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.
Category: behavioral targeting watch
Harvard’s Berkman Center, its online marketing industry connections, and the need to prominently disclose
The Berkman Center is well-known for its work on digital media issues. But it has often failed to address–in its research and public work–the negative consequences of online marketing and interactive advertising. Berkman is partially funded by leading online marketers–including Google and Microsoft. When Berkman conducts research on such issues as children’s online marketing and privacy [an issue I am involved with], it should always prominently disclose on the first publication page its funding conflicts–including whether Berkman staff work with online marketers. Berkman should tell Congress and the FTC about such conflicts when it submits research and testimony.
For example, Berkman’s faculty co-director John Palfrey works for a venture investing firm that financially backs behavioral targeting and other online marketing companies. Professor Palfrey does disclose on his blog that in addition to his Harvard duties, he is also a “Venture Executive” at Highland Capital Partners. Highland’s “Internet and Digital Team,” which Prof. Palfrey serves on, has one current investment in Affine Systems, a video targeting company. Affine’s Video Platform explains it enables marketers to engage in behavioral targeting: “Affine integrates behavioral data from exchanges and exclusive third-party partnerships. This data is used to audit and optimize campaigns as they run. Detailed analytics are collected, and valuable retargeting data is generated with every campaign.” [“What makes the Video Targeting Platform special is the amount of insight it provides…by taking advantage of the data provided by Affine’s data partners, you can even target specific demographic or psychographic groups, and reduce the waste that is currently expected from online video buys.”]. Highland also invests in search engine and interactive TV companies serving the China market and many others. [Given the investments in China’s online market by Mr. Palfrey’s company, it also raises questions about Berkman’s Global Network Initiative role evaluating how companies like Google and Yahoo operating in China and elsewhere address human rights]. Previous online marketing (and behavioral targeted related) investments made by Highland included the youth online targeting company Bolt, Coremetrics, and mobile ad targeting company Quattro.
The well-known online analyst and commentator Dana Boyd is a Fellow at Berkman, and has made it clear she also works for Microsoft Research. But given Microsoft Advertising global efforts to extend the power of online marketing and personalized data collection, including its online ad research lab in Beijing, its support for neuromarketing in digital ads, and its extensive behavioral and online targeting apparatus–including for junk food targeting youth in its gaming divisions, we hope Ms. Boyd will more closely examine her employers work in the area.
Online ad research done by Profs. Goldfarb and Tucker: fails to address how online marketing really works– and also its implications for privacy, consumer protection and civil liberties
Whenever an industry is in political trouble, there is usually research made public that supports its position. Often, the research is actually funded by the very companies or trade associations involved in the political fight. The new paper “Privacy Regulation and Online Advertising” just released by Professor Avi Goldfarb [U of Tornoto] and Catherine E. Tucker [MIT], appears designed to discourage Congressional and FTC policymakers from enacting privacy safeguards. In this case, according to the authors, the paper wasn’t funded by industry. But in response to my question, Professor Tucker explained that “we have received funding in the past (for other work on internet advertising) from the NET Institute and from a Google/WPP Marketing Research Award. Avi has also received funding Bell Canada.“ The Net Institute’s board, btw, includes employees of Microsoft and Google, among others.
The new report is already being touted as evidence of the cost to online marketers if privacy rules are enacted. But the study is very problematic–and I believe fails to really analyze how online marketing works. The authors examined the impact of privacy rules in the EU and claim they have negatively impacted the effectiveness of online ads. But by only examining banner ads, they miss the point. Online marketing in both the EU, U.S., and elsewhere is really an integrated system involving an array of applications and techniques [where data is collected and used at all points]–from viral, to online video, social media, neuromarketing, games, mobile, etc. Indeed, at our CDD we follow the EU market very closely–including collecting data from EU based online marketers, trade associations, case studies, etc. These reports indicate tremendous success for online ads (and ironically, much of the innovation for online marketing comes out of the UK; Admap just reported it’s the German marketers in the forefront of neuromarketing).
Given the study’s discussion of the Boucher bill, it’s clear there is a political motivation here. But the main fault is how the study misses the key questions and ignores how the market really works. This paper needs to be revised and gets an incomplete!
PS: Btw, I also told the authors that Leslie Harris of CDT is a woman. They had her as Mr. Harris. Perhaps they also need a better fact-checker.
