Google Exec on Behavioral Targeting: “massive benefit for advertisers” [note he didn’t call it “Preference” Marketing!

Online industry reaction to the Wall Street Journal privacy series, and generally, illustrate a basic disconnect in how they view the privacy concerns raised by digital profiling, tracking and targeting.  Leading online marketers frequently claim that behavioral targeting and related data-focused techniques are actually good for the consumer.  The problem, they argue, is that consumers lack basic information about the process.  Presumably, they believe, if we really understood how it worked, we would be relieved.  In truth, of course, the opposite is true.  The more one knows about the processes underlying what the online ad industry claims is a digital marketing “ecosystem,” the more a consumer and citizen should be alarmed.

In the UK, EU and in the U.S., companies like Google and Microsoft are working together on PR campaigns to convince both the public and policymakers all is well with behavioral profiling for marketing.  One Google executive in the UK recently told New Media Age that “The use of behavioural targeting is growing and is a massive benefit for advertisers wishing to serve more relevant ads. It also helps pay for content and services. But there is user confusion about how it works…Lack of understanding is the biggest problem facing behavioural targeting in the UK. There’s a knowledge gap between those who work in the industry and are familiar with terms such as cookies, remarketing and aggregated data, and users who search the web for information and goods. It’s our job, along with the rest of industry, to inform those users about how online advertising works and the choices they have.” 

But in reality, the industry–including Google–has failed to be candid with consumers and policymakers about all the data collection practices that are deployedsuch as by Google subsidiaries Doubleclick, Admob, & Teracent, for example.

Microsoft is also very bullish about behavioral targeting–especially since it’s in a global digital fight with Google to deliver data-enriched ad targeting for the biggest brands.  In the same New Media Age issue [22 July 2010], Zuzanna Gierlinska, head of Microsoft Media Network at Microsoft Advertising explains that:  “We’re not saying you should use targeting – whether that’s behavioural targeting or re-messaging – just to push conversion.  But it can have a strong brand uplift. People come into a channel, see a nice creative with high-impact imagery and then go away. But that message stays with them.”  The article goes on to explain that: It’s this ability to talk to people on an ongoing basis, and give them a better experience, that’s the key to why combining re-messaging and behavioural targeting with a standard brand buy works, argues Gierlinska. For example, with re-messaging, users are already a warm lead, while behavioural targeting tightens the focus on users who are demonstrating an interest… This positive experience benefits both conversion and brand uplift among the target audience. “Targeting benefits everyone,” Gierlinska says. “It benefits the publisher because it’s not wasting impressions or serving ads to just anyone. It benefits the advertiser because it has efficiencies with its media buy. But it’s also really beneficial to the users because they’re getting relevant messaging that’s timely and ideally helping their productivity in what they’re doing online, rather than just being served random messages.”

Much of how the industry addresses the behavioral targeting and its related data mining application are rationalizations [maybe all their therapists are on vacation or Freudians!  Just kidding].  But it reflects a failure by industry leaders to recognize a serious problem that affects the public.  That’s the same kind of `it’s all good for us, regardless of what we do’ behavior that led to the recent–and ongoing–global financial collapse.

WSJ Begins Online Ad/Privacy Series. Plus Online Marketers Explain Behavioral Targeting, including role of social media for predicting people’s behavior “before they do it”

The Wall Street Journal launched an important new series on the online marketing and data collection/targeting industry.  Julian Angwin and colleagues have the the first main piece entitled “The Web’s New Gold Mine: Your Secrets.”  The subhead underscores what we have been telling policymakers and others for the last several years:  “…one of the fastest-growing businesses on the Internet is the business spying on consumers.” The theme of the series: “Marketers are spying on Internet users – observing and remembering people’s clicks, and building and selling detailed dossiers of their activities and interests.”

They have done a terrific job, including producing a innovative video on how cookies work, including its history online. There are special graphics as well illustrating the data tracking process.  They also discuss the growth of so-called predictive behavioral targeting, including the use of social media.  The OpenAmplify CEO explains “Social media is an amazing opportunity. For the first time in marketing history we have hundreds of millions of people online telling us what they like, what they hate and what they’re going to do before they do it … That’s extremely valuable data.”

