Category: elections & Internet

Behavioral Advertising: Targeting “Users Further Down the Purchasing Funnel”

When you can get the online ad industry to write your copy, it makes the work at the FTC and the European Commission so much easier! Here’s an excerpt from a revealing imediaconnection article entitled “Targeting Tips for a Converged Media World.” [Jan. 30, 2008]
“In days past, audience segmentation was based solely on demographic and contextual targeting information, which allowed advertisers to promote their products or services to a group of potential consumers based on their gender, age and other fairly unsophisticated, generic characteristics. In the online world, consumers now essentially determine their own segmentation based on individualized habits, determined through behavioral targeting…. Behavioral targeting…is also an additional way for marketers to target users further down the purchasing funnel and helps marketers better predict how users will act… Marketers will be able to track individuals or user clusters across their favorite TV shows, travel habits through their car’s GPS or obtain their video game proficiency through in-game advertising… As users age and change their personal preferences, behavioral targeting can change with users’ habits and compensate accordingly…With marketers able to include interactive components into traditional media outlets while infusing behavioral knowledge and targeting, advertisers must create messages that can be delivered across all platforms. For example, we could see mobile ads that use interactive elements if marketers know the behavioral cluster exhibits a preference for interactive media.”

Google’s Privacy PR: Here’s What They Sent to Reporters. But real safeguards are required, especially in the GoogleClick era

Yesterday a reporter sent me the following email sent from the Google PR shop. Instead of calling for responsible policy safeguards to protect consumers, Google is distributing booklets, videos and other self-help materials (in other words, let the user beware). It’s not surprising that Google is on a PR effort to quell the growing calls for real privacy protection. But they are not living up to their own ideals if they fail to really be more candid about the conflicts they have with a business model entirely based on data collection and targeted marketing.

Here’s the email:

“From: “Adam Kovacevich”
To: undisclosed-recipients:;
Sent: Monday, January 28, 2008 12:23:11 PM (GMT-0500) Auto-Detected
Subject: Happy Data Privacy Day

Okay, okay, so you can be forgiven if you didn’t realize today was Data Privacy Day here in dear old North America. At Google we’ve been doing a lot lately to educate our users about our privacy policies (particularly the launch of our Google Privacy YouTube channel ), but we figured today was a good day to unleash a few more education efforts. To wit:

• A brand spankin’ new video on the YouTube channel explaining how cookies work: http://youtube.com/user/googleprivacy
• A new booklet ( http://64.233.179.110/blog_resources/google_privacy_booklet.pdf ) that gives our users an in-depth look at our privacy practices and approach. This should be a particular good resource for you journos too.
• We’ve co-sponsored the creation of educational materials ( https://www.privacyassociation.org/images/stories/pdfs/DPD08_TeenPrivacyOnline_slides.pdf ) on teen online privacy for parents and educators.
• Our senior privacy counsel Jane Horvath is today joining legal scholars, privacy professionals, and government officials from Europe and the U.S. at an international data privacy conference being held at Duke University in Durham, North Carolina.

For more on all of this, check out our blog post:

http://googleblog.blogspot.com/2008/01/celebrating-data-privacy.html

or background from the Search Engine Land blog:

http://searchengineland.com/080128-095148.php

Adam

—
Adam Kovacevich | Sr. Manager, Global Communications and Public Affairs | Google
1101 New York Ave NW | Second Floor | Washington, DC 20005 “

EC’s Questionnaire 1 on Google/DoubleClick merger

Following press reports of a new questionnaire sent by the European Commission Competition Directorate, we thought we should place here what we believe was the initial survey sent. Eventually, Congress and others will need to investigate how well the FTC conducted its own review of the deal. Frankly, several parties–including commissioners–spoke of their concern that the agency’s loss in Whole Foods and other cases made it more difficult to confront the Google takeover of DoubleClick case. This is an ongoing story. But for now, here’s the questionnaire:

Case COMP/M.4731 – Google/DoubleClick

Questionnaire to Customers 1
Deadline for Reply: 18/10/2007

Google Inc. (“Google”) notified to the European Commission its intention to acquire control of DoubleClick Inc. (“DoubleClick”) by way of purchase of shares. The two parties to the merger Google and DoubleClick are hereinafter collectively referred to as “the parties”. Both are active in the online advertising industry.
Pursuant to the Merger Regulation , the Commission is required to assess the operation’s possible effects on competition within the common market. To this end, the Commission needs to gather relevant information from the parties to the operation as well as from other market operators, such as competitors and customers.
Therefore, your replies to the following questions as well as any other opinion on the effects of the operation you might consider relevant, are of key importance to the investigation. We should also be grateful for any additional remarks you may wish to make relating to the proposed concentration. If you consider that a particular question is not relevant, please indicate this and explain why. Please reply to this questionnaire on behalf of all companies belonging to your group.
When you reply to this questionnaire, please provide TWO versions of your reply: (i) a CONFIDENTIAL version; and (ii) a NON CONFIDENTIAL version which excludes business secrets or other confidential information.