Behavioral Targeting for fast food: Brought to you by Yahoo! and Dunkin Donuts
]How would customers–even for donuts– feel if they knew their information was collected so they could be profiled, tracked and targeted. Read this excerpt from a new case study released by Yahoo!
Data becomes important in not only knowing what the customer wants, but also for getting them through the door. So Dunkin’ Donuts went online with a national Yahoo! campaign to gather data to drive in store sales; a strategy that franchisees can also use at the local level…The company primarily gathers its purchase behavior data through its Dunkin’ Donuts Perks Card (DD Perks), a rechargeable loyalty card that tracks data such as transaction amounts and time of day for purchases. Dunkin’ Donuts analyzes this data along with the information it gathers about its customers through website enrollments, gift card registrations, and point-of-purchase promotions to drive sales…Dunkin’ Donuts turned to Yahoo! because online marketing provided more accountability and engagement for the campaign…“You will know exactly how many people enrolled and how much you spent. You also know that it’s an efficient spend because you know those people are engaged, they opted in to get that communication, so they’re more likely to pay attention. Online is a persuasive tool, rather than a blunt instrument like broadcast,†says Tryder [David E. Tryder, Director of Interactive & Relationship Marketing at Dunkin’ Donuts]. Yahoo! helped Dunkin’ Donuts run a 41 day display campaign with promotions to encourage customers to enroll in its DD Perks program. Yahoo! Account Manager Steven Schmitt worked with Dunkin’ Donuts to implement behavioral targeting and to continually optimize the campaign to increase its performance. The campaign garnered over 16,000 sign-ups and through continual optimization, enrollment increased 300% between the first 14 days and the last 14 days of the campaign…With demographic, geographic, and behavioral targeting, Yahoo! can help Field Marketing Managers and franchisees go online and provide that relevant and local messaging for consumers.
Perking up Dunkin’ Donuts Perks.  Yahoo Advertising. May 18, 2010
Online Advertisers Side with Kids Junk Food Marketers: Opposing Consumer Protection by FTC, Even to Address Childhood Obesity Epidemic
The Interactive Ad Bureau [whose board members include Google, Fox, NBC, Comcast] is working with the marketing and data collection lobby to oppose proposed Obama Administration legislation that would enable the FTC to protect consumers. It’s clear from the comments below in Reuters, that the IAB is siding with those that don’t want to really address the youth obesity crisis. If the FTC is allowed to conduct the same rulemaking procedures that the FCC and other agencies already do, it might actually be able to better protect consumers, including kids. Shame on the IAB and its lobbyist colleagues for being on the side of those against the public health of our nation’s children. By preventing the FTC to engage in consumer protection, the IAB, ANA and others are supporting the same deregulatory scheme which led to the current financial disaster for so many Americans and our economy. Here’s the Reuters excerpt:
“A more powerful FTC could boost its oversight of advertising of sugary and salty snacks to children, the online collection of personal data by advertisers and green advertising, said Dan Jaffe of the Association of National Advertisers…This (financial reform/CFPA bill) is a fast moving train,” said Zaneis. “The FTC provisions that are likely to be added onto the CFPA bill really are industry’s no. 1 legislative priority.”
Ad Exchanges, Real-Time Auctioning of Users and Privacy: “our ability to target across many dimensions”
Last week, CDD, USPIRG and World Privacy Forum filed a complaint with the FTC asking it to protect the privacy of U.S. consumers.  Over the last two years, the growth of the data collection, tracking, analysis and targeting industry online–including the real-time auctioning off a consumer based on sets of their data–raises many concerns. This blog will be covering the field, as CDD works to encourage the FTC and the EU to address the issue. For now, it’s always useful to see what people from the online ad business say about these practices. In OMMA magazine, here are some excerpts from an article on the topic.
“We are definitely seeing the most exciting things for us in display in our ability to target across many dimensions,” says David Cohen, U.S. director of digital communications at Universal McCann. “Whether that is behavioral targeting or third-party data or our own platform – that is where we are seeing the most excitement – in targetability.” …“If you are an owner of display advertising, this is a great time to be in the marketplace,” says Dave Zinman, vice president and general manager of display advertising at Yahoo, which delivered 521 billion ad impressions in 2009… A new alphabet soup of suppliers and technologies emerged last year that promised at long last to apply better science to the art of display. Data providers like BlueKai or Media6Degrees helped marketers find the right audiences amidst the endless inventory of the Web. Much hope is circulating around real-time bidding (RTB) at ad-exchange engines like PubMatic, Yahoo’s RightMedia and The Rubicon Project. In these models, user data combines with real-time analysis of available inventory so an advertiser can buy individual impressions across a wide array of sites. Your ad appears only when just the right person hits a page… agencies have jumped on board with their own demand-side platforms (dsps) that buy inventory on the exchanges and networks along with third-party data in order to create their own audiences for clients…At the No. 2 seller of display, Fox, Mark Papia, senior vice president of the Fox Audience Network, is as enthused as anyone about the prospects for laser-targeting through the technologies and data layers that have been assembled over the last year. With 158 million uniques combined with data from Fox and 800 other publishing partners, he believes FAN has the scale and data to profit from next-gen display.
