In a December 2009 interview in New Media Age, Facebook’s director for commercial marketing in the EMEA and UK market explained that [excerpt]: CPMs on our home page are three or four times those of Yahoo’s. On click-through, the engagement levels we’re getting are 10-15 times that. Not 10% more, 10-15 times Yahoo’s click-through rates. This is where we’re selling to P&G and those big brands. The other side of our business is performance: those little square boxes, ASUs [Ad Space Units], that appear everywhere except the home page. 80% of our inventory is driven through a self-service auction model. We’re on 50bn of them a month in the UK. That’s scale. And big brands are saying they’re getting more volume and lower cost than Google on Facebook right now…The big thing we’re bringing to the market in early Q1 is Nielsen-branded research, which will reveal what people are doing, using awareness consideration and favourability metrics that are important to branded advertising. We’ll be able to quantify this via Nielsen.“
Category: European Commission
Which “Network/Entertainment” Company is Expanding its use of Neuromarketing? NeuroFocus Looks for Specialist to help that showbiz client “Develop actionable insights from neurological studies”
Companies that rely on influencing brain behavior in order to achieve marketing goals are treading on a very slippery regulatory slope. Nielsen-backed NeuroFocus is currently searching for a “Partner” in its “Consulting Practice.” That person will be “responsible for the development and presentation of neurological studies commissioned by our key client in the network/entertainment industry…Of primary focus will be…developing insights from the neurological study results to benefit the client leading to a lasting relationship. Summary of essential job functions:
…
• Develop actionable insights from neurological studies
• Present results of neurological studies directly to clients
• Deep understanding of entertainment industry / network & cable television industry
• Experience in management consulting, market research, and advertising…
NeuroFocus, Inc. is the market leader in bringing neuroscience to the world of advertising, messaging, packaging, and product development. NeuroFocus clients include Fortune 100 companies across consumer package goods, food and beverage, entertainment, financial services, automotive, consumer electronics and retail sectors. NeuroFocus clients also include major companies in the TV and Motion Picture industries.”
Facebook and Privacy: Why the FTC and EU Have to Become Our Real “Privacy Wizards”
Facebook is a very valuable tool. But its effort to harness more of its member data–and cloak it as a “privacy” approach–illustrates how out of touch Facebook is with the fundamental concept of personal privacy. That’s why the FTC and EU Privacy commissioners have to step in and act as Facebook’s true “privacy wizard.“ Left on its own, with its business interests driving Facebook to make our information available to them and their business partners, the privacy of 100 million US users (and even more globally) are at risk. Facebook cavalier approach that your “name, gender, current city, networks, Friend List and Pages” is considered by them “publicly available information” illustrates this. Facebook has framed these changes as beneficial to users, claiming that its “new, simplified privacy settings giver you more control over the information you share.”  Classic PR doublespeak with a Silicon Valley accent.
We have raised concerns about Facebook in the past–especially with Beacon and also with the third party apps (my CDD played a leading role providing information on the data collected by third party applications to the leading Canadian privacy group).  I asked Facebook officials to brief me and other privacy groups on the recent changes: that briefing was on Wednesday. I wanted Facebook to explain how its new privacy approach allowed its users to control data mined by Facebook and its third party developers used for interactive advertising and marketing. I was so appalled by what Facebook officials said at that meeting that, after some additional research into Facebook’s plans, my Center for Digital Democracy decided to join with EPIC and others in a complaint to the Federal Trade Commission.
I was flabbergasted to hear Facebook officials claim that its new changes actually reflected “Fair Information Principles” for privacy. That in their view the concept of privacy has “evolved,” with users wanting to share all their information via what they call the “social graf.” Facebook officials said that only a few people (implying privacy advocates) wanted to have control over their information. That they didn’t consider allowing users to control the data collected on them for marketing and advertising purposes as part of a privacy regime. Data used for advertising–even to Minors–is considered outside of what a person should be able to control, in Facebook’s view.  They also suggested that those who didn’t appreciate what they called its privacy “permission” model were out of step.
