Category: adolescent privacy

Google Expands User Tracking/Profiling via Behavioral Targeting [Annals of “Interested-Based” Micro Persuasion]

Here’s an excerpt from what Google is telling its AdSense clients:

Advertisers spend more money on campaigns that reach the right audience; helping them do that should drive more revenue to your websites. This week we’re announcing plans to provide interest-based advertising across AdSense publisher sites…With this enhancement they’ll also be able to reach users based on their previous interactions with them, such as visits to the advertiser website, as well as reach users on the basis of their interests (such as “sports enthusiasts” or “travel enthusiasts”)…To develop interest categories, we’ll recognize the types of webpages users visit across the AdSense network. As an example, if they visit a number of sports pages, we’ll add them to the “sports enthusiast” interest category.

The real digital TV transition: Why TV “Advanced Advertising” [aka Project Canoe] Raises Privacy & Consumer Protection Concerns

The cable and telephone industry have Google envy.  These broadband communications giants recognize that online advertising companies such as Google and Yahoo have created an enormous market for themselves through the delivery of online ads.  Comcast, Time Warner, Verizon and others want to use their Bush Administration-given broadband monopoly status to gain a significant share of this market.  Cable giants are also working together to transform television so it can better compete with online, and target viewers with more precision and in-depth ads.  The goal–for cable, phone and online ad companies–is to eventually provide a seamless system that tracks, profiles and targets us across every “screen,” including TV, PC and mobile.

Comcast is heavily investing for such a viewer/user tracking world.  It has plans, according to the trade publication Multichannel News to create a “gigantic database called “TV Warehouse,” able to store a full year of statistics gathered from digital set-tops in more than 16 million households nationwide…TV Warehouse, envisioned as having a massive 500 Terabytes of storage, would then feed up to a database even broader in scope operated by Canoe Ventures, the advanced-advertising venture formed by Comcast and five other large MSOs.  The idea: to give advertisers an enormous set of actual viewing metrics — showing exactly what millions of cable customers watched and when — as opposed to representative samples.”

Not surprisingly, Comcast’s Brian Roberts has said his company should no longer be viewed as merely a provider of television:  “Over the last few years we have successfully transformed Comcast from a cable company into a new products company that utilizes one infrastructure to deliver a growing number of products.”  Advanced Advertising, which is what the cable industry’s technical consortium known as CableLabs calls it, is one of the major products Comcast and others will soon provide.  According to CableLabs, “Advertising is growing in importance for cable operators. CableLabs is currently supporting activity in four areas designed to create new revenue opportunities around advanced advertising technologies. These areas are digital ad insertion, interactive advertising, reporting, and addressability.”   Cable executives are working with advertising companies to “…agree on a valuation metric. What’s a click worth?”

But the core concern with Advanced Advertising is the tracking of viewers, including the use of internal and outside databases for targeting. Comcast Spotlight, for example, offers marketers access to a broad range of databases for more precise targeting. Acxiom offers cable and other providers a host of database segmentation services, including its Personicx VisionScape. “With PersonicX VisionScape, marketers have at your fingertips real-time access to a wealth of information… that can help them understand more about their customers – what type of products they use, their purchasing behaviors, their channel and media preferences.  The PersonicX household-level segmentation system is built with InfoBase-Xâ„¢ data and places almost every U.S. household into one of 70 distinctive segments and 21 life stage groups based on specific consumer behavior and demographic characteristics.”

Cable’s work to create a more powerful viewer data collection and targeting system has been out of public and policymaker view.  Cable engineers have been working  together to perfect the technology that will allow it to merge “content and subscriber metadata for targeting zones (or, in a unicast environment, for targeting individuals) to bring the right ad to the right consumer at the right time.”

The phone and cable companies, knowing that the 1984 Cable Communications Act contains privacy safeguards for interactive TV ads and aware of the current debate on behavioral targeting, claims that such data collection and targeting will be anonymous and could include an “opt-in.”  We don’t believe any cable or phone consumer is being told the extent of the plans underway to track and target them.  For example, Alcatel’s product for IPTV related advanced advertising explains that:
“To capture the full revenue potential of targeted and interactive advertising, IPTV providers need to ensure that the following critical actions are addressed:

  • Capture and measure — The network must be able to collect “opt-in” subscriber information from a broad range of databases, which advertisers will use to reach specific “targeted” markets. This anonymous data includes usage patterns, subscriptions, demographics, location, presence and preferences — including how, when and where advertising messages are delivered, along with the type of device that is used. In addition, accurate measurement capabilities are needed that can verify audience response and track the effectiveness of ad campaigns…
  • Activate and interact — Finally, this data, combined with the right systems and infrastructure must be able to deliver personalized and interactive ads to the right consumer, at the right time.”

Consumers/subscribers should decide whether such an advanced system can target them at all.  Beyond informed consent (and data security), there need to be clear safeguards.  Targeted ads for financial, health, and products aimed to children and adolescents raise consumer protection issues.  I have real concerns about “ethnic” profiling, given how lucrative advertisers realize the Hispanic and African American markets are.  We believe that the cable industry has to engage the public in a serious debate about the scope and goal of its Project Canoe and advanced advertising initiative.  Congress, the FCC, and the FTC must become more proactive to protect our privacy from this new approach.