source: Can Science Save the Banner? Steve Smith. OMMA. April 2010.
NAI New “Study” on Behavioral Targeting: Self-Defense for Privacy-Threatening Data Collection
The Network Advertising Initiative (NAI), the online ad industry’s toothless self-regulatory scheme–has released a report designed to undermine policy safeguards protecting consumer privacy. The NAI engaged the services of Prof. J. Howard Beales--a former FTC official who largely supported self-regulation of online data collection during his tenure at the agency–to issue a study. Not surprisingly–and something anyone who follows behavioral online advertising knows–is that these practices work. When you track, collect, profile a consumer online and know their interests, background, location, you can make a better ad experience. Privacy is only mentioned once in the report.  The study’s message is really that if it makes money, don’t think of protecting consumer privacy.  The NAI explained in a release that “Behaviorally targeted ads sell for twice the price and offer twice the effectiveness of normal run-of-network ads, significantly enhancing the advertising revenue engine driving the growth of the Internet.â€
The suggestion that we should not be concerned about privacy even if these practices threaten consumer protection is absurd. Anyone who suggests that we should permit a wholesale invasion of privacy (and more) because it helps support online publishing isn’t addressing the critical question. How can we protect consumers and also have a robust online content system? Both can–and must–be done.
The IAB’s Targeting/Data Collection Glossary: Oh, What a Tangled Privacy Threatened Web They Weave [Annals of Geo. Orwell meets Madison Ave.]
The Interactive Advertising Bureau has released for public comment a telling document that illustrates why Congress and the FTC need to develop some rules to protect consumers. Take a look at the definitions the IAB has embraced on targeting and data collection–and ask yourself. Based on what they say, can this really be–as the IAB claims–non personal information? Here are some of the definitions from the Networks & Exchanges Quality Assurance Guidelines [Feb. 2010]:
*Audience Targeting:A method that enables advertisers to show an ad specifically to visitors based on their shared behavioral, demographic, geographic and/or technographic attributes. Audience targeting uses anonymous, non-PII data.
*Behavioral Targeting: Using previous online user activity (e.g., pages visited, content viewed, searches, clicks and purchases) to generate a segment which is used to match advertising creative to users (sometimes also called Behavioral Profiling, Interest-based Advertising, or online behavioral advertising). Behavioral targeting uses anonymous, non-PII data.
*Attribute – A single piece of information known about a user and stored in a behavioral profile which may be used to match ad content to users. Attributes consist of demographic information (e.g., age, gender, geographical location), segment or cluster information (e.g., auto enthusiast), and retargeting information (e.g., visited Site X two days ago). Segment or cluster information is derived from the user’s prior online activities (e.g., pages visited, content viewed, searches made and clicking and purchasing behaviors). Generally, this is anonymous data (non-PII).
*Behavioral Event – A user-initiated action which may include, but not limited to: searches, content views, clicks, purchases, form-based information and other interactions. Behavioral events are anonymous and do not include personally identifiable information (PII).
*Clickstream Data – A Clickstream is the recording of what a computer user clicks on while web browsing. As the user clicks anywhere in the webpage or application, the action is logged on a client or inside the web server, as well as possibly the web browser and ad servers. Clickstream data analysis can be used to create a user
profile that aids in understanding the types of people that visit a company’s website, or predict whether a customer is likely to purchase from an e-commerce website.
*Cookie – A small text file sent by a website’s server to be stored on the user’s web- enabled device that is returned unchanged by the user’s device to the server on subsequent interactions. The cookie enables the website domain to associate data with that device and distinguish requests from different devices. Cookies often store behavioral information.
*Cross-site Advertiser Analytics – Software or services that allow an advertiser to optimize and audit the delivery of creative content on pre-bought publisher inventory. Data can range from numbers of pages visited, to content visited, to purchases made by a particular user. Such data is used to surmise future habits of user or best placement for a particular advertiser based on success.