Meanwhile, online marketers are preparing to place the forthcoming behavioral ad “icon” from the online ad industry– that’s supposed to help the industry politically head off consumer protection rules.  Here’s how one legal expert working with online marketers, in discussing the icon, describes behavioral targeting:

“Behavioral ads use technology that tracks a user’s surfing behavior on the Internet. Key data includes clickstream data such as searches made, content read, site-visit times, and websites visited. With this key data about a specific user, advertisers can create a behavioral pattern that can be linked to a specific online demographic, which becomes the basis for ads that target the specific demographic…For example, a frequent traveler can be tracked to different locations through geographically different IP addresses, and then by combining this information with cookie data, an advertiser can draw a clear picture of the person’s travel habits – destinations, length of stay, travel frequency, preferred airlines – plus much more.”

I doubt the forthcoming digital data collection and targeting “icon” and its accompanying information will stand the truth test!  How do you explain an entire “ecosystem” of data collection and profiling techniques, including social media marketing, neuromarketing, “immersive” video, online ad exchanges, etc. with a tiny digital [and appropriately named] ‘bug.”

Ad Lobby Research Says Vast Majority of Online Ads Involve Behavioral Profiling & Targeting

The online ad industry lobbying group–the Interactive Advertising Bureau [IAB]–has revealed results from its own research that show the widespread use of behavioral targeting.  In a post on its criticisms of privacy legislation introduced by Chairman Bobby Rush, the IAB explains that:

“In an IAB survey of ad agencies conducted earlier this year, we found that 80% or more of digital advertising campaigns were touched by behavioral targeting in some way.

That means the majority of what consumers do online–including when they deal with sensitive transactions involving their finance, health or other family matters–are being closely tracked and profiled.  In addition, the IAB attacks the important civil rights provisions in both the Boucher/Stearns and Rush bills.  That provision would ensure that data collection about a consumers racial, ethnic or sexual orientation would be better under the control of the individual.   You would think that the IAB leadership, including Google, NBC, CBS, and Disney, would support a policy that would restrict the potential use of online racial profiling.  But the IAB claims these provisions protecting multicultural and other consumers “could constrain multicultural marketing and media…These types of services provide great benefits to their audiences and the proposed restrictions would actually harm the very group of people they seek to protect.”  That’s an irresponsible position.  We should be able to protect civil rights and promote diverse online publishing.
The IAB’s claims that behavioral targeting is anonymous doesn’t hold up to the facts, as well.  The time for action by both the FTC and Congress has arrived.

Teens and Online Privacy: Empowering Adolescents to Control How Online Marketers Can Stealithily Target Them and Collect Data

Some commentators–and groups funded by online marketers that target teens–are worried that proposals to the FTC and Congress that adolescent privacy be protected will somehow create a system that requires forms of age verification online.  The coalition of leading consumer, child advocacy, health and privacy organizations filing comments at the FTC last week aren’t calling for the parental permission paradigm used by the Children’s Online Privacy Protection Act [COPPA] be extended to teens.  But there are many online commercial services specifically targeting adolescents–that’s their target market.  It’s those sites and services specifically focused on adolescents that we want to have better privacy safeguards.   We want those sites to be governed by an opt-in regime that gives teen users meaningful control of how their information is collected and utilized.  Those sites should be required to engage in the Fair Information Principles known as  “data use minimization.”  Commercial sites targeting adolescents should make its data collection practices fully transparent and under the control by the teen (including a truly accessible privacy policy).  In another words, a privacy safeguard regime that really should be available for everyone.  Teens are ‘ground zero’ for much of digital marketing–for examples see our site: www.digitalads.org [especially the update section].  If you look at the reports on that site, you will see that the most recent scholarly thinking is that brain development in adolescents occurs much later than what was once thought.  They don’t have the ability to effectively understand the intent of highly sophisticated interactive marketing and the corresponding data collection which underlies contemporary digital advertising. That’s why empowering them so they can protect their privacy strengthens their rights.

