Category: European Commission

Google Sells To Advertisers: User Profiles for Consumers Looking for Credit Cards [UK]

The new Consumer Financial Protection Board–and the FTC–will have their digital hands full as they begin to investigate the stealth world of online financial marketing.   Disclosure and consumer control has to be built into these applications–but they are not.  Of interest is a trial run by Google in the UK to sell credit cards, part of its move into “comparison” marketing.  According to New Media Age [my emphasis], “Google is testing its own [credit card] comparison product, launched earlier this year.  Currently focused purely on UK credit card providers, it lets users search on Google, click on an interactive ad showing rates from participating advertisers and takes them to a comparison page. Advertisers bid for user profiles that match their target audience and pay on a cost-per-lead basis.”

Take a look at Google’s credit card comparison site; does a consumer know about the advertiser bidding to buy their profile? See also Google similar product selling mortgages here in the U.S.

Facebook Promotes its “Virtual” Currency–and its data tracking–via Cancer Charity

When big advertising and media companies want to introduce a new or expanded form of marketing, they generally found some non-profit cause.  Who can complain about the techniques used–say for mobile ads, data collection, online games–when the funds are earmarked for a worthy charity?  It’s a time honored tactic, done by the Ad Council, initiatives such as Pepsi Refresh and now Facebook.  AllFacebook reports that “Stand Up to Cancer” is asking supporters to donate using “Facebook Credits.”  It explains that:

Facebook has been making great progress in its goal of making Credits the main or exclusive virtual currency on the site, with Zynga the latest social game company to agree to an exclusive deal. Facebook makes a 30% cut when users spend Credits on virtual goods in social games such as Farmville or Mob Wars… Facebook does gain in other ways from the collaboration, besides feeling good about helping cancer research. The fundraising event will help promote Facebook Credits as a payment system, both on the site through user activity and potentially also through the hour-long celebrity fundraising telethon on ABC, CBS, Fox, NBC and some cable channels …

On the Facebook “Stand Up to Cancer” page, one can learn that “Facebook Credits are the safe and easy way to make payments on Facebook. You can buy Facebook Credits using PayPal, your credit card, or mobile phone. Please keep in mind if your donation includes Facebook Credits that you received for free, the value of your donation will be reduced by those free credits. Also, your donation may not be tax deductible, so please consult a tax professional. For this event, Facebook is waiving its processing fees and 100% of your donations go to Stand Up To Cancer.”

Facebook has ambitious plans for its Credit initiative: it “wants Credits to be the universal currency in social games on its platform.”  The social network is using Credits with a Target stores partnership.  Earlier this month, Facebook took “a step closer to establishing Credits as the exclusive payment system for virtual goods on the social networking site, wrapping up a deal with the biggest social game company, Zynga…Facebook gets a 30% cut from the game developer for all transactions via Credits.” Virtual goods, as its called, is already a major business–estimated with $1 billion sales this year.

But there are questions around Facebook Credits and other virtual currencies–on privacy, consumer protection rules, and digital marketing.  Charities and others should be more cautious when endorsing such schemes.  The FTC, EU and other regulators need to place digital currencies on a real–not virtual–policy radar.

Microsoft Fuels Youth Obesity Epidemic via Xbox tie-ins: Digital Product Placement and Beyond

Microsoft is one of the most aggressive online marketing companies targeting teens online.  Across the globe, Microsoft Advertising touts its ability to deliver interactive food and beverage ads on PCs, mobile phones, gaming devices and via IM, Bing, etc.  Teens and young adults are the key target–but so are young children.  In its desperation to catch up with online ad leader Google, Microsoft has strained to be the “yes we will” digital agency.  For several years, Microsoft has had a close tie with Pepsi’s Doritos and Mountain Dew, offering various special games that feature the chip.  Now Microsoft is continuing that alliance, as the new Halo:Reach edition comes to market.  As explained by Variety, “helping build Microsoft’s brand is Madison Avenue, which has fully embraced the franchise’s main character, Master Chief, and turned him into a pitch soldier, with PepsiCo plastering him on 300 million Mountain Dew cans and 30 million bags of Doritos for the launch of the latest game.”

Microsoft officials–and those who play a influential role in the company–should not endorse digital marketing schemes that target youth–and especially contribute to such major public health problems as youth obesity.  For shame, Microsoft.