*Deep Packet Inspection – A form of computer network packet filtering that examines the data and/or header part of a packet as it passes an inspection point. In the context of online advertising, it is used to collect data, typically through an Internet Service Provider, which can be used to display targeted advertising to users based on previous web activity.
* Retargeting (or re-targeting) – The use of a pixel tag or other code to enable a third-party to recognize particular users outside of the domain from which the activity
was collected. See Creative Retargeting, Site Retargeting.
*Creative Retargeting: A method that enables advertisers to show an ad specifically to visitors that previously were exposed to or interacted with the advertisers’ creative.
*Unique User – An individual user that has interacted with online content, which is smaller than or equal to the number of cookies observed. The number of unique users to a website is usually an estimate. Â
A Glimpse Under the Data Collection `Hood’: Behavioral, Social Graph, Ad Exchanges, Ad Optimization
As CDD explained to the FTC and data protection commissioners, advances in online ad data collection, selling and targeting raise significant privacy concerns. This rapidly evolving infrastructure of user data auctioning requires scrutiny and safeguards. Here are some excerpts from jobs in the sector, which gives one a glimpse of what’s going on.
Director of Agency Development- NYC – eXelate
About eXelate
The eXelate Targeting eXchange is the world’s first and largest open marketplace for behavioral targeting data. Through participation on the eXchange, data buyers build an instant behavioral targeting function and optimize their campaign delivery, while data sellers gain insight on their audience, control over their data distribution, and build a new privacy–friendly income stream. The eXchange includes over 40 top ad network/agency buyers and dozens of leading publishers, who deliver targeting data on more than 170 million unique users each month.
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Account Manager – NYC – Netmining…
Netmining is a global provider of behavioral marketing solutions that are proven to increase conversion rates across websites, online advertising, email programs and offline sales channels. With a real-time profiling engine that understands each individual’s interests and buying propensity, Netmining enables companies to deliver highly relevant and personalized interactions across the entire customer lifecycle.
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Senior Account Manager – Social Targeting Data – NYC – Media6degrees: About Us
We are the first online advertising firm built from the ground up specifically to leverage “social graph” data. The power of this data is captured by the phrase “birds of a feather flock together.” We have mapped the social graph interactions of nearly 75 million US consumers and are the first company to offer “social targeting” which allows marketers to fully exploit the network value of every individual customer with whom they interact while also significantly improving response rates on new acquisition campaigns.
Our platform employs proprietary cookies to map the social graph. Our core data used to map the social graph has long been part of the standard Internet advertising protocols for trafficking advertisements and has been fully integrated with both Yahoo’s RightMedia platform as well as the DoubleClick Exchange and is accessible to any of the thousands of major marketers who advertise through these vehicles.
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Senior Account Executive (2 Jobs) – NYC, SF – TARGUSinfo:Â
Its unique identification, verification, qualification and location services enable retailers, call-center operators, Web-based marketers, communication service providers and others to dramatically increase the quality of their services and the effectiveness of their marketing. A privately held company, TARGUSinfo is headquartered in Vienna, Va. For more information, visit www.TARGUSinfo.com.
With a focus on delivering measurable, predictable results in a online environment, TARGUSinfo is defining tomorrow’s marketing standards by delivering a display advertising targeting solution to advertising networks, interactive advertising agencies, and publishers. We currently have a large cookie-based audience solution based on verified offline data assets.
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Optimization Consultant, Ad Exchange – NYC – Google
you will be responsible for working with buyers and sellers on the Ad Exchange to optimize their experience (ie. manage yield or drive return on marketing investment). You will be responsible for partnering closely with Product Management, Engineering, Sales, and Services to build models, develop new ones, apply customer specific data, and develop insights.
Interactive Ad Bureau boasts it “Lobbied extensively and proactively against” FTC Consumer Protection Proposals
In its annual report for 2009, the Interactive Advertising Bureau [IAB] cites as a accomplishment that it “Lobbied extensively and proactively against several proposals— including the FTC Reauthorization Act—that would grant broad newn rulemaking powers to the Federal Trade Commission.“ It also notes that the “IAB PAC had an active year supporting many key Congressional champions of the interactive advertising industry and was able to host the first ever IAB fundraiser. The PAC begins 2010 with a healthy balance of over $55,000 cash on hand.“