Google, ITA, Travel, Privacy and also Competition

Travel is a major part of the online marketing industry.  But it has lots of privacy concerns–who knows where you plan to go, spend time [in the exact location via geomapping, etc], how much money you generally spend, with your family or on business, etc.  There are a host of civil liberties issues related to commercial and government access to this data.   That’s one of the reasons why competition and privacy regulators around the world should closely critically analyze the proposed Google acquisition of travel information leader ITA Software.

Google is currently expanding its online travel advertising business–and swallowing ITA will undoubtedly boost its market share–and give it access to reams of additional data on consumers and business practices.  For example, in its Seattle regional office, Google is hiring several marketing specialists, including:


*Display Account Manager, Travel:  [“As a Display Account Manager, you’ll sell and manage advertising for the sixth-largest media property in the world and other Google display offerings. You will be a part of the team on the cutting edge of interactive marketing and media. You will drive the online video marketplace forward and engage advertising agencies and brand marketers in programs that move the needle for their companies. The primary responsibility of the Display Account Manager is to drive new business revenue for YouTube and other Google display services and products with Fortune 1000 advertisers across multiple industries.”]   They also want an Account Manager, Travel Vertical and a Display Account Executive, Travel.  Other travel online ad sales jobs are posted for London [“As a Google Industry Manager, Travel you will be working with clients to provide digital solutions for sales & marketing objectives via a variety of Google’s Search, Display and Tools. This job is a mix of finding and managing new and existing business customer relationships, and working closely with the Industry Head to develop Google’s marketplace in the Travel sector. You’ll combine digital media and deep commercial knowledge with strong presentation and communication skills. You’ll own the relationships with clients and agencies, targeting, educating and developing new clients to grow the business in unpenetrated territory.”]; Australia [Account Strategist, Travel Industry].  Plus its DoubleClick division performs travel related online marketing work.  Of course, given Google’s recently expanded role providing mobile ad targeting, via its Admob acquisition, related privacy and competition issues are also raised.

Draftfcb uses neuromarketing, academic ties to create Institute for Subliminal Advertising

Actually, the ad giant says it’s calling its new research arm the Institute of Decision Making. But given their plan to harness neuromarketing to better tap into the “instinctual ways that consumers behave,”  we think it should be renamed.  At the Cannes ad festival, Draftfcb discussed, according to a report, “how advertising messages have a mere 6.5 seconds to make a connection with the audience.”  A Draft exec. told the New York Times that “[U]nderstanding the foundation of consumers’ behavior decisions has become more complex [as they] consume more information and make decisions faster” [than before].   Hence, marketers like Draft–whose clients include MillerCoors and Levis–want to use neuroscience to create ads that deliberately bypass  a consumers rational decision-making system.   The ad agency is working with academics at UC Berkeley and Stanford–raising questions about the role scholars should play helping marketers–or anyone else–deliberately tap into our subconscious minds in order to influence our behavior.

Online Ad Lobby and Chamber Celebrate Victory over Consumer Protection & FTC

Yesterday, the online ad lobby [IAB, ANA, DMA]–working with Chamber of Commerce–scored a major political victory by forcing the Financial reform bill conference committee to drop proposed provisions that would have strengthened the FTC.  Under the House bill, the FTC would have been given the same kind of regulatory authority most federal agencies have [APA rulemaking].  Marketers and advertisers are celebrating their win, because it keeps the FTC on a weakened and short political leash.  While consumer protection is significantly expanded because of the CFPB and new financial rules, the FTC is to remain largely hamstrung.  The online marketing and advertising lobby [including ANA, DMA–see below] were afraid that the newly invigorated FTC under Pres. Obama would require the industry to protect privacy online and also become more accountable to consumers engaged in e-commerce.   I heard IAB and Chamber are dancing in the streets! Congressmen Barney Frank, Henry Waxman and Sen. Rockefeller deserve praise for working hard to protect consumers, including their proposal on the FTC.