Nothing was said by Facebook officials about the company’s real motivations for expanding its access to its user data (as if business reasons had nothing to do with Facebook’s approach to member privacy!). As InsideFacebook recently explained, “Last week, Facebook launched a major initiative geared towards getting users to share more information more openly…However, while many people don’t want to share much information publicly online today, some do. For those people, Facebook’s historical default privacy settings did not make it the right product for them. As a result, Facebook recognized that its default-private model made it vulnerable to other services with default-public models, like Twitter…Facebook’s decision to make the recommended privacy options for profile data like “Family and Relationships†and “Posts I Create†be set to “Everyone†– as well as its move to remove privacy controls for Gender, Current City, and Friends – were pretty aggressive by almost anyone’s standards. In particular, its decision to present users with a binary choice between “Everyone†and “Old Settings†for some privacy preferences was especially confusingly executed…Facebook isn’t satisfied with a mostly-private platform: it wants to be the single place where both sensitive personal information is shared and public memes spread…Facebook has shown, as recently as a few months ago with its launch of the “real-time†stream as the default News Feed, followed by its decision a few months later to go back to the algorithmic News Feed, that it is capable of making suboptimal product decisions due to intense feelings about services like Twitter…”
Relevant too are Facebook’s plans to enable its third party developers to gain access to more of its member data, including their email addresses. As Facebook explains on its “Roadmap” for developers, “We’re excited to announce that you will soon have the ability to ask users for their primary Facebook email addresses, providing you with a direct channel to communicate with your users.” At our briefing, Facebook officials said they were soon addressing third party apps and their access to data. But given Facebook’s failure to protect basic user privacy, we have serious doubts it will deal with data access by its developers.
CDD will be working to educate the FTC, EU privacy officials and others. Facebook is consciously devaluing the notion of privacy for its own interests. How Facebook deals with user data–including what is used for advertising–will be on the policy agenda. The complaint from EPIC, Consumer Federation of America, Privacy Rights Clearinghouse, CDD and others opens the door for a serious examination of Facebook’s data collection practices.
CDD Joins Facebook FTC Complaint
“Facebook’s new policy has seriously eroded the privacy rights of its members,” explained Jeff Chester, executive director of the Center for Digital Democracy (CDD). “The leading social network has not acted responsibly. It cannot be permitted to deliberately weaken the control its users have over their information, just because it may boost its bottom line. We call on the FTC to swiftly act on this complaint to protect the more than 100 million U.S. members of Facebook.”
Online Financial Marketing, Subprime Loans, Digital Banking & Neuromarketing–Why We Need the Consumer Protection Financial Agency
How we handle our money–including credit, loans and banking–is moving online. Digital marketing of mortgages, credit cards, student loans and other financial products will become the dominant way we relate to banking and related services. The CEO of Capital One has already said that ” [A] mobile phone is just a credit card with an antenna.” So called M-commerce (mobile commerce) will be a crucial avenue where we actually apply for credit on “the fly,” so to speak, with our cell phones themselves used to buy products.  Banks and other financial companies are using Facebook, other social media, online video, Twitter, search engines and interactive online marketing techniques to sell their services to consumers. They are also using digital media in PR campaigns designed to make consumers forget about their unethical behaviors which led to the current fiscal crisis.
Financial services companies are even using so-called neuromarketing–testing messages via fMRIs, for example–to help hone their marketing messages. Neurofocus, a Nielsen backed company that helps create digital and other ads based on brainwave research, released a study earlier this year that “dived deep into test subjects subconscious minds to discover their hidden, unspoken beliefs and feelings about financial institution brands.†They “tested consumers in its laboratory to determine exactly what financial brand messages they responded to best, at the deep subconscious level of their minds, where brand perceptions, brand loyalty, and purchase intent are truly formed.â€Â Financial marketers are also using behavioral targeting online, which stealthily collects data on us for tracking and target marketing. That’s why we keep seeing ads for credit cards and other money-related products. The information gathered as we fill in forms on the Internet can be sold as part of the online lead generation business. Online lead generation played a role in the subprime debacle, as consumers provided marketers with personal information that helped trigger pitches for mortgages and other credit.
Alternet has just published my article on these issues. It can be found here.
