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

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

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

Rules Required for Data-mining and Consumer Protection: A good offer for you– but not for your neighbor!


As Congress and the FTC focus on 21st Century consumer protection safeguards to address the digital marketplace, a guiding principle should be accountability and transparency.  Advanced computer systems for both business and government far out-strip the ability of a single consumer to understand–let alone control–how their information is collected and used.  We need to have fair marketing rules so some people–because of their income, where they live, what the spend and what on and especially–race/ethnicity–find themselves confronting the emerging discriminatory web.  Take what Stream Base Systems does for e-commerce–and ask yourself: wouldn’t you want to understand how such real time data tracking and mining is used to determine prices and offers made for you? [excerpt]:

As Internet transactions and data volumes continue to skyrocket, more and more traditional eCommerce and Web 2.0 businesses need to monitor and instantly react to all user activity in real-time in order to ensure a positive customer experience, high customer retention rates, and greater profit…

  • Website Monitoring: With clickstream and transaction rates soaring, a growing number of high-traffic e-businesses are seeking to monitor and react instantaneously to website-generated real-time events. StreamBase enables e-Businesses to analyze and react to clickstreams in real-time, which in turn enables the immediate delivery of personalized cross-sell or up-sell offers, or online product merchandising customized to the real-time activity of site visitors.  By analyzing current web activity data and correlating this with stored customer history data, personalized offers can be generated that match the Web customer’s current interests and activity.


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

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

Facebook Places, Brands, Ads & Data

We have been raising concerns about privacy and location data collection and targeting–including with our colleagues at USPIRG.  Facebook’s new location feature is designed to generate more user data that can be used by Facebook and its affiliates to bolster ad and brand targeting.  I want to excerpt this post from one of Facebook’s developers–Vitrue–which illustrates how soon companies like McDonald’s will work with Facebook to harvest local data and our behaviors:

“…A user will open up their mobile Facebook app and be able to see shops, restaurants, parks, areas, etc. that they are near.  They can then check-in to that location.  If a location doesn’t exist, the user can simply create it.  A story about where that person checked-in will be published to their profile and subsequently their friends’ news feeds…Facebook’s massive user-base is a distinct advantage and is likely to generate location-based activity orders of magnitude greater than other companies already in the space. As the leading social network, Facebook is able to capitalize upon the users existing friends, and use their collected demographic and preference data to show users places that it thinks is relevant to them, instead of just places nearby.

How Will Brands Take Advantage of Facebook Places?

With all of these users checking in to locations, what does that mean for brands?  Well if your brand has brick-and-mortar locations, your brand can claim these digital “Places”, turning the locations into Facebook Place Pages.

Brands can choose to merge a Facebook Place Page with an existing Facebook Page, if one exists, and if prompted– the option may not be widely available yet as Facebook is rolling it out over a period of days…

At this time Facebook does not recommend merging your Places with your Page if you are a national or global marketer with more than one location, like a McDonald’s or GAP.  They recommend managing the Places separately and have stated that a solution that will help these types of brands is planned for the future…Currently, Facebook CEO Mark Zuckerberg says they aren’t looking to monetize Facebook Places right now, but that doesn’t mean that they can’t in the future.   With Facebook collecting all of this location-based data, it seems like Facebook could allow brands to place highly targeted Facebook ads on the Places Facebook pages.  For example, if your brand’s products are sold in grocery stores, you could potentially place your ads on certain grocery stores’ pages to be viewed by people who’ve checked in.”

In another words, in the world of mobile and location ad targeting, our data will provide marketers with real-time sophisticated insights giving them a rich history of where we spend time and what we do [go to the bank, buy at the pharmacy, eat fast food, etc].  Such “360 degree” targeting, as the online marketers call it, require the appropriate privacy safeguards.

Facebook Places and Location Marketing: Plans to `Send in the Crowds’ from Advertisers

You have to read between the lines to understand what Facebook’s new location feature is really designed to do:  Open you and your friends to be more closely tracked by Facebook and its marketing partners, including major advertisers [Fans are worth money to Facebook and their marketing partners].   On Facebook’s blog post on the new location service [which is written in typical Silicon Valley PRspeak suggesting they are doing this only to bring pleasure into your life], the key telling phrase is: “You may want to share your check-in information with third-party applications that build interesting experiences around location, such as travel planning. Applications you use must receive your permission before getting this information. Your friends will be able to share your check-ins with the applications they use to help create new social experiences with location.”