Google’s non-neutral YouTube–Gives Advertisers “Brand Protection” to bypass online videos

Google, like other major advertising and media companies, works hard to please its biggest advertisers.  For decades, radio and TV networks relied on Standards and Practices divisions to screen programs to make sure they were suitable “environment” for commercials.  So-called “brand protection” has mushroomed online–as we predicted it would many years ago.  The business model for TV and the Internet are aligned–it must please the Fortune 1000 advertiser first.  So it’s no surprise that Google has launched a “brand protection feature” for YouTube, explains Ad Age, that provides “more control for advertisers to exclude objectionable videos, genres, channels.”  Ad Age explained that YouTube’s new feature, is called “target excludes.” It’s “part of the site’s Video Targeting Tool, which gives advertisers the choice to exclude as few as one video they don’t want their product associated with as well as specific genres and channels. The feature addresses the most often-criticized aspect of YouTube: You can buy video there, but you never know what you’ll get.Other uses for this new feature by advertisers include improving returns by excluding channels or videos that are not relevant to the brand or those that are performing poorly.”

Here’s how Google explains it: “We’re constantly working to give advertisers control and flexibility over their YouTube campaigns. We place great value on this because ads are an extension of what a company represents as a business, and we want YouTube to be a place where that reputation and image can flourish. To that end, we’ve been rolling out features to keep advertisers in control of their campaigns…Google has also been investing significantly in ensuring brand safety, transparency and control for advertisers across the Google Display Network. We’re hoping that these added layers of control will make your campaign targeting even more precise.”

As we said, so-called online brand protection is a booming business.  But its purpose, explains one online advertiser, is to be “a preemptive technology and is designed to block ads from appearing next to controversial content…protecting brands from potentially damaging negative associations resulting out of negative content adjacencies.”  But questions should be raised now about how decisions will be made placing videos and other content on so-called censoring “whitelists” [which are really blacklists]. How will it ultimately affect the diversity of controversial content online?  Does YouTube further go from a quasi common carrier to an environment where, as we already see, Google favors some content over others?   Will the online medium be further transformed to reflect the TV model, with consequences to serious journalism and independent content?  The questions are larger than what Google does.  But given Google’s network neutrality flipflop and its online ad and data collection ambitions, a debate about the impact of so-called “brand protection” on the future of the online media is in order.

Retargeting 3.0–It tracks and observes a consumer, adds new data–and changes its sales pitch

Yesterday, the New York Times ran a front-page story on retargeting--the practice of stealthily tracking an individual user online in order to keep delivering sales pitches–including for health and financial products.  We gave the NYT lots of information, including how so-called “smart” ads technologies are now melded with retargeting–for so-called “Retargeting 3.0.“  [My CDD and USPIRG, btw, asked the FTC to investigate retargeting back in 2007 and to protect consumers].  Here’s some of what we sent to the Times.

From Criteo:“Retargeting allows you to find your previous website visitors across the Internet and display relevant banners to lead them back to your website to complete their transaction. Bringing ready-to-buy users back to your website after they have left should be a key part of your customer acquisition and conversion strategy. Criteo provides a breakthrough dynamic personalised retargeting solution…Criteo has revolutionised retargeting with the most sophisticated form of dynamic personalised retargeting. Over the past decade there has been a slow evolution of retargeting. This third generation of retargeting enables an advertiser to show each lost visitor a unique banner based on his/her very specific past interactions on the advertiser’s website. This new form of retargeting involves on-the-fly, real-time personalised banner creation and has a dramatic impact on campaign performance.”

Retargeting data now incorporates user information from outside demand side platform sources, and can the rights to retargeting you can be sold to the highest bidder via online ad exchanges, such as the one run by Google.

A recent MediaPost panel sums up how retargeting has evolved:
Re-Thinking Re-Targeting 
Re-targeting continues to be the tried and true workhorse of behavioral targeting. Tagging and retrieving someone who has already shown an interest in your business is about as simple a use of the BT model as it gets. But it is not so simple any more, and like everything else in this complex ad economy, re-targeting too is in for a upgrade. Dynamic ad creation driven by recommendation engines offers new opportunities to marketers to be even more effective. Demands for greater accountability, control over placement and clearer attribution press the ad networks and tech providers to provide new levels of transparency. And just like everyone else in the ad economy, re-targeting is working its way through questions about metrics and pricing, do marketers optimize and pay according to clicks, conversions, purchase? And what role does retargeting now play in this larger field of audience creation and the age of the DSP?

