Category: European Commission

Google’s “Health Vertical” Division and the YouTube `Branded’ Channel for Obesity-related Medical Product

Google is in, as we know, the interactive marketing of health products and medical information.  Here’s an excerpt from Advertising Age on one of Google’s new YouTube related efforts.  We are deeply concerned about the role of interactive health marketing, including the techniques used to present information, influence consumer behavior, and collect user data.

Excerpt: In the video, Viki, a middle-age blonde, tears up recounting her moment of truth: A couple of years ago she was so obese that she could not chase after her toddler to keep him from running into the street…If this sounds like a setup for a weight-loss ad, that’s because it is. But not for a diet shake, pill or plan. The video is for Ethicon Endo-Surgery’s Realize adjustable gastric band — a device placed around the stomach that restricts food intake. The video is on Realize Band’s branded YouTube channel.

“Video is such a powerful medium for people who are having this type of surgery,” said Mary Ann Belliveau, managing director of Google Health Vertical. “What the channel does is give the patients a home for this, so they can get a more thorough experience, specifically with the company and the brand.”…The Realize band’s YouTube channel went live June 20 and already has received nearly 8,000 channel views. Ethicon also has a branded site for the band, where patients can learn more about the surgery and join the device’s online support program. In the video on YouTube, Viki describes her own experience with the Realize band. On the Realize website, consumers can read Viki’s diary, as well as those of other patients. Complementing Viki’s story on YouTube, there is a video simulating implantation of the band, and another explaining how to financially prepare for the surgery, which costs $17,000-$26,000 on average…”

source:  Gastric-Band Maker Reaches Out with YouTube Channel.  Marissa Miley.  Ad Age.  July 6, 2009 [sub required]

Online Consumers Require Real Privacy Safeguards, Not the Digital Fox [AAAA, ANA, BBB, DMA & IAB] in Charge of the Data Hen House

The self-regulatory proposals released today [2 July 2009]  by five marketing industry trade and lobby groups are way too little and far too late. This move by the online ad industry is an attempt, of course, to quell the growing bi-partisan calls in Congress to enact meaningful digital privacy and consumer protection laws. It’s also designed to assuage a reawakened Federal Trade Commission–whose new chair, Jon Leibowitz, recently appointed one the country’s most distinguished consumer advocates and legal scholars to direct its Bureau of Consumer Protection (David Vladeck). The principles are inadequate, even beyond their self-regulatory approach that condones, in effect, the “corporate fox guarding the digital data henhouse.” Effective government regulation is required to protect consumers. We should have learned a painful lesson by now with the failure of the financial industry to oversee itself. The reckless activities of the financial sector—made possible by a deregulatory, hands-off government policy–directly led to the current financial catastrophe. As more of our transactions and daily activities are conducted online, including those involving financial and health issues–through PCs, mobile phones, social networks, and the like–it is critical that the first principle be to ensure the basic protection of consumer privacy. Self-dealing “principles” concocted by online marketers simply won’t provide the level of protection consumers really require.

The industry appears to have embraced a definition of behavioral targeting and profiling that is at odds with how the practice actually works. Before any data is collected from consumers, they need to be candidly informed about the process–such as the creation and evolution of their profile; how tracking and data gathering occurs site to site; what data can be added to their profile from outside databases; the role that data targeting plays on so-called first-party websites, etc. In addition, the highest possible consumer safeguards are necessary when financial and health data are involved. Under the loosey-goosey trade industry principles, however, only “certain health and financial data” are to be treated as a “sensitive” category. This would permit widespread data collection involving personal information regarding our health and financial concerns. The new principles, moreover, fail to protect the privacy of teenagers; nor do they seriously address children’s privacy. (I was one of the two people that led the campaign to enact the Children’s Online Privacy Protection Act).

The failure to develop adequate safeguards for sensitive consumer information illustrates, I believe, the inability of the ad marketing groups to seriously address online privacy. The so-called “notice and choice” approach embraced by the industry has failed. More links to better-written privacy statements don’t address the central problem: the collection of more and more user data for profiling and targeting purposes. There needs to be quick Congressional action placing limits on the collection, use and retention of consumer data; opt-in control over profile information; and the creation of a meaningful sensitive data category. Consumer and privacy groups intend to work with Congress to ensure that individuals don’t face additional losses due to unfair online marketing practices.

[press statement by the Center for Digital Democracy]

Protecting Privacy and Consumers: Testimony on Behavioral Targeting Before House Commerce Subcommittees

Last week, I testified on the threat to both consumer privacy and welfare from the growing data collection, profiling, and targeting interactive online marketing system.  I told Congress it was critical to enact legislation that would protect consumers, especially as they use online and mobile networks for financial and health-related transactions (credit card applications, banking, health inquiries, etc.).  As you can see from the testimony, I said we should be able to have an online privacy policy that  ensures the public is protected, while also promoting the growth of the commercial online medium.