Here’s what two of the ad groups placed on their sites about the FTC issue:

Progress on FTC Enforcement Provisions in Wall Street Reform Conference

June 23, 2010

The marketing and media community has made substantial progress on defeating the broad expansion of FTC powers that is included in the House version of the Wall Street reform bill.  But we still need your assistance to keep these provisions out of the final bill.

Yesterday the Senate conferees presented an offer on the bill that rejected the new FTC powers that are in the House version.  Chairman Dodd indicated that while he may support changes in the Magnuson Moss rulemaking process, there is no Senate provision and these issues are too complex and important to be resolved in the context of the Wall Street reform bill.  Conferees hope to finish the conference this week so the final bill can be cleared for the President’s signature next month.

The House conferees may still continue to push for these provisions, so it is very important that marketers contact the Senate conferees to express our appreciation for their support and to urge them to remain strongly opposed to these new powers for the FTC in this bill.  Contact information for the Senate conferees is located here and our letter to Senate conferees is available here.  Please let the Senators know if you have plants or operations in their states.

ANA took part in a very important meeting yesterday with Senate Commerce Committee Chairman Jay Rockefeller on these issues.  We argued that these issues are very important to the entire marketing community and deserve careful consideration outside of the context of the Wall Street reform bill.  The Chairman strongly indicated that he will continue to push for changes in the Magnuson Moss rulemaking procedures this year.

If you have any questions about this matter, please contact Dan Jaffe (djaffe@ana.net) or Keith Scarborough (kscarborough@ana.net) in ANA’s Washington, DC office at (202) 296-1883.

http://www.ana.net/advocacy/content/2418

DMA Asks Financial Reform Conferees to Keep FTC Expansion Out of ‘Restoring American Financial Stability Act’

June 10, 2010 — The Direct Marketing Association (DMA) today was joined by 47 other trade associations and business coalitions in sending a letter to each of the conferees on H.R. 4173, the “Restoring American Financial Stability Act” (RAFSA), urging them to keep language that would dramatically expand the powers of the Federal Trade Commission (FTC) out of the final bill.

As the House and Senate conferees work to reconcile their versions of the financial regulatory legislation, the associations — which represent hundreds of thousands of US companies from a wide array of industry segments — expressed strong opposition to provisions in the House version of the bill that would expand the FTC’s rulemaking and enforcement authority over virtually every sector of the American economy.

“The balance struck in the Senate bill is the right one,” said Linda Woolley, DMA’s executive vice president, government affairs.  “That bill makes the most sense in the context of financial reform legislation, maintaining the FTC’s existing jurisdiction without expanding its rulemaking and enforcement authority over industries and sectors that had nothing to do with the financial crisis.  Issues of FTC expansion deserve their own due consideration and debate in the more appropriate context of an FTC reauthorization, as has been done in the past.”

DMA and the other associations strongly believe that granting the FTC broad new authority is not a necessary or relevant response to the causes of the recent recession and, therefore, asked the conferees to oppose the inclusion of any provisions that would expand FTC authority, rather than making changes to the Commission that would have a fundamental impact on the entire business community and the broader American economy.

For more information please visit www.dmaaction.org.
http://www.the-dma.org/cgi/dispannouncements?article=1449

Yahoo uses neuromarketing for online ads: helping “maximize emotional connection and drive higher purchase intent” for Pepsi and others

The FTC and EU will need to develop safeguards on the use and role of neuromarketing techniques in advertising, especially when deployed for online campaigns.  Here’s an excerpt from a Yahoo post on the power of neuromarketing:

“…how do you measure the emotional connection in your advertising? Are some advertising mediums better than others in making that emotional connection? To answer these questions, Yahoo! partnered with NeuroFocus, a market leader in neurological market research. Yahoo! measured the brain waves of 74 people in real-time as they viewed online, print, and television executions of three ad campaigns from Pepsi, Infiniti, and Yahoo!…The simple answer is, consumers can’t hide their brain waves. By measuring the direct response of advertising at the brain level, we are able to observe and quantify pre-cognitive reactions
before reporting biases set in.

