Online Marketers, Privacy & Self-Regulation: “Repeatedly Failed Promises Syndrome”

To help undermine the impact of the forthcoming FTC proposal to protect consumer privacy, a coalition of online ad lobby groups will unveil yet another self-regulation plan.  According to Mediapost, online consumers will soon see “[I]cons to signify behavioral advertising — or serving ads based on people’s Web activity.”  Since 1999, online ad groups have rolled out self-regulatory regimes promising to protect consumers online.  Each has failed to do so.   This new effort involves the very same groups and companies that offered self-regulatory promises in the past.   For example, see the World Privacy Forum’s report on the failure of the Network Advertising Initiative’s self-reg schemes; that group is part of the new effort, btw.

This new effort is seriously flawed–and before marketers and advertisers adopt it, it must be independently evaluated by consumer groups, independent academics, and the FTC.  We believe that the system will fail to protect consumers–because it will not candidly inform them about how the data is collected and used.  Meanwhile, in a revealing flip-flip, the IAB’s UK counterpart deep-sixed its just released safeguard on retargeting.  According to a new report, “[O]nline advertising trade body the Interactive Advertising Bureau (IAB) has withdrawn a code of practice which recommended that behavioural advertising retargeting cookies should expire after 48 hours. The IAB’s Affiliate Marketing Council (AMC) published the code last week. It applied to the practice of ‘retargeting’ web users who had visited a site with ads for that site on other people’s websites, using cookies to track their movements and activities…That code has been withdrawn and will be reworked after further industry consultation, though, the IAB said. The code has disappeared from the IAB’s website.”

Consumers and citizens require real safeguards governed by law and regulation–not flimsy digital promises designed to sanction ever-expanding data collection practices.

Google’s Ad Targeting on Finance & Health via its Exchange: Do you know this?

Google tells users, policymakers and reporters that its “ad preference manager” is an effective consumer tool that addresses behavioral marketing.  But on its Doubleclick Ad Exchange, advertisers can use Google provided tools to target online consumers based on a wide range of product and issue “vertical” categories, including health and finance.  Here’s what Google says advertisers can target in the health and financial area.  Ask yourself.  Did you know this and shouldn’t all this be truly transparent, under full user control, with real safeguards about how such information can be obtained and used?  We do. Google isn’t the only one doing this, of course:
Doubleclick Category Targeting Codes:
category::Finance
category::Finance>Accounting & Auditing
category::Finance>Accounting & Auditing>Tax Preparation & Planning
category::Finance>Banking
category::Finance>Credit & Lending
category::Finance>Credit & Lending>Auto Financing
category::Finance>Credit & Lending>College Financing
category::Finance>Credit & Lending>Credit Cards
category::Finance>Credit & Lending>Debt Management
category::Finance>Credit & Lending>Home Financing
category::Finance>Currencies & Foreign Exchange
category::Finance>Financial Planning
category::Finance>Grants & Financial Assistance
category::Finance>Insurance
category::Finance>Insurance>Auto Insurance
category::Finance>Insurance>Health Insurance
category::Finance>Insurance>Home Insurance
category::Finance>Investing
category::Finance>Investing>Commodities & Futures Trading
category::Finance>Retirement & Pension