The link to the testimony via a press release is here.

Microsoft uses brain research to improve ads in online games, including for Doritos [annals of neuromarketing]

excerpt:  “…in-game ads have begun to move out of the “experimental buy” bucket and into the media plan because advertisers now realize that ads in games produce results…Measurement is very important…Earlier this week, the Interactive Advertising Bureau (IAB) released new in-game advertising guidelines for public comment to establish a common methodology for counting impressions and to simplify the process of buying and selling in-game advertising… Microsoft’s advertising arm also has been involved in a study that examines the emotional reactions consumers have toward advertising campaigns in and around video games. The first phase of the study — conducted with EmSense, a neuroscience company — compares the findings with similar results from television commercials. The companies discovered that the interactive elements in the video game ad campaigns evoke stronger emotional connections with consumers and more positive emotional associations with the brands.

EmSense analyzed several different advertising campaigns on Xbox 360 games, Xbox Live and MSN Games. Some brands involved in the study include Doritos, Kia, Sprint, Hyundai and Microsoft.

In-Game Ads In The Ad Game.  Laurie Sullivan.  Online Media Daily.  June 16, 2009

PS:  Among the in-game ad categories [excerpt] proposed by the IAB include (and I kid you not!):

 3.1.1.1 Valid Ad Impression:
The threshold for a valid Ad Impression is a cumulative exposure to an ad of ten (10) seconds.   An In-Game Measurement Organization may accumulate ad exposures of shorter time lengths to achieve this Ad Impression threshold…

3.1.2.2 Lighting
Only ads that are visible within the virtual game environment with sufficient lighting during darkness should be counted.

3.1.2.3 Maximum Ad Angle Relative to Game Screen
The angle of the ad must be no greater than 55 degrees relative to the game screen.

MTV uses Neuroscience to Analyze Ads for Games: Examining “the optimal way of connecting to this audience when they’re that rabid and that engaged.”

excerpt:  “…MTVN  conducted a three-day study of more than 60 gamers at a biometrics lab in Las Vegas; they showed the players various ads and games, all while examining stats like heart rate, respiration, movement patterns and visual attention. Interestingly, they found that 15-second pre-rolls were the most effective way to garner a player’s “focused attention”—beating out 30-second spots, in-game display ads, and even overlays. Pre-roll ads commanded up to 85 percent focused attention, MTVN’s study found, meaning that the vast majority of the viewers paid full attention to the ads…“The question we wanted to answer was do ads need to be more disruptive to be effective?” said Jason Witt, GM for MTVN’s Digital Fusion ad unit. “We can always stick a bigger ad in front of somebody. And we found that you don’t have to be more disruptive, by and large. The proof is that 15-second pre-rolls were the most effective.” The study also found that game ads had 8x higher unaided brand awareness over online display ads in general, and fueled a 12x higher intent to purchase…So for us, the goal is to see what’s the optimal way of connecting to this audience when they’re that rabid and that engaged.” 

source:  Need To Reach Casual Gamers? MTV Says 15-Second Pre-Rolls Work Best.  David Kaplan.  paidcontent.org.  June 10, 2009.

Behavioral Targeting Meets Neuroscience: “The ability to tap into psychological and physiological testing for ad targeting is an emerging field”

Here’s an excerpt from the article BT: Can It Mean Behavioral Responses To Ads?:

Companies touting the targeting of online ads to consumers as a mixture of art and science could soon find psychologists employed among their midst…One To One Interactive will open its primary research lab, OTOinsights, to other advertising agencies and research firms… Along with the main lab in Charleston, Mass., a mobile lab that can travel anywhere offers input on eye tracking; click tracking; bio-feedback such as heart rate, respiratory rate, galvanic skin response; neuro-feedback such as EEG/active attention; and facial recognition technology that interprets six fundamental human emotions: happy, sad, angry, surprised, scared, disgusted, and neutral…The ability to tap into psychological and physiological testing for ad targeting is an emerging field…There are between 10 and 15 firms…spearheading efforts. …Neurofocus…focuses on EEG electroencephalographic- (EEG-) based neurological testing that reveals the degrees of attention, emotional engagement, and memory retention that consumers experience at the deep subconscious level of the brain.

source:  Laurie Sullivan.  Behavioral Insider.  June 4, 2009.

Behavioral Targeting U.S. Hispanics: Another Example of Why Policymakers Must Be Proactive

Here’s an excerpt from a column written by an executive from a leading behavioral targeting company:

Behavioral targeting can help marketers reach across the cultural divide, helping to identify Hispanic online audiences, or any other ethnic group for that matter…Behavioral targeting is used to create Hispanic audience segments first based on users who have visited Spanish-language sites or any sites with Hispanic-relevant content. You can then create sub-segments based on not only ethnicity, culture, or language, but also interests and purchase intent behaviors observed on those or other sites. You can even identify “purchase influencers” among U.S. Hispanic populations, based on browsing and buying behaviors plus geographic location. You may then serve culturally relevant marketing messages to these segments when they travel to any other site online.