PS:  This week’s Multichannel News offers insight into the latest developments.  Here’s an excerpt:  “This year, the largest cable operators in the U.S. plan to have upgraded at least 20 million digital set-tops with code to run standardized interactive-TV applications. That will make it possible for viewers to click a button on their remote to, say, ask an advertiser to e-mail them more information…The industry over the last two years has coalesced around a common technical standard, maintained by CableLabs, referred to as Enhanced Binary Interchange Format, or EBIF (pronounced “EE-biff”)…Comcast, for one, claimed it had deployed EBIF user agents on more than 10 million Motorola set-top boxes by the start of 2009. The operator hopes to complete the rollout to its entire Motorola footprint, about 20 million boxes, by midyear…” [Interactive TV Begins to Bloom.  Todd Spangler.  Multichannel News.  March 3, 2009].

MySpace Exec on its ad hypertargeting system: We have “massive amounts of data” on our users (and an example using Pepsi)

Excerpt.  on MySpace CEO Chris DeWolfe presentation.  via paidcontent.org:  “MySpace has 76 million unique online users in the US, and 139 million users worldwide; 40 percent of all Americans based in the US are on mySpace…MySpace has been working on its monetization technology currently used online called Hypertarget, which is five algorithms that basically segments the “massive amounts of data” on mySpace users into “enthusiast buckets.” Currently, they have their audience divided into over 1,000 of these segments, and for example, if Pepsi wants to target alternative music users they can serve them up an ad. Said DeWolfe, “It’s incredibly effective, and increases our yields.” This will be moving onto mobile.”

Marketers Urging Targeting of Hispanic Tweens, including via Mobile [Annals of Mobile Marketing]

There’s nothing to say except read what this marketer wrote for MediaPost’s Engage series.

Excerpt:  “To effectively reach Hispanic tweens…Don’t forget mobile. Many tweens already have cell phones, and they use them daily to text their friends. Text messages are a key way to connect with tweens, especially if you offer them a fun service, such as daily horoscopes, that doesn’t feel like an ad. Cell phone numbers can be collected right alongside emails in your lead-gen efforts. You get a branding boost, as well as their mobile number in your database for future text messaging campaigns.”

source:  Make Your Marketing Dollars Pay: Target Tweens.  Engage Hispanics:  MediaPost.  February 6, 2009

Ad Industry Lawyer Spins in Ad Age that Privacy Will Be on “Back Burner.” Not Only Incorrect–but self-serving

This week’s Advertising Age has a “Legal Issues to Watch in 2009” column.  Written by Douglas J. Wood of Reed Smith, it claims that: “PRIVACY TO THE BACK BURNER- Congress and regulators are in a Catch-22: While under constant pressure from constituents and consumerists to curtail the use of personal information or behavioral targeting, they recognize that advertising is the backbone of the internet. So while there will be occasional skirmishes, the war on privacy will continue in its stalemate. Regulators will also see browser makers offering more control to consumers to block ads and the collection of personal information as adequate progress.”

Mr. Wood, it turns out is “a member of Reed Smith’s Executive Committee and the firm’s Advertising Technology & Media Group…and is General Counsel to both the Association of National Advertisers and the Advertising Research Foundation.”

Perhaps Mr. Wood is too busy to really follow Hill and FTC developments, because he is wrong.  There will be considerable activity on the Hill and elsewhere.   His column should have been labeled as written by the lawyer for the ad industry lobby group.  But it does reflect a lack of insight about the online ad industry’s problems related to privacy and consumer protection.

A Behavorial Targeting Example Shows Why Privacy Laws are Required, including a New and More Accurate Definition of Personally Identifiable Information

Interclick, “one of the largest advertising networks in the U.S., reported higher revenues today.  The company says that it collects “non-personally identifiable information (non-PII)” via cookies.  Here’s what Interclick considers, like other online advertisers, non-PII: “On the interCLICK network, we collect non-personally identifiable information (non-PII) such as web sites visited, content viewed, ad interaction, interaction with advertiser websites, IP addresses, search terms used, and other click and browsing behavior. Additionally, we may collect non-PII technical information including IP address, OS, browser type, language settings.”

Meanwhile, Interclick’s behavioral targeting “option” for advertisers explains that its: “innovative behavioral targeting filters allow you to target the right individual users at the right time, increasing the effectiveness of your campaigns. With over 350 behavioral categories, interCLICK can get as precise as you want.

We segment users based on observed behaviors into 3 interest levels: slightly, moderately and very. Furthermore we use frequency and recency to classify these interest as short, mid, or long term interests. As the user navigates throughout our network of sites, we continually adjust their profile based on anonymous observations, assuring the accuracy of our profiles.” It offers “Behavioral Segments” which allows online advertisers to “Leverage interCLICK’s massive data warehouses to effectively target users who have been determined to exhibit certain behaviors throughout interCLICK’s network. interCLICK offers over 350 different Behavioral Targeting categories/sub-categories.”