In accordance with the Merger Regulation and in the light of the deadlines which the Commission must respect following the notification of the case, the Commission wishes to have your reply by 18/10/2007.
If you have questions of administrative nature or wish to receive this questionnaire in electronic format, please contact Ms Györgyi Nyiregyhazi (Tel.: +32 2 29 85327, e-mail: gyorgyi.nyiregyhazi@ec.europa.eu) clearly indicating the reference: M.4731 Googkle/DoubleClick – Questionnaire to Publishers.

If you have any further questions on the substance of this request, please contact Mr Bertrand Jéhanno (Tel.: +32 2 29 91048, e-mail: bertrand.jehanno@ec.europa.eu), Mr Carl-Christian Buhr (Tel: +32 2 29 86 033, e-mail: carl-christian.buhr@ec.europa.eu), Mr Flavien Christ (Tel: +32 2 29 90931, e-mail: flavien.christ@ec.europa.eu,), Mr. Peter Eberl (Tel: +32 2 29 60783, e-mail peter.eberl@ec.europa.eu), Ms Vera Pozzato (Tel: +32 2 29 93012, e-mail: vera.pozzato@ec.europa.eu).

Thank you for your help and co-operation.

A. General questions

Please give the contact details of the person responsible for replying to this questionnaire
Company:
Contact person: Phone:
Position: Fax:
E-mail:
Address:
Country:
Company web-site:

Please give a brief description of your organisation, of its size and of your activities. If your company is a subsidiary please indicate the group to which it belongs to.
Description of your organisation:

Please indicate the countries within the EEA in which you are active as online publisher (website owner):

B. The provision of display ad serving, management and reporting infrastructure technology
The provision of display ad serving, management and reporting infrastructure technology could be distinguished according to whether services are provided to advertisers (and agencies) or to publishers (including self-provisioning).
The Commission understands that advertisers create advertisements and upload them onto the advertiser-side ad server. Once a website publisher has agreed with the advertiser (directly or through an ad network or ad exchange) to run the ads on its website, the publisher enters the campaign terms of the ad (location, price, targeting criteria) into the publisher-side ad server. There is then a relationship between the publisher-side ad server – which records the “impression” generated by the user’s visit of the web site and determines the advertiser to call – and the advertiser-side ad server – which chooses the appropriate ad to deliver on the web page. The relationship between the two servers also enables the advertiser to obtain information relating to the user’s online behaviour in the context of the placed ad via browser cookie technology.
1. What is the value of the online advertising revenues generated by your website(s) in Europe?

2. Through which channels do you sell advertising space on your website/s?
Direct sales: YES/NO
And/or
Brokers, intermediaries, ad networks, ad exchanges: YES/NO

3. If you use both the direct channel and the indirect channel (ad network/ad exchange), please indicate (broadly) what % of your online revenues originate from the direct channel.

4. Do you foresee that direct sales of online advertising will decrease in the future in favour of intermediation through ad networks and ad exchanges?

5. Do you foresee that numerous ad networks and ad exchanges will be able to survive in the near future (2-3 years)? Please briefly elaborate.

6. If you use a 3rd party ad serving supplier (e.g. DoubleClick, OpenAdstream, AdManager…): if the price of 3rd ad serving services was to raise by 5-10% (all else equal) would you switch part of your inventory to an integrated network like Google AdSense?

7. Do you consider the cost of switching ad serving technology supplier to be high / moderate / low?

8. If you use more than one supplier of such technology/services, please describe briefly the advantages and disadvantages of such a solution compared to a situation in which only one supplier is used. Please also indicate why your company chose to use more than one supplier for this technology/services.

9. If you only have one supplier for this particular product/service, do you consider it possible/usefull using another supplier for a comparable product/service at the same time? If yes, please name these other possible suppliers. If not, please explain the reason why you choose single homing (e.g. exclusivity clauses, cost saving, quality of service …).

10. Please name other providers of display ad serving, management and reporting infrastructure technology that you consider as competitors of your provider/s at EEA level.