Health
category::Health
category::Health>Aging & Geriatrics
category::Health>Aging & Geriatrics>Alzheimer’s Disease
category::Health>Alternative & Natural Medicine
category::Health>Alternative & Natural Medicine>Acupuncture & Chinese Medicine
category::Health>Alternative & Natural Medicine>Cleansing & Detoxification
category::Health>Health Conditions
category::Health>Health Conditions>AIDS & HIV
category::Health>Health Conditions>Allergies
category::Health>Health Conditions>Arthritis
category::Health>Health Conditions>Cancer
category::Health>Health Conditions>Cold & Flu
category::Health>Health Conditions>Diabetes
category::Health>Health Conditions>Ear Nose & Throat
category::Health>Health Conditions>Eating Disorders
category::Health>Health Conditions>GERD & Digestive Disorders
category::Health>Health Conditions>Genetic Disorders
category::Health>Health Conditions>Heart & Hypertension
category::Health>Health Conditions>Infectious Diseases
category::Health>Health Conditions>Infectious Diseases>Parasites & Parasitic Diseases
category::Health>Health Conditions>Infectious Diseases>Vaccines & Immunizations
category::Health>Health Conditions>Injury
category::Health>Health Conditions>Neurological Disorders
category::Health>Health Conditions>Obesity
category::Health>Health Conditions>Pain Management
category::Health>Health Conditions>Pain Management>Headaches & Migraines
category::Health>Health Conditions>Respiratory Conditions
category::Health>Health Conditions>Respiratory Conditions>Asthma
category::Health>Health Conditions>Skin Conditions
category::Health>Health Conditions>Sleep Disorders
category::Health>Health Education & Medical Training
category::Health>Health Foundations & Medical Research
category::Health>Medical Devices & Equipment
category::Health>Medical Facilities & Services
category::Health>Medical Facilities & Services>Doctors’ Offices
category::Health>Medical Facilities & Services>Hospitals & Treatment Centers
category::Health>Medical Facilities & Services>Medical Procedures
category::Health>Medical Facilities & Services>Medical Procedures>Medical Tests & Exams
category::Health>Medical Facilities & Services>Medical Procedures>Surgery
category::Health>Medical Facilities & Services>Physical Therapy
category::Health>Medical Literature & Resources
category::Health>Medical Literature & Resources>Medical Photos & Illustration
category::Health>Men’s Health
category::Health>Mental Health
category::Health>Mental Health>Anxiety & Stress
category::Health>Mental Health>Depression
category::Health>Mental Health>Learning & Developmental Disabilities
category::Health>Mental Health>Learning & Developmental Disabilities>ADD & ADHD
category::Health>Nursing
category::Health>Nursing>Assisted Living & Long Term Care
category::Health>Nutrition
category::Health>Nutrition>Special & Restricted Diets
category::Health>Nutrition>Special & Restricted Diets>Cholesterol Issues
category::Health>Nutrition>Vitamins & Supplements
category::Health>Oral & Dental Care
category::Health>Pediatrics
category::Health>Pharmacy
category::Health>Pharmacy>Drugs & Medications
category::Health>Public Health
category::Health>Public Health>Health Policy
category::Health>Public Health>Occupational Health & Safety
category::Health>Public Health>Poisons & Overdoses
category::Health>Reproductive Health
category::Health>Reproductive Health>Birth Control
category::Health>Reproductive Health>Erectile Dysfunction
category::Health>Reproductive Health>Infertility
category::Health>Reproductive Health>OBGYN
category::Health>Reproductive Health>Sex Education & Counseling
category::Health>Reproductive Health>Sexual Enhancement
category::Health>Reproductive Health>Sexually Transmitted Diseases
category::Health>Substance Abuse
category::Health>Substance Abuse>Smoking & Smoking Cessation
category::Health>Substance Abuse>Steroids & Performance-Enhancing Drugs
category::Health>Vision Care
category::Health>Vision Care>Eyeglasses & Contacts
category::Health>Women’s Health

Google & Microsoft Tout their Mobile Targeting Clout, inc. Behavioral, Location, Gender, etc.

My CDD and USPIRG asked the FTC in January 2009 to investigate mobile marketing and its threat to both privacy and consumer protection issues (Ringleader Digital, now the subject of lawsuits and stories in the WSJ and NYT, was included in the complaint, btw).  Online mobile marketers, including Microsoft and Google, illustrate how regulators in the U.S. and abroad should require safeguards to protect the public from unfair and deceptive practices–including those that involve their privacy.  In Ad Age, both Google and Microsoft loudly proclaim what their mobile marketing services can do for brands, ads and marketers.  Here are some choice excerpts:

Microsoft:  “Microsoft Advertising’s industry-leading mobile display and search advertising solutions engage more than 43 million on-the-go U.S. consumers each month—regardless of a user’s mobile phone or wireless carrier. Its innovative ad placements and ad formats include display, rich media, search, video and custom in-app ad units…

Advanced Targeting Options
  • Profile targeting: age, gender, household income, location, time of day
  • Behavioral targeting: more than 120 custom segments (e.g., “movie watchers” and “business travelers”)
  • Device: make and model
  • Wireless carriers: on-deck inventory
  • Keyword targeting: exact or broad match…Complete mobile ad solutions for automotive, CPG, entertainment, financial services, retail, technology, telecommunications, travel and other sectors…
  • More than 43 million, or 55 percent of active mobile web users in U.S.
  • More than 80 million active mobile users globally in 32 countries.”