Retargeting illustrates how online marketers have deployed armies of digital private detectives to shadow us online.  They watch us closely, take notes, even learn about us, and then appear when we don’t expect it.  Consumers shouldn’t have to confront such digital surveillance.  Retargeting is “Exhibit A” in making the case to lawmakers that consumer privacy online should be protected.

Questions should also be raised about retargeting and consumer protection.  Should I get a better discount because the data collected about me indicates I spend more or live in an expensive neighborhood? Or that because they believe I am a certain ethnicity, I might spend more on certain products.  Retargeting is a non-transparent marketing technique that raises important consumer protection issues about the use of digital advertising.  Consumers require a fair deal online.

PS:  Here’s how Google explains its retargeting service–which in typical Silicon Valley meets George Orwell fashion, it calls “remarketing’ [for the Google Content Network]: “Remarketing is extremely effective because it targets a highly-relevant audience. With it, you can target users who:

  • have visited your website or viewed specific product categories on your site
  • didn’t convert or who abandoned their shopping cart
  • have converted (in order to up- or cross-sell to them)

If you’re already driving traffic to your site through other means, like contextual targeting or your search ads, remarketing is a great complement to those efforts to increase your return-on-investment (ROI).”

and we believe in fair play.  Here’s what Microsoft says its “remessaging” service can do:   “After consumers visit your site, see one of your campaigns or click through on an ad, remessaging offers several ways to continue the conversation and ensure that your message is seen by the people to whom it matters most.  With site remessaging, you can re-engage a consumer to complete a purchase or further engage with your brand. Creative remessaging drives brand perception, awareness, and favorability, and enables advertisers to re-engage audiences who have seen or clicked on an existing campaign. Email remessaging complements email assets such as newsletters by placing tags and accessing the same email recipients to reinforce your message to a loyal audience.”

and Yahoo!:  “…Enhanced Retargeting, which combines standard site retargeting with dynamic ad generation. For example, users who visit an airline website to check offers for flights from SFO-JFK can be served a personalized offer for that specific flight when they visit a page within the Yahoo! Network. In a recent trial, a market-leading online travel company saw a 230% increase in total bookings and a 651% increase in click-through rate when comparing Enhanced Retargeting to their traditional retargeting campaign.  Recognizing the need for more focused audience segmentation and improved control, Yahoo! Search Marketing will offer advertisers Enhanced Targeting capabilities for Sponsored Search and Content Match programs. New features are designed to extend the advertiser’s control over where and when an ad is shown at both the campaign and ad group level, including what time of day and day of the week an advertiser would like campaigns to run (ad scheduling) and what age and gender they’d like to reach (demographic). Advertisers will be able to vary their bids for different segments in order to increase their ability to reach the desired audience.”

“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.

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.

Google: Creating a “dynasty” in online data ad targeting

From the Connected Marketing Week in SF, via ClickZ:  Google is simultaneously attempting to fill the role of ad exchange, ad network, DSP (through its Invite Media acquisition), and media agency…Michael Rubenstein, president of AppNexus and the former head of Google’s ad exchange efforts, said Google has been admirably fair and transparent. But he said that could change.”Google is putting together the pieces to form a dynasty,” he said. “So far they’re behaving pretty well as far as keeping the ecosystem open to everybody, probably because they need to. But we’ll see what happens over time as they accumulate more market power.”

Google tells investors via SEC: New privacy laws could be “inconsistent with our data practices” And the “hundreds” of engineers they have working on display ad technology

Google’s 10Q second quarter report just filed at the SEC has an interesting reflection on how the online ad giant views the privacy issue.  It wrote that:

Regulatory authorities around the world are considering a number of legislative proposals concerning data protection. In addition, the interpretation and application of data protection laws in Europe and elsewhere are still uncertain and in flux. It is possible that these laws may be interpreted and applied in a manner that is inconsistent with our data practices. If so, in addition to the possibility of fines, this could result in an order requiring that we change our data practices, which could have an adverse effect on our business. Complying with these various laws could cause us to incur substantial costs or require us to change our business practices in a manner adverse to our business.

And a somewhat related angle–Google’s focus on generating more ad dollars online.   Brandweek reports, in an article on all the venture investment going into expanding online targeting that:

Neal Mohan, the vp of product management at Google who leads its display ad efforts, believes the display ad market could be five times the size it is today, if the system for buying ads was more efficient and the performance measurement was better.

“It can be done, frankly, a lot better than it is today,” Mohan said, noting Google now has “hundreds” of engineers working on display advertising technology.

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