If you sell advertising space through direct sales

11. Which provider/s of display ad serving, management and reporting infrastructure technology is directly supplying your company?

12. Have you ever experienced a switch of supplier for this particular product/service? YES/NO
If yes, please:
explain the reason why you made such experience:
provide the name of your former supplier:
the name of the replacing supplier:
the cost caused by the switch:
the time it took to complete the switch

13. What is the % represented by the cost of ad serving in the total revenue generated by your advertising space? Please provide broad estimates.

If you sell advertising space through brokers/intermediaries/ad networks/ad exchanges
14. Which provider/s of display ad serving, management and reporting infrastructure technology is/are indirectly supplying your company?

15. Have you ever experienced a switch of supplier for this particular product/service? YES/NO
If yes, please:
Explain the reason why you had to switch:
provide the name of your former supplier:
the name of the replacing supplier:
the cost caused by the switch:
the time it took to complete the switch:

16. If you use the indirect channel, what is (a) the % represented by the cost of ad serving in the total revenue generated by your advertising space; (b) the % represented by intermediation fees in the total revenue generated by your advertising space? Please provide broad estimates.

17. If you multi-home, why have you become member of several ad networks?

C. Effects of the merger

18. According to you, is DoubleClick’s large publisher customer base an advantage for the quality of services offered by DoubleClick to publishers? In other words, is there a direct benefit to a publisher to use an ad serving supplier with a larger publisher base? If so, please briefly describe the benefit(s) (e.g. does the ad serving service improves the monetization of inventory if the ad server processes the data on user behaviour accross numerous publishers?).

19. If Google and DoubleClick were to merge, do you consider that integrated networks like Yahoo! (with RightMedia) and Microsoft (with aQuantive) would be able to provide strong competition to Google/DoubleClick? Please briefly elaborate.

20. Would you consider open source ad serving software as a viable alternative to commercial ad serving software? If so would you consider it suitable, in conjunction with a standalone ad network, as an alternative to Google’s AdSense? Please explain.

21. What are, in your view, the main effects of the proposed operation on:
a) your company?
b) the markets for (display and text) ad serving, management and reporting services for publishers?
c) the prices of (display and text) ad serving, management and reporting services for publishers?
Please give reasons for your answers.

22. Do you have any other comments that you wish to bring to the Commission’s attention?

Thank you for your assistance!
Please do not forget to add a non-confidential version to your response.

EC Enisa Report Underscores Privacy Threats and other Risks from Social Networks: Wake-Up Time for Facebook, MySpace, IAB, FTC, Congress. Rules & Safeguards Required

The expanded targeting based on user profile activity launched last month by both Facebook and MySpace underscore why we must craft federal (and EU) rules to govern the data collection apparatus of social networks. By combining behavioral targeting, transaction data, and profile information, Facebook and others have entered into a new territory. Even industry insiders understand how a line has been crossed: one senior VP at Digitas (part of the Publicis Groupe ad industry empire) noted that [our emphasis]:

“Facebook has made an announcement that has major implications for how marketers can communicate to members going forward. Essentially, Facebook said that it will allow marketers to target members with ads based on its user’s personal profiles, social connections and even the recent activities of each user’s extended network.

This announcement marks a significant departure in the way social networks have been organized to date. Until now, marketers have had limited opportunity to serve ads directly to users within the social network. With this change, marketers will now have the opportunity to target consumers directly based on attitudinal, behavioral and demographic attributes included directly in or inferred from personal profiles and connections online.”

We have sent out to the FTC today this new report [pdf] by ENISA—the European Network and Information Security Agency. Released in October, “Security Issues and Recommendations for Online Social Networks” is worth reading—for its clear and thoughtful analysis and, frankly, its disturbing implications. It’s clear from the start of the paper that social networking sites (SNS) are more than just commercial or personal playgrounds—they are, notes ENISA—“…all-embracing identity management tools…” As the report explains:

“Users are often not aware of the size or nature of the audience accessing their profile data and the sense of intimacy created by being among digital `friends’ often leads to disclosures which are not appropriate to a public forum. Such commercial and social pressures have led to a number of privacy and security risks for SN members.”