Google: “Today’s consumers are on the move. More than ever before, audiences are searching and browsing the web on their mobile devices. How do advertisers connect with the on-the-go consumer…As customers go mobile, advertisers need smart mobile advertising strategies. With Google, they can easily target and tailor messages according to location and automatically show their customers relevant local business information or phone numbers to enable them to take immediate action. Once a campaign is up and running, marketers can measure their results via detailed reports. Additionally, integrated mobile reporting in Google Analytics allows them to track and optimize conversion, e-commerce and engagement metrics on mobile devices. They can take advantage of Google’s mobile-specific ad formats. Click-to-call text ads, animated mobile banner ads, click-to-download ads and other display ad formats are examples of how Google is innovating for the small screen.  Google closed its acquisition of AdMob, one of the world’s leading mobile advertising networks, in May. AdMob’s innovative rich media ad units—including full-screen expandable, animated banner and interactive video—create opportunities for advertisers to engage with a relevant audience on their mobile devices. Now the Google and AdMob teams are working to create new ways to deliver engaging and innovative advertising experiences that will help marketers drive their businesses forward…

CASE STUDY

CHALLENGE: Esurance, a direct-to-consumer personal car insurance company, wanted to ensure that customers could do business with it on their own terms and at their own convenience… To make the connection between mobile users and Esurance agents, Esurance used Google mobile ads with integrated click-to-call functionality. The CTC ads gave mobile users the option of clicking through to Esurance’s mobile-optimized landing page or initiating a phone call with a licensed insurance agent…Results…

  • Boosted conversion rates: Click-to-call mobile ads drove a 30 percent to 35 percent higher response.”

PS:  Attention Music Lovers.  In the same Ad Age piece, the online music service Pandora exclaims that it can provide:“Through powerful hypertargeting, reach the right person, at the right time, without waste. Target based on age, day, gender, location, mobile platform, time and type of music…Pandora offers a broad array of formats and rich media functions to create an immersive mobile experience, including:

  • Tap to video
  • Drag and drop
  • Tap to app
  • Tap to call
  • Tap to e-mail
  • Tap to expand
  • Tap to find a location
  • Tap to iTunes
  • Tap to mobile webpage
  • Standard banners”

Mobile Marketer Delivers “Real World Behavioral Targeting”–they know where you are and what you do!

Mobile marketers have embraced the behavioral tracking, profiling and targeting paradigm–but they now add real location.  Brightkite, which offers “highly targeted mobile media, says it delivers “Ultra-Targeted Advertising,” including:

Real World Behavioral targeting

Want to target people who have purchased items in a hardware store? Or people who go to the movies more than twice a month? Or people that buy coffee more than three times a week? We know who they are, and can put your campaign in front of an audience who cares.

Examples:

For Pantene, we targeted people in hair salons.
For Dentyne, we targeted people in social groups of two or more…

Location and Place targeting

We can target by precise geography – such as, people in Tulsa, people within 2 miles of a KFC, people at Costco, people in a bar, etc.

Examples:

For Chevrolet, we targeted people within 3 miles of a dealership on a given weekend.
For Jack in the Box, we targeted people within 2 miles of a restaurant in the week following the launch of smoothies in each restaurant…

Activity

Want to target people who are currently doing something specific? We know what our members are doing throughout the day, so we can get a relevant ad to match their current activity.

Example:

For Grey Goose Vodka, we targeted people over 21 engaged in drinking and nightlife activities…

Weather

We know the location of our millions of users, and we also know the precise weather in each location. This allows us to target or optimize ads according to the local weather. We can deliver ads only when the temperature is over certain threshold, or deliver different creatives if the weather is sunny, cloudy, raining, snowing.

Example:

Diet Coke wanted to target people when the afternoon temperature was over 75°.
Big-O tires wanted to target to days with ice or heavy rain.

Google’s new `simplifed’ Privacy Policy: More disclosure and honesty required [updated]

Last week Google announced it was “simplifying and updating” its privacy policies.  As it so often does, the announcement was framed as a `we did for your good’ kind of effort.  “[W]e want to make our policies more transparent and understandable,” it explained, noting that “most privacy policies are still too hard to understand.” But as so often with Google and other online marketers, you have to both read between the digital lines and also analyze what’s really going on.

Google’s revised policy, which takes effect October 3, fails to really explain to consumers/users what’s actually going on.  Like other privacy policies, Google claims that all its data collection is to “provide you with a better experience and to improve the quality of our services.”  But what they really mean–and what the Congress, the FTC and other regulators must require them to disclose–is that they have crafted a wide-ranging system designed to foster personalized data collection and online targeting.  Missing from the revised Privacy Policy (which Google, btw, is pitching to privacy advocates and no doubt others as a  paragon of digital virtue) is any candid disclosure on how its Doubleclick, Admob, Google Display Network, Ad Exchange, Teracent, and other services collect information from and about us.