Microsoft’s latest Neuromarketing Research for its Xbox LIVE: Tracking “brain activity, breathing rate, head motion heart rate, blink rate and skin temperature”
Microsoft, Google and Yahoo, among many others, are using the latest tools from neuroscience to hone their interactive marketing services. Microsoft released its latest neurmarketing “groundbreaking “study yesterday, which used “neuroscience to compare Xbox LIVE to traditional video…” Here’s an excerpt from the release:
In the study, Microsoft and Initiative, a division of Mediabrands, measured advertising effectiveness across media types and explored how neuroscience technologies can help answer two questions that marketers have asked for years: how to measure audience engagement with their brand and how to measure advertising impact across several media types.
This pilot study, conducted by EmSense, a leading neuroscience company, involved two of Initiative’s clients, Hyundai and Kia Motors, in which test subjects were exposed to various media and advertising campaigns from the companies while wearing a special sensor-laden headset. The headset tracked brain activity, breathing rate, head motion, heart rate, blink rate and skin temperature. Test subjects were also asked to take a post-exposure survey.
The Xbox LIVE campaigns consisted of interactive billboards that users could click through to a branded landing page where they could then interact with content and download videos. The traditional videos used in this study included a 30-second television spot for Hyundai and a 60-second in-theater spot for Kia Motors America.
The results showed more time spent, greater recall and higher levels of emotional and cognitive response in association with the Xbox LIVE ad campaigns than with the traditional video spots. The interactive capabilities of Xbox LIVE enabled an additional 238 seconds of engagement beyond the traditional video ad, which lead to increased unaided recall and brand awareness. For example, the Xbox LIVE ads delivered 90 percent unaided brand recall, compared with 78 percent unaided brand recall rates for the 60-second spot. In addition, the Xbox LIVE ads delivered higher levels of both cognitive and emotional responses.
“We know from our standard performance metrics that our Xbox LIVE campaign is effective,” said Michael Hayes, executive vice president, managing director of Digital, Initiative. “What’s compelling about this research is that we now know that consumers are making an emotional connection with Kia Motors America as well.”
Even more compelling is the methodology that allows brands to compare impact and engagement across multiple measures and across a variety of media types…said Mark Kroese, general manager of the Microsoft Advertising Business Group, Entertainment & Devices Division, Microsoft. “…If we can crack the code on this, marketers and advertisers will be able to pinpoint ROI by media type and know which campaigns are yielding the greatest impact.”
Consumer and Privacy Groups at FTC Roundtable to Call for Decisive Agency Action
Washington, DC, December 6, 2009 – On Monday December 7, 2009, consumer representatives and privacy experts speaking at the first of three Federal Trade Commission (FTC) Exploring Privacy Roundtable Series will call on the agency to adopt new policies to protect consumer privacy in today’s digitized world. Consumer and privacy groups, as well as academics and policymakers, have increasingly looked to the FTC to ensure that Americans have control over how their information is collected and used.
The groups have asked the Commission to issue a comprehensive set of Fair Information Principles for the digital era, and to abandon its previous notice and choice model, which is not effective for consumer privacy protection.
Specifically, at the Roundtable on Monday, consumer panelists and privacy experts will call on the FTC to stop relying on industry privacy self-regulation because of its long history of failure. Last September, a number of consumer groups provided Congressional leaders and the FTC a detailed blueprint of pro-active measures designed to protect privacy, available at: http://www.democraticmedia.org/release/privacy-release-20090901.
These measures include giving individuals the right to see, have a copy of, and delete any information about them; ensuring that the use of consumer data for any credit, employment, insurance, or governmental purpose or for redlining is prohibited; and ensuring that websites should only initially collect and use data from consumers for a 24-hour period, with the exception of information categorized as sensitive, which should not be collected at all. The groups have also requested that the FTC establish a Do Not Track registry.