Among the segments include financial services including “personal banking seekers, credit card seekers, retirement investing.”   There’s a segment targeting “college seekers,” raising issues related to youth marketing.  Another segment is on “health,” including categories targeting “Diet & Fitness Enthusiasts.”

InterClick is just of many ad networks engaged in such data collection and targeting.  But it illustrates why the online ad industry must be regulated, to protect consumer privacy and welfare.

The “Revised” Network Advertising Initiative Principles: Ghost-written by Bernard Madoff?

That was really what we felt reading the “NAI Response to Public Comments” released yesterday.  It accompanied the 2008 principles announcement by the self-regulatory trade online marketing trade group.  The “response” is worth reading, because it really reveals the inability of the group to meaningfully address how to protect consumers online.  You would think that an organization which has Microsoft, Google, Yahoo, Time Warner and many others as paying members could at least clearly state what happens to our data in the online marketing process.  But the real goal of the NAI is to prevent the enactment of serious state and federal privacy policies that would protect consumers. My group put out a statement yesterday discussing the new principles.

The credibility of Google, Microsoft, Yahoo and Time Warner are at stake.  They should be able to ensure that their own organization can honestly address the implications of online advertising.  But it’s time to abandon any call for self-regulation.  That has been a failure.  It’s clear that a growing number of consumer and privacy groups are calling for a legislative solution, as well as a more effective FTC.  Responsible online ad companies will support such regulation.

Google’s Doubleclick Using Widgets to “give advertisers the ability to tap into the incredible power of potential brand evangelists”

Google’s Doubleclick division is working with social media and widget advertising company Gigya so marketers can “integrate a viral component into any campaign to allow consumers to “snag” or “grab” the ad onto their personal homepage or social network page.” We think the Doubleclick release is very revealing. So here are some choice excerpt excerpts:

“Widgets are part of a fundamental change within the online marketing arena,” said Ari Paparo, vice president of advertiser products for DoubleClick. “Widget Ads provide audiences with the ability for self-expression and identification with well-loved brands while providing marketers the benefits of virality and engagement along with the measurability of traditional online channels.”…

“Incorporating viral functionality helps give advertisers the ability to tap into the incredible power of potential brand evangelists,” said Ben Pashman, vice president of business development with Gigya,…enabling great creative to enter a user’s social circle, where it may become an even more powerful, user-endorsed ad unit.”

Widget Ads may be distributed in a multitude of ways including branded websites, word-of-mouth outreach and even through another rich media ad… integration with the industry-standard DART platform allows for valuable Widget Ad metrics including impressions, interactions, video metrics, viral “grabs” for different social networks, and reach and frequency…”

Statement on FTC’s Children’s Online Privacy Protection Act legal action against Sony/Additional Privacy Policies are Required

Statement of Dr. Kathryn C. Montgomery, who led the campaign for the passage of the Children’s Online Privacy Protection Act (COPPA), commenting on the FTC children’s privacy lawsuit announced today against Sony BMG Music Entertainment

I applaud the FTC’s actions to enforce the Children’s Online Privacy Protection Act. The government’s lawsuit against SONY sends a strong signal to the online industry that this law must be taken seriously. COPPA was designed to protect children under the age of 13 from unfair data collection and manipulation by online marketers. Congress passed the law ten years ago to establish a clear set of safeguards and principles that were built into the foundation of the emerging digital marketplace. However, in recent years, online data collection has become increasingly sophisticated, expanding into a variety of new platforms — from social networks to mobile phones to interactive games — that are now central tools in young peoples’ their lives. In the new administration of President-elect Barack Obama, both the FTC and Congress must support additional policies that will extend COPPA’s mandate and create privacy protections for all children under the age of 18.

Kathryn C. Montgomery, Ph.D, is Professor of Communication at American University in Washington, DC.

New AT&T-funded “Future of Privacy” Group: Will it Support Real Privacy Protection or Serve as a Surrogate for Self-regulation and Data Collection?

A new group co-directed by former DoubleClick and AOL chief privacy officer Jules Polonetsky, called the “Future of Privacy Forum,” has been announced. It is connected to the law firm representing AT&T–Proskauer Rose–which has a considerable practice in the online marketing and data collection area. Other backers include Intel, General Electric, IBM and Wal-Mart.

We are concerned, however, that the role of the Forum is to help discourage Congress from enacting an opt-in regime for data collection. Both ISPs–such as AT&T, Verizon, Comcast and Time Warner–as well as online advertising companies such as Google/DoubleClick, Yahoo, and Microsoft must be governed by privacy laws which empower and protect consumers. The role of ISPs in any data collection for targeted online marketing, in particular, requires serious analysis and stringent safeguards. AT&T, Google, Microsoft, Comcast, the online ad networks, and social media marketers (to name a few) must be required to provide meaningful disclosure, transparency, accountability and user control (with special rules governing health, financial and data involving children and youth). Self-regulation has failed. If the Future of Privacy group is to have any legitimacy, it will work to support serious federal rules. But if it trots out some sort of voluntary code of conduct as a way to undermine the growing call for real privacy safeguards, this new group may soon be viewed as beholden to its funders and backers.