Among the “threats” the report lists includes:

1.1 Digital dossier aggregation: profiles on
online SNSs can be downloaded and stored
by third parties, creating a digital dossier of
personal data.
1.2 Secondary data collection: as well as data
knowingly disclosed in a profile, SN
members disclose personal information
using the network itself: e.g. length of
connections, other users’ profiles visited
and messages sent. SNSs provide a central
repository accessible to a single provider.
The high value of SNSs suggests that such
data is being used to considerable financial
gain.
1.3 Face recognition: user-provided digital
images are a very popular part of profiles
on SNSs. The photograph is, in effect, a
binary identifier for the user, enabling
linking across profiles, e.g. a fully identified
Bebo profile and a pseudo-anonymous
dating profile.
1.6 Difficulty of complete account deletion:
users wishing to delete accounts from SNSs
find that it is almost impossible to remove
secondary information linked to their
profile such as public comments on other
profiles.

Among the report’s other recommendations include the need to consider reviewing regulatory safeguards and data protection law, such as the FTC’s Fair Information Practices. Social networks have become a place where people are living out their lives, sharing intimate details about their identity. They cannot be operated as data mining and digital marketing operations solely. They must operate in the public interest as well, including rules protecting privacy for those under 18.

It’s time for a broad range of stakeholders to work together to address what must be done.

PS: ENISA held a conference on the issue last June, featuring a number of interesting papers.

The evolution of targeting users online (or, "Oh where oh where has our privacy gone")

An excerpt from a recent trade piece that should encourage reflection and concern (our emphasis):

“Today, we can not only target by the sites we think our customers frequent, we can follow them around the Web and target them based upon the other sites they actually visit. We can also target them based upon the words typed into a box, and from where those words are typed through search geo-targeting. We can also retarget searchers elsewhere on the Web. Facebook’s recent announcements take targeting to a whole new level, based upon age, location, interests, and other online activity.”

Source: “Search And Online Advertising: A Continual Evolution.” Ellen Siminoff. Search Insider. November 16, 2007

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Google & the Public Interest Policy Pod People

They’re coming. The “Google Policy Fellows” to help staff an array of public interest groups and policy think-tanks. “As lawmakers around the world become more engaged on Internet policy,” says Google, “a robust and intelligent public debate around these issues becomes increasingly important…The Google Policy Fellowship program offers undergraduate, graduate, and law students interested in Internet and technology policy the opportunity to spend the summer contributing to the public dialogue on these issues…Fellows will… work at public interest organizations at the forefront of debates on broadband and access policy, content regulation, copyright and trademark reform, consumer privacy, open government, and more. Participating organizations… include: American Library Association, Cato Institute, Center for Democracy and Technology, Competitive Enterprise Institute, Electronic Frontier Foundation, Internet Education Foundation, Media Access Project, New America Foundation, and Public Knowledge.”

It’s wrong for public interest and consumer organizations to take Google’s money and especially provide a “Fellowship” in its name. We need to build more consumer advocacy capacity to address Google’s growing power, especially its threat to privacy. No matter what these groups say (and some already take money from Google; others receive broad media industry support), there are digital strings attached, as subtle as they may be. The Fellowship program is just another lobbying and PR effort coming from a company that has a broad policy agenda. Many of the groups above should be training people to represent the public versus companies such as Google, and other big online advertisers and new media conglomerates. Giving Google a say on the training of policy advocates, let alone a funding role, undermines the public interest movement.

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Google & DoubleClick Mobile [plus Jaiku]=a Dart to Privacy

DoubleClick is promoting, via full-page ads in the U.K. trades, its new DoubleClick Mobile service “Introducing a new way to serve ads on small screens,” touts the copy. It goes on to say that online marketers can “[U]se Doubleclick Mobile to sell and managage mobile advertising with the same team and tools you use for your display and rich media business.” Here’s what DC’s “Mobile Overview” tells marketers [excerpt]: “As you engage your audience on the mobile platform you have the opportunity to take control of your revenue and operations with DoubleClick Mobile. You can capture more dollars from your mobile content by adding dynamically served mobile display ads and destination offers…Just as online banners are uploaded into DART, mobile banners and mobile companion jump pages are uploaded into and served by DART. Mobile specific targeting criteria can be set within the DART interface, including content, device and capability targeting…DoubleClick Mobile helps you deliver ads to mobile devices worry-free through our database of over 3,000 handsets indetifying each device’s unique screen size and capabilities…”

On its website, DC says that its Mobile service allows marketers to “[S]et mobile-specific targeting criteria for dynamically served mobile display ads, including content, device and capability targeting.” In the UK, DC explains that: “DoubleClick Mobile tracks impressions, third party impressions, clicks and jump page conversions. Tracking mechanisms meet the unique requirements for mobile delivery, and care has been taken to ensure compliance with network operators.”