You will also find re-targeting useful, once you have begun to build these behavioral segments. As you serve ads to your Hispanic audiences and sub-segments, you can then re-target them across whichever network or sites you choose, with upsell, cross-sell, or discount offers…Behavioral profiles that have been tagged as part of a Hispanic audience or sub-segment can be given a boost by search data including Spanish-language or Hispanic content keywords or search engines that have been set to Spanish.

source:  How to use BT to reach U.S. Hispanics.   Jeff Hirsch.  April 21, 2009.  imediaconnection

Tracking You Offline for Better Targeting You Online: Why both the FTC and Congress Need to Protect Consumers

There is growing evidence daily about threats to consumer privacy online–all of which have real life consequences for the decisions we make when we buy products.   As the public relies more on using online to apply for credit cards, mortgages, explore health concerns or issues affecting their children and teenagers, it’s absolutely essential the individual–not the business–have full control over their data.  In a trade article on the “profiling” of consumers for online targeting, here’s how they describe linking your offline data with your digital experience.  It shows how the current definition of Personally Identifiable Information, PII, is out of date and fails to protect consumers.  Marketers don’t need your name or address to know your behaviors and target you [excerpt]:

How do marketers get access to the offline purchase data? More importantly, how do they marry it to your online identity without using PII? Usually, this involves the cooperation of several parties. The first might be an online retailer that links a credit card used in an ecommerce transaction with a third-party cookie. The second party is a data partner who owns that particular cookie and pulls in additional purchase history to augment the profile associated with that cookie, and then rents the profile to a marketer. The third is an online ad exchange, which will allow ad hoc purchasing of inventory against a particular cookie across inventory sold on the exchange.

source:  Where do we draw the line on consumer profiling?  Tom Hespos.  imediaconnection.com.  May 21, 2009

Google’s Retention of Search Data–tied to selling ads [Google Connects Offline Behavior To Digital Marketing]

This excerpt from an online ad news report illustrates perhaps a more compelling reason for Google to retain user data for longer periods, so it can better analyze the decision-making process for consumer purchasing for its ad businesses:

“We now understand the types of keywords people use at specific points prior to purchase,” says Davang Shah, head of automotive marketing at Google. “Six months prior to the purchase, we see roughly 56% of the auto searches buyers conducted were on non-branded search terms such as fuel efficient or hybrid sedan.”…Search plays a critical role throughout the purchase process…The data, related to paid, organic and display advertising as well as online marketing, includes the facts that 68% of buyers visit a manufacturer’s site in the six months prior to purchase, and 77% visit a third-party site. In aggregate, 84% visit at least one or the other…Shah says Google will cut the data by brand and provide the information to manufacturers, dealers and third-party companies…”

source:  Google Connects Offline Behavior To Digital Marketing.  Laurie Sullivan.  Online Media Daily.  May 22, 2009.  

Behavioral Targeting Merges with Social Media Marketing for Individual Profiling [Annals of Behavioral Targeting]

As a growing number of people recognize (and taking advantage of), behavioral targeting is part of the social media marketing business model.  Such an approach illustrates why policymakers across the globe must address what is a largely stealth commercial surveillance system.  It has implications for the collection of data on individuals by government as well [my bold].

Here’s a excerpt from a recent announcement by WPP owned 24/7 Real Media Inc.:  “the leading global digital marketing company, has begun a pilot program to integrate social media engagement metrics into its behavioral targeting application. These social media engagement metrics will augment existing behavioral targeting attributes to drive robust advertising response and conversion.  Working with companies such as NuConomy, an innovator in social media measurement, select 24/7 Real Media advertisers are now leveraging non-traditional metrics such as comments, ratings, video plays, and link sharing to customize advertising, increase responsiveness and drive purchases.”

and Nuconomy says that:
“By tracking engagement and site activity at the individual user level, NuConomy’s module automatically builds rich behavioral profiles, or interest maps, for each user – such as who is posting comments on bikes or sharing music recommendations with friends. This level of detail gives publishers a deeper understanding of user behavior so they can optimize their sites and marketing messages for different audience segments, even different individuals.”

PS:  We see that the folks over at the AT&T, Yahoo, AOL, etc. backed Future of Privacy Forum has engaged WPP to help its new research effort designed “to develop a variety of [privacy] notices that will resonate with consumers and begin to test them with users.”

We suggest that as its initial effort, the Forum require WPP to make public all the various methods it uses to collect data from consumers.  Such a list includes WPP’s ad networks, online games, mobile, cable broadband platforms, social media, etc.  That would provide the research initiative a good place to begin, if its effort is to be taken seriously.