Google isn’t alone–Facebook, Microsoft, Yahoo and everyone else rely on a purposefully deceptive privacy policy to engage in data collection activities that require disclosure and individual user control.  Google is also reshaping its privacy policy to better capture all the data it can collect across multiple platforms and applications. Here, just for the record, is what Google advertised in Ad Age’s recent Ad Exchange and online advertising guide [excerpt]:  No matter how you define performance, the Google Display Network offers a solution. By bringing more measurability and precision to your advertising, it enables you to create, target and optimize ads based on real-time data, meaning better returns for you.

The Google Display Network helps advertisers and agencies achieve performance at scale by delivering relevant, accountable ads to their target audiences—in more places, more often…Precisely target your audience: The Google Display Network’s technology enables you to find customers based on their interests, sites they visit and when they’re engaging with relevant content via contextual targeting, or show specific messages to users who’ve already visited your site with remarketing…The Google Display Network provides opportunities to advertise in all such environments—feeds, games, mobile, social networks and video streams— enabling you to create an immersive experience for your audience.

PS.  Well, Google just also announced what its interactive display ad system can do for marketers.  How come this isn’t in the privacy policy in understandable language and full consumer control? Excerpt:  Advertising with Google used to be all about four lines of text, on Google.com and on our partner sites. No longer. Did you know that, outside of ads alongside search results, more than 40 percent of the ads that we show are now non-text ads? And that doesn’t include the 45 billion ads that our DoubleClick advertising products serve every day across the web.

We get excited by display advertising for a number of reasons…Teracent’s technology can automatically tailor and select the creative elements in an ad, and adjust them based on location, language, weather and even the past performance of ads, to show the optimal ad.  We’re focused on helping advertisers get the best results from their campaigns—by enabling creative branding campaigns, precise targeting, wide reach and effective measurement. Over recent years, we’ve added a ton of new features to YouTube and the Google Display Network, to help advertisers get—and measure—the results they’re after. From remarketing to Campaign Insights to video targeting on YouTube, we’re building tools that are helping advertisers get great results and enabling them to run some of the most amazing ad campaigns the world has ever seen.

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.

“Tipping Point for Geo-Marketing”—Facebook Places (and what the Like Button already tells marketers)

You have to follow your data [and your friends and networks]–that’s how the money is generated in online marketing.  This article via DM News explains that:“…Facebook continues to gather more information about what people do and where they are – critical data for marketers. “What I find interesting is where people check in says even more about what they like. Now we’re actually looking at their real-world behavior, instead of just a button they click on a website,” he said [Augie Ray, senior analyst at Forrester Research]. “I think this really will continue to help Facebook offer much better targeting and permit marketers to do a better job of understanding their consumers and targeting ads at those consumers.  The very scale that Facebook Places creates is a welcome event for marketers, said industry professionals.  “I would say this is a tipping point for geo-marketing,” said Lawrence Kimmel, CEO of the Direct Marketing Association…Maria Mandel, VP of marketing and media innovation at AT&T Advanced Ad Solutions, agreed that the service makes geo-marketing much more mainstream. “It certainly brings location-based social media to the mass market,” she said. “It validates the relevance of the location-based check-ins and may offer substantial new opportunities for advertisers.”  Leveraging location may prompt innovative promotional campaigns, such as scavenger hunt contests, Mandel noted. There is also the scope to build long-term loyalty programs by rewarding people for checking in at certain locations to build toward prizes, offers or discounts, she said.

source:  Marketers See Potential in Facebook Places.  Shahnaz Mahmud.  DMNews.  August 20, 2010.

PS:  One social media marketing company writes that:  “…Facebook already provides marketers with a comprehensive list of your interests and favorite things with the integration of the Like button. Retailers, like Amazon, have already begun to leverage this information to create purchase suggestions for you and your Facebook friends…Now, with Facebook Places…[M]arketers can (and should) use this invaluable information to direct promotions and advertisements to consumers…This information is highly valuable as social media once again allows businesses to gain access to the exact niche of consumers they are striving to reach.”

Facebook Places and Location Marketing: Plans to `Send in the Crowds’ from Advertisers

You have to read between the lines to understand what Facebook’s new location feature is really designed to do:  Open you and your friends to be more closely tracked by Facebook and its marketing partners, including major advertisers [Fans are worth money to Facebook and their marketing partners].   On Facebook’s blog post on the new location service [which is written in typical Silicon Valley PRspeak suggesting they are doing this only to bring pleasure into your life], the key telling phrase is: “You may want to share your check-in information with third-party applications that build interesting experiences around location, such as travel planning. Applications you use must receive your permission before getting this information. Your friends will be able to share your check-ins with the applications they use to help create new social experiences with location.”