In this study, we specifically measured emotional engagement, purchase intent, and overall effectiveness. Ad responses were measured on a 10 point scale, with the median ad performance around 5.0.

GeographicTargeting_web

We found that the ads from all three brands performed above average across all platforms. However, when ads are optimized for the Internet, they maximize emotional connection and drive higher purchase intent. In fact, by designing ads that fully leverage the interactive strengths of the online platform, advertisers can even outperform TV in emotional engagement…When ads are optimized for the Internet, they maximize emotional connection and drive higher purchase intent
By taking full advantage of the unique capabilities of the Internet platform, the Infiniti ad scored higher on emotional engagement, purchase intent, and overall effectiveness than both the television and print version of this ad.”

from:  Making the Emotional Connection:  Advanced neurological research reveals deeper insights into ad effectiveness by medium.  Yahoo.  May 17, 2010.

Facebook: Ads, Data, and Dollars–its revenue comes from targeting “on users’ real life data”

Facebook execs frequently claim they don’t share their users personal information with advertisers.  They also always add that Facebook isn’t really that interested in advertising revenues.  But that’s not correct, as the Facebook Quarterly Business Review: Q1 2010 reflects.  Facebook, now cash positive, was said to earn somewhere between $600-700 million in revenues last year–up dramatically from the $150 million generated in 2007. The Quarterly estimates that Facebook should earn over $1 billion in 2010.  How?  “By growing multiple revenue sources, mostly around advertising,” it explains. Facebook is expected to earn some $350 million alone in 2010 from selling its ad services to big brands, with more growth expected.  In the last year, Facebook has “invested heavily in expanding its brand advertising efforts by opening up offices in Paris, Madrid, Milan, Hamburg, Sydney, Stockholm, Toronto and Los Angeles.”  The report says that Facebook will eventually earn some $20 billion a year, with a huge increase coming from big brand advertisers.

So-called performance advertising on Facebook [from social games, for example] is expected to bring in between $500-600 million this year.  There will also be additional revenues from Facebook’s virtual currency [and soon from mobile and location based marketing as well].

Facebook’s users aren’t informed about the datamining that occurs on what they post and communicate, including to their social networks.  We believe these systems require transparency and mechanisms of user control. And FTC and Congressional action.

CDD Statement on Facebook’s new privacy settings [Digital Deja-vu Dep’t!]

Facebook made some positive changes today, but only because of political pressure from policymakers and privacy advocates on both sides of the Atlantic.  Mr. Zuckerberg’s failure to acknowledge the political realities don’t bode well for Facebook’s future approach to privacy.  He appears to be living a Alice in Digital Wonderland fantasy, where changes are made on privacy only because Facebook has the goodwill of its users in mind.  Just last December 9, after all, Facebook made one of its typical self-reverential announcements that it was “rolling out easy-to-use tools to empower people to personalize control over their information.”  These changes triggered a user revolt, letters from Senators, an opinion ordering a reversal from the EU, and concern from the FTC.

There are more simplified and manageable privacy settings, and Facebook has made an important first (or back-tracking!) step.  Unfortunately, Facebook still refuses to give its users control over the data it collects for its targeted advertising products.  The defaults should also be initially set for non-sharing, with the minimization of data collection at the core of Facebook’s approach to privacy.   CDD and other privacy groups will examine these new settings and identify where further changes should be made, including on advertising data.  Meanwhile, we want Congress to hold hearings on social networking privacy, with Mr. Zuckerberg as a star witness.  Mr. Zuckerberg should be asked to explain how Facebook continues to develop new approaches to data collection and privacy–from Beacon to Instant Personalization–that continually lowers the bar–until the company has to do some form of hasty retreat.   Congress needs to examine how Facebook develops its approach to privacy, and what its business plans mean for the future.

CDD will also press the FTC to investigate Facebook, including acting on complaints filed with EPIC and other groups.  It’s time for the FTC to announce guidelines to protect social networking privacy on Facebook and other sites.
Jeffrey Chester
Center for Digital Democracy
jeff@democraticmedia.org