Quotes from Monday’s panelists:
Marc Rotenberg, EPIC: “There is an urgent need for the Federal Trade Commission to address the growing threat to consumer privacy. The Commission must hold accountable those companies that collect and use personal information. Self-regulation has clearly failed.â€
Jeff Chester, Center for Digital Democracy: “Consumers increasingly confront a sophisticated and pervasive data collection apparatus that can profile, track and target them online. The Obama FTC must quickly act to protect the privacy of Americans,including information related to their finances, health, and ethnicity.â€
Susan Grant, Consumer Federation of America: “It’s time to recognize privacy as a fundamental human right and create a public policy framework that requires that right to be respected,†said Susan Grant, Director of Consumer Protection at Consumer Federation of America. “Rather than stifling innovation, this will spur innovative ways to make the marketplace work better for consumers and businesses.â€
Pam Dixon, World Privacy Forum: “Self-regulation of commercial data brokers has been utterly ineffective to protect consumers. It’s not just bad actors who sell personal information ranging from mental health information, medical status, income, religious and ethnic status, and the like. The sale of personal information is a routine business model for many in corporate America, and neither consumers nor policymakers are aware of the amount of trafficking in personal information. It’s time to tame the wild west with laws that incorporate the principles of the Fair Credit Reporting Act to ensure transparency, accountability, and consumer control.â€
Written statements and other materials for the roundtable panelists are available at the following links:
CDD/USPIRG: http://www.democraticmedia.org/node/419
WPF: http://www.worldprivacyforum.org/pdf/WPF_Comments_FTC_110609fs.pdf
CFA: http://www.consumerfed.org/elements/www.consumerfed.org/File/5%20Myths%20about%20Online%20Behavioral%20Advertising%2011_12_09.pdf
EPIC: www.epic.org
Pay for Engagement Ad Model Raises Consumer Protection Issues
Let alone issues related to editorial independence. Here’s an excerpt from the UK’s Marketing Week on what P&G is doing with the pay per engagement model (something we believe has privacy implications):
Brands are moving away from simple CPM deals and click-through rates. Indeed, back in September it emerged that Procter & Gamble was briefing media owners about a new payment model that would see publishers paid more for users that go beyond simply seeing the ads and sign up for newsletters, play games or watch videos, for example…It also means media owners having to work harder on the relationship between content and advertising… As publishers continue to struggle, the possibility of bringing significant brand money online is too compelling to argue about the conditions attached.
Games Microsoft Plays: “consumer online behavior” tracked on its video gaming service [a “massive” invasion of privacy!]
Microsoft’s just announced a new consumer tracking and profiling tool for advertisers using its Massive video gaming platform service. Calling it a “breakthrough” in its press release, the new Microsoft/comScore research tool enables advertisers:
“… to see the direct impact that in-game advertisements have on consumer online behavior…, advertisers will get an inside look at the degree to which in-game ads motivate gamers to visit Web sites, conduct brand-related search queries and engage in other online actions, something that previously had gone unmeasured…Through this collaboration with comScore, we will also now be able to measure those consumer actions that result from in-game ads. We think this has the potential to literally ‘change the game’ for both advertisers and publishers who want to improve the effectiveness of their in-game ad efforts.â€
AdEffx Action Lift for Gaming matches in-game console ad serving data from Massive with comScore’s third-party, post-campaign panel data to track and measure in-game advertising effectiveness. By combining Microsoft’s proprietary, non-personally identifying Anonymous ID data, which is common across Xbox LIVE and Microsoft Web properties (known as Windows Live ID), with user data from comScore’s panel of 2 million Internet users worldwide, comScore can determine if panelists who saw in-game advertising subsequently visited a brand’s Web site, searched brand-related terms or engaged in other online behaviors important to advertisers.”
Microsoft Advertising offers “Profile Targeting”
As we just told the BEUC conference on consumer protection and online marketing, we couldn’t make this up if we tried. Here’s what Microsoft Advertising says it can do via its UK site for marketers:
Just say who, when and where
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Profile Targeting can help you find the people you’re looking for by who they are, where they are and when you want to be seen by them. Just name the characteristics that matter most to you. It could be anything from the consumer’s age, gender or country, to the day of the week you want to target the audience on.
[and here’s what they say about behavioral retargeting, which they euphemistically now call “re-messaging“]”
With Re-messaging we can narrow our audience by finding the people who have already visited you. It means we can ensure they always stay intouch and help create continual engagement with your brand. Re-messaging is effective on its own, but works at its best whencombined with other forms of targeting and campaign performance. By placing action tags on your website, we can track visitors throughout the course of their online journey and re-message them on our network. For example the consumer may have previously searched for a hotel but not booked, compared credit cards but not applied, or visited a promotional website. Whatever it may be, if they’ve gone part way to making a purchase or performing an action, we can help you continue the conversation and ensure that the relevant message is seen by the people it matters most to.