That really means Facebook already has plans to use location data to expand its marketing business (inc. from thrid part apps), which is expected to help the social network bring in $1 billion this year.  Mobile and location applications require greater safeguards for privacy, as my CDD and USPIRG petitioned the FTC to do last year [as a result the FTC has opened up a “mobile lab” examining data collection and mobile marketing practices]. Companies such as Facebook. Google, Foursquare, and others are keenly aware of the huge ad revenue opportunity from location marketing.  One Google backed location social game start-up [SCVNVR] calls this potential the “social coefficient.”  As Mobile Marketer reported, the “Social Coefficient is a score determined by the number of social interactions at a specific location…The more friends at one place or the more users participating in the challenges over time, the higher the Social Coefficient score for that particular location.”  Facebook and others understand that advertisers are willing to pay more if they can encourage friends to market to other friends. 

McDonald’s is already in discussion with Facebook to use this new service.

Leaving Your Data in Las Vegas: Facebook, Online Gambling & Privacy [Annals of behavioral tracking and targeting in online casino gaming and the need for safeguards]

The Las Vegas Casino the Golden Nugget has created a social game [take a look] on Facebook where, says DM News, users can “build their own Vegas casinos, including table games such as Blackjack, Video Poker and Roulette. As they earn virtual money, consumers can create their own customized furniture layouts and decorations by purchasing store items, as well as slots, tables and clothing for a consumer’s avatar. Players can also visit their Facebook friends’ casinos and build their avatar.

It’s also about data collection:  “That is about data collection, as well as rewarding people who are playing the game,” [said a Nugget representative].  The game’s developer explained that it “will examine targeted behavioral gameplay data to help advertisers and to provide consumers with more compelling experiences.”

As Congress debates legislation that would okay online gambling, one of the key issues should be privacy.  What happens when a consumer is identified by a online casino or a Facebook that they gamble?  How does that get used in their online behavioral targeting profile, along with health and financial information?  Should we even permit the behavioral tracking of any user who engages with online casinos?  There are a host of privacy and consumer protection issues about leaving your data in Las Vegas–or with online marketers such as Facebook.

Google’s Mobile Ad Plans–A Key Reason Why No Net Neutrality for Wireless [Follow the Mobile Ad $$$]

Just a quick reminder to network neutrality supporters that Google has made a multi-billion dollar investment in its ability to deliver mobile ads.  That’s a key reason for its “let’s make a digital deal” with Verizon.  For example, in 2007 Google acquired  Doubleclick:“DoubleClick Mobile is an ad delivery system for mobile websites that delivers dynamic, interactive ads to mobile web pages based on specific criteria as determined by you. It supports a wide range of devices and boasts a full management and reporting suite. Now publishers can deploy mobile advertising with the same confidence and control as online display ads…DoubleClick Mobile enables you to manage and report on your mobile advertising campaign through every click. We’ve made it easy to set campaign dates, define mobile specific targeting criteria and get full reports on all mobile campaigns…records information on third-party destination sites…DoubleClick Mobile features support for a variety of ad networks to enable you to sell more of your inventory and maximize possible yield…”

This year Google acquired Admob:  “AdMob offers brand advertisers the ability to reach the addressable mobile audiences. Our innovative ad units will carry your brand messaging onto the top mobile sites. As one of the leading brand mobile advertising marketplaces, we have the products and the people to help you meet your campaign needs…Mobile advertising provides you with targeted access to mobile users, and is easy to buy and measure…AdMob stores and analyzes data from each ad request to serve the most relevant ad possible. AdMob Mobile Metrics offers a snapshot of this data to provide insight into trends in the mobile ecosystem.”

And don’t forget Google Adsense for mobile:  “AdSense for Mobile helps you earn money by displaying relevant Google ads alongside your mobile web pages or within your mobile applications.”  Or YouTube Mobile.

PS:  eMarketer got it right.  The Google/Verizon deal is about preserving mobile as a controlled digital territory: “By 2014, eMarketer expects the number of mobile internet users in the US to reach 142 million, a near tripling of 2008 levels. The total pool of internet users, which includes mobile and wired access, will increase over the same time period from 203 million to 250 million. By 2013, more than half of all US internet users will be accessing the web through a mobile network, either alone or in addition to wired usage.”