Pixelating Privacy: Here’s what ClickZ said about the new DC mobile service: “DoubleClick Mobile aims to bring “a lot of heavy iron” [said DC VP Ari Paparo] to the developing marketplace for ads on handsets. The product is capable of pairing ads with content…In addition to standard mobile display ads, it supports ad formats such as combination ads and roadblocks. Through pixel-based ad tracking, agencies and other third parties can access campaign performance data through their own campaign reporting systems.”

Finally, we think Google’s new acquisitions (such as Zingku] in the mobile area bear examining, esp. for privacy implications. Google also just bought Jaiku, a Finnish company. Here’s how Jaiku describes its service: “Jaiku’s main goal is to bring people closer together by enabling them to share their activity streams. An activity stream is a log of everyday things as they happen: your status messages, recommendations, events you’re attending, photos you’ve taken – anything you post directly to Jaiku or add using Web feeds. We offer a way to connect with the people you care about by sharing your activities with them on the Web, IM, and SMS – as well as through a slew of cool third-party applications built by other developers using our API.

The most powerful instrument of social peripheral vision is your mobile phone. We’ve put in a special effort to create Jaiku Mobile, a live phonebook that displays the activity streams, availability, and location of your Jaiku contacts right in your phone contact list. We modestly believe it is the best solution out there for seeing what your friends are up to.”

The future is now calling. Will we act to protect our privacy?

Canadian Privacy Group Raises Key Concerns on Google, Doubleclick and Threat to our Privacy

We urge everyone to read the CIPPIC petition filed yesterday in Canada asking for a investigation of Google and Doubleclick. Among the key questions raised is whether the two companies are violating Canadian privacy law (Personal Information Protection and Electronic Documents Act-PIPEDA). The full document is on the Canadian Internet Policy and Public Interest Clinic website. But here are some key excerpts raising very important issues. Bravo! (and Merci) CIPPIC.

“37. Google’s servers automatically record information when the user visits Google’s website or uses Google products. Google server logs record the search request, URL, Internet Protocol (IP) address, browser type and language, and the date and time of the request, and one or more cookies that may uniquely identify the user’s browser. Google stores server logs indefinitely, but “anonymizes” them after 18 months.

38. The act of collecting user search queries and IP addresses invokes PIPEDA, requiring Google to provide adequate notice to users of any collection, retention, use, or disclosure of personal information other than that which can be reasonably implied (in this case, collection, retention and use necessary to deliver search results to the individual user). Without such notice, Google cannot be said to be obtaining meaningful consent from users to any other information practices, including retention and use for targeted marketing purposes.

39. The fact that Google’s search service is entirely dependent upon targeted marketing to users is not evident to the ordinary computer user. It cannot therefore be said that users implicitly consent to the use of their data for marketing purposes, even if such use is central to Google’s business model. Indeed, most users likely do not reasonably expect Google to retain their search queries in connection to their IP address for much longer than necessary to deliver the requested search results.

62. Google collects a variety of personal information about its users and uses that information to, among other things, improve its target marketing services. Online advertising services are constantly being improved, sometimes in ways that involve greater collection and use of personal data. This raises the question of what level of data collection and analysis is necessary for the purpose of target marketing; at what point is Google collecting more personal data than necessary for advertising purposes? No doubt Google is limiting its collection of data to that which is relevant for the marketing purposes, but the test in Canada is necessity, not relevance.

63. CIPPIC submits that a determination of what is necessary under Principle 4.4 should be driven not by what is possible or desirable from an advertising perspective, but rather what is actually necessary for Google to provide the service. The same test should be applied to all online advertisers, not just Google.”

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Google’s Mobile Search Advertising Ambition: Control the Market

From Online Media Daily [“Google’s Mobile Ad Move Gets Everybody Talking.” Tameka Lee. September 14, 2007] excerpt:

The search giant “is acting fast to take control of the mobile search ad market–a crucial move if it expands as predicted,” said Silicon Alley Insider’s Dan Frommer. And with The Kelsey Group predicting mobile search to generate more than $1.4 billion in ad revenue by 2012, Google is trying to get a jump on what right now is anyone’s game.

Google had been testing mobile text ads since last year, but decided to expand the effort–informing all AdWords advertisers through emails that if they didn’t opt-out, their sponsored links would now be served to mobile searchers…

According to a Google spokesperson, the company went full-scale with mobile search ads, partly because of the sheer volume of mobile-ready ads in place, and because “the mobile space is an increasingly important part of how users are accessing information.