That really means Facebook already has plans to use location data to expand its marketing business (inc. from thrid part apps), which is expected to help the social network bring in $1 billion this year.  Mobile and location applications require greater safeguards for privacy, as my CDD and USPIRG petitioned the FTC to do last year [as a result the FTC has opened up a “mobile lab” examining data collection and mobile marketing practices]. Companies such as Facebook. Google, Foursquare, and others are keenly aware of the huge ad revenue opportunity from location marketing.  One Google backed location social game start-up [SCVNVR] calls this potential the “social coefficient.”  As Mobile Marketer reported, the “Social Coefficient is a score determined by the number of social interactions at a specific location…The more friends at one place or the more users participating in the challenges over time, the higher the Social Coefficient score for that particular location.”  Facebook and others understand that advertisers are willing to pay more if they can encourage friends to market to other friends. 

McDonald’s is already in discussion with Facebook to use this new service.

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

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

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

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

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.

Microsoft’s Global Social Media Marketing Strategy–A glimpse into how it plans to boost its brand, generate more advertising, and tell`branded’ stories

Last March, Microsoft hired a “Microsoft Emerging Media Manager.”  Here’s an excerpt from the job description:

“research, coordinate, project manage and implement emerging media marketing initiatives as across major global brands including Windows, Bing, Office, Windows Phones, and across our commercial business audiences. The ideal person will be immersed in what it means to “live life online” through channels such as Hulu, Twitter, Facebook, YouTube, etc. across the three screens of PC, television, and mobile phones… drive the evolution of Microsoft’s engagement with consumers around new and developing experiences including social media and mobile, will leverage and connect paid and earned media activities, and drive business impact in a results-driven manner to increase adoption and scale…be fluent in online campaign engagement…”

and from its current Social Media Manager opening; note the role of story-telling.–“Collaborating with social media BG owners to build a connected social strategy that incorporates BG social properties and brings to life Microsoft’s consumer innovation story.
• Working with the social media agency to build, launch and manage Microsoft branded social platforms
• Member of the One Microsoft v-team building an editorial calendar to tell the One Microsoft story across social channels.
• Become the internal and external voice for Microsoft social media consumer story, participating in best practice sharing and creative idea generation.  This role requires a passion for digital media and intense curiosity about the future of how consumers interact with each other, consume and engage with content, and develop affinity to brands online.

U.S. Consumers Targeted with 1 Trillion Display Ads in 2010, First Quarter

That’s right–a Trillion.  Think about all the data collected.  Facebook itself delivered 176 billion display ad “impressions,” explains comScore.  Yahoo and Microsoft sent 132 billion and 60 billion ads, respectively.  Leading online advertisers that quarter were AT&T, Verizon, Scottrade, Experian and others–so think about privacy, network neutrality, online financial marketing and consumer protection all together.  These issues are all connected.

Online Ad Industry Exec Warns of Dangers from “Targetocracy”/Urges IAB to Take Privacy Issue Seriously

We’re glad other online industry leaders see that addressing consumer privacy issues is required–instead of the denials coming from the IAB online ad lobbying group.  Doug Weaver, CEO for the UpStream Group writes in response to the IAB’s op-ed in USA Today, for example that:

I think a sustainable privacy strategy begins with acknowledgment of the problem that exists.   Facts is facts: the “Targetocracy” in our business is big, wildly overcapitalized and a little bit out of control.  What I think consumers want to hear from Randy and the IAB is “we take the issues raised by the Journal very seriously.  The issues and the technology are quite complicated, but we remain committed to rooting out the bad guys and maintaining an environment that’s rich, free and privacy focused.”

As one of the IAB’s earliest board members and one who’s contributed a great deal of time and effort toward its mission over the years, I believe it’s time for the group to act less like the Chamber of Commerce and more like the Internal Affairs Department.  There are both rogues and careless polluters in our industry and their actions poison the environment for everyone.   Not everyone wants regulation, but the consumer wants to know someone’s in charge.  Who’s that going to be?