through ads placed on Web sites, and social media sites such as YouTube, Facebook, and MySpace.

So far, online search advertising, whereby a company buys ad space that will appear when a user types a keyword or phrase (“New York City pizza”, for example) into a search engine, has made up the largest portion of media spending online.

…”It’s a direct connection, direct response,” Sebastian says….

Web sites across Google’s content network partner with the company to syndicate advertisements, and Google works with individual web sites and companies to broker advertising.

“If I know my customers are on … any web site where in the content there is a discussion about pizza, I can place my advertising there so it’s available contextually,” Sebastian says.

Papa John’s recently launched its first foray into advertising on the Google Content Network with a one-day blitz of display ads on various sites including MySpace, and restaurant and menu guide site MenuPages.com.

The flash display ads promoted an offer of one free medium cheese pizza with any online pizza purchase for customers who signed up to receive e-mail offers…

Get Set, Ready, Regulate!: Online Marketing and Data Collection in 2009-2010 [see how everyone “owns” your data except you!]

New Year, new Administration and Congress.  Plus a growing global concern from policymakers, advocates and citizens about data collection online.  Even the relatively feckless Federal Trade Commission will do more on the issue this year. Here’s a toast to hope for a honest discussion about the data collection and targeting system which embodies the online marketing apparatus.  Look at this excerpt from a story on behavioral targeting and online publishing from this week’s Advertising Age.  Note that everyone believes that can collect and use the data collected from observing an individuals’ behavior–and don’t even have to get permission from the actual person.  Such online marketing practices, of course, raise important civil liberties issues, as far as I’m concerned.

Here’s the excerpt:  “…Who created the customer and who owns the data generated by a visit or a sale? “Data is key; everybody wants to own it, everybody wants to use it. It’s not just ad networks — its portals, publishers and holding companies,” said Mike Cassidy, CEO of Undertone Networks. “The question to be answered is who owns the data, if anybody.” In the offline world, publishers market their own subscriber lists. But online that data is harvested by a host of third parties such as Google’s DoubleClick, Microsoft’s Atlas and vast ad networks such as Platform A’s Advertising.com. “People are stealing from the media companies who have lost control of their data,” said Operative CEO Mike Leo….Here’s how it works: A publisher decides to allow an ad network to sell some of its inventory. That network places a cookie on the publisher’s site. Now, when a user leaves that site, and goes somewhere else, the network can track that user.”

source:  “As Tracking Proliferates, Web Publishers are Left Out: Behavioral Targeting Punishes Producers of Original Content.”  Michael Learmouth.  Advertising Age.  January 5, 2009 [sub may be required].

CDD Memo to President-elect Obama’s FTC Transition team

My organization provided the FTC-transition team of President-elect Obama a brief memo on what the agency should do as it changes leadership. With a new majority, the FTC should be in the forefront of addressing how the financial and marketing system has evolved in ways which threaten our fiscal well-being and privacy, among many other concerns.  Here’s an excerpt:

The Federal Trade Commission has a potentially extraordinary role to play in the new Administration.  The agency should be engaged in developing and promoting policies that protect privacy, ensure consumer welfare, and stimulate economic development.  Unfortunately, in recent years the commission has largely failed to comprehend the threats to consumer privacy arising from the data collection-based online marketing system.  It ignored, for example, the role that data collection and behavioral targeting played in the marketing of subprime loans and other consumer financial products…
Under new leadership, the FTC should view its role as a champion of consumers…. in consumer protection, privacy, and online-related competition policy, the agency has failed to conduct the kind of serious inquiry that would enable it to make sophisticated recommendations or decisions.  It has not developed a 21st century framework that will protect consumers in the digital marketing “ecosystem.”  We saw this with behavioral advertising and privacy policy, protecting children and youth from marketing linked to the obesity crisis, and in the approval of the Google and DoubleClick merger, for example.
If the FTC is to help the country move forward during this crucial period of economic transition, it should:
•    Make Consumer Protection its highest priority
•    Recruit new staff for consumer protection with a background and commitment to consumer interests
•    Engage in a serious and ongoing analysis of the digital marketplace, with a focus on the impact of interactive advertising/behavioral targeting on financial products, health and medical services, product purchasing, and children and adolescents
•    Propose new policies to protect consumer privacy and welfare online…
•    Work with the FCC and state authorities to create a new Mobile Marketing, Consumer Protection, and Privacy Task Force (with annual reports to the public, and, where appropriate, new legislation recommended to Congress).

Behavorial Tracking a User of Search and Display: Hey, FTC. Better Tighten Up Those Proposed self-regulatory rules [Annals of Behavioral Targeting]

Online ad companies, such as Microsoft, have been developing ways of tracking a users journey online (“engagement mapping” of the digital marketing “conversion funnel”) so the share of ad dollars can be more properly apportioned (meaning, it’s not only the ad companies providing the “last-click” that receives all the credit).  We have long been troubled by the stealth tracking and commercial surveillance system being put in place.  Rich media online ad company Eyeblaster has developed a similar service.  Here’s an excerpt from a trade article.  After you read it, think about the FTC during an Obama Administration, and what we should expect it to do under a new majority:

“Eyeblaster has introduced Channel Connect for Search, a service that helps marketers track consumers who click on their display ads but do not transact immediately.

The service places a cookie on a user’s computer that remains on his or her desktop for 30 days. Eyeblaster customers can then identify those individuals when they later convert through search.

“It bridges the gap between display and search advertising,” said Thomas MciIheran, senior media manager with digital media agency Sicola Martin, which is based in Austin, TX. “It’s such valuable information, because there are clients who say display advertising isn’t working, and they think they should stop. This could be eye opening for them, because it shows that display is leading to search, and how much.” …The new service is “able to pinpoint crucial campaign data and draw important insights about the interaction of our search and display ads,” said Harry Case, director of media analytics and technology at Mindshare, in a written statement. “In the end, it provided us with a more comprehensive overview of user behavior.”

Ad Industry Lawyer Spins in Ad Age that Privacy Will Be on “Back Burner.” Not Only Incorrect–but self-serving

This week’s Advertising Age has a “Legal Issues to Watch in 2009” column.  Written by Douglas J. Wood of Reed Smith, it claims that: “PRIVACY TO THE BACK BURNER- Congress and regulators are in a Catch-22: While under constant pressure from constituents and consumerists to curtail the use of personal information or behavioral targeting, they recognize that advertising is the backbone of the internet. So while there will be occasional skirmishes, the war on privacy will continue in its stalemate. Regulators will also see browser makers offering more control to consumers to block ads and the collection of personal information as adequate progress.”

Mr. Wood, it turns out is “a member of Reed Smith’s Executive Committee and the firm’s Advertising Technology & Media Group…and is General Counsel to both the Association of National Advertisers and the Advertising Research Foundation.”

Perhaps Mr. Wood is too busy to really follow Hill and FTC developments, because he is wrong.  There will be considerable activity on the Hill and elsewhere.   His column should have been labeled as written by the lawyer for the ad industry lobby group.  But it does reflect a lack of insight about the online ad industry’s problems related to privacy and consumer protection.

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

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

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

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

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

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