The new “Digital Advertising Alliance” self-reg plan. See if it tells consumers what its sponsor ad groups really say to each other. That they track and target your “digital footprint”

On Monday, the new self-regulation magical “icon” that is designed to make the online ad industry’s privacy problems disappear will be unveiled.  A new group called the “Digital Advertising Alliance” will unveil the icon-based plan–all timed to help head-off the kinds of protections and safeguards consumers require.  The current financial crisis affecting tens of millions of Americans require that government and big business groups do more than pay digital lip service to consumer protection.

As a kind of litmus test for the new self-regulation effort, see if the icon and the information connected to it really informs you about how data on you is collected and used for profiling, tracking and targeting. For example, last week, the Interactive Advertising Association (IAB), one of the key backers of the new Alliance, released a guide to targeting consumers at the local level.  Here’s excerpts of what they say.  See if that little icon is being honest when you click it.  Of course, we really require rules that eliminate the kind and amount of data that can be collected on you and you family and friends in the first place–as well as honest disclosure on the process.  Note as well that all that data on you is expensive–and others are cashing in on information that belongs to you!  From the new “Targeting Local Markets” guide:

Explicit profile data Targeting. definition–
Explicit data is “registration quality data” collected either online or offline. For online registration data, the user has certain attributes in his or her registration profile at a particular site or service, and that data is associated with the user’s Web cookie or some sort of audience database when the user next logs in. Offline registration data includes the sorts of data held in the massive offline direct response industry databases built up over the last several decades. These are then matched to a user online when that user logs in somewhere that is a partner of the data company. The site at which the user logs in, usually an online mail or similar site, sends the name/email combination to the data company, which then makes the match and sends back data…pricing–In general, first party data commands a far more variable premium than third party data…Third party data is usually available in much larger quantities, and yet there is often a fee of anywhere between $0.50 to $2.00 or more paid to the data provider by the ad seller – thus increasing the cost of goods sold (COGS) on the ad, and therefore increasing the price…

Behavioral Targeting (Implicit profile data Targeting)-definition-
Behavioral Targeting is the ability to serve online advertising based on profiles that are inferred from an individual user’s technical footprint and viewing behavior…As the medium has grown from a “browsing” experience to interactional so have the levels of information gathered. Newer forms of information include the data collected about influences, social preferences through social networks and an individual user’s content created online…The data is often gathered in real-time and can be used for real-time decision-making so that relevant advertising can be delivered dynamically to an individual user during their online session…Behaviorally targeted advertising commands a higher price because of targeted placement versus general run-of-site (ROS) advertising…Behavioral Targeting can be highly accurate when the user is leaving a digital footprint of their activities as they move through the Web.

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”

Google, Time Warner, Washington Post, Verizon, Canoe Ventures [Comcast] Funding Online Ad Lobby’s Campaign Against Consumer Privacy Safeguards

The Interactive Advertising Bureau (IAB) is a lobbying group that is working to oppose federal (or state) legislation and regulation that would protect consumer privacy online.  It recently led the lobbying campaign that removed from the new financial reform bill a key provision that would have enabled the FTC to better protect consumers.  What companies are helping fund the IAB’s Orwellian named “Consumer Protection and Education Campaign” battling consumer and privacy groups?  Here’s a list of the financial donors, who have ponied up about $500k so far.  Other companies are contributing free online ad space for the IAB’s campaign–1 billion impressions worth. The donors are:
AdMob
AudienceScience
Canoe Ventures
Cars.com
CPX Interactive
eBureau
Eyeblaster
Feeva Technology
Google
IDG.net
IM Services Group
Mediamath
Meredith Interactive
Microsoft
Quantcast
Sharethis
ShortTail
Simulmedia
Time Warner
Traffic Marketplace
Tumri
Verizon
Washington Post
WildTangent

Google Sells To Advertisers: User Profiles for Consumers Looking for Credit Cards [UK]

The new Consumer Financial Protection Board–and the FTC–will have their digital hands full as they begin to investigate the stealth world of online financial marketing.   Disclosure and consumer control has to be built into these applications–but they are not.  Of interest is a trial run by Google in the UK to sell credit cards, part of its move into “comparison” marketing.  According to New Media Age [my emphasis], “Google is testing its own [credit card] comparison product, launched earlier this year.  Currently focused purely on UK credit card providers, it lets users search on Google, click on an interactive ad showing rates from participating advertisers and takes them to a comparison page. Advertisers bid for user profiles that match their target audience and pay on a cost-per-lead basis.”

Take a look at Google’s credit card comparison site; does a consumer know about the advertiser bidding to buy their profile? See also Google similar product selling mortgages here in the U.S.

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.

Google’s non-neutral YouTube–Gives Advertisers “Brand Protection” to bypass online videos

Google, like other major advertising and media companies, works hard to please its biggest advertisers.  For decades, radio and TV networks relied on Standards and Practices divisions to screen programs to make sure they were suitable “environment” for commercials.  So-called “brand protection” has mushroomed online–as we predicted it would many years ago.  The business model for TV and the Internet are aligned–it must please the Fortune 1000 advertiser first.  So it’s no surprise that Google has launched a “brand protection feature” for YouTube, explains Ad Age, that provides “more control for advertisers to exclude objectionable videos, genres, channels.”  Ad Age explained that YouTube’s new feature, is called “target excludes.” It’s “part of the site’s Video Targeting Tool, which gives advertisers the choice to exclude as few as one video they don’t want their product associated with as well as specific genres and channels. The feature addresses the most often-criticized aspect of YouTube: You can buy video there, but you never know what you’ll get.Other uses for this new feature by advertisers include improving returns by excluding channels or videos that are not relevant to the brand or those that are performing poorly.”

Here’s how Google explains it: “We’re constantly working to give advertisers control and flexibility over their YouTube campaigns. We place great value on this because ads are an extension of what a company represents as a business, and we want YouTube to be a place where that reputation and image can flourish. To that end, we’ve been rolling out features to keep advertisers in control of their campaigns…Google has also been investing significantly in ensuring brand safety, transparency and control for advertisers across the Google Display Network. We’re hoping that these added layers of control will make your campaign targeting even more precise.”

As we said, so-called online brand protection is a booming business.  But its purpose, explains one online advertiser, is to be “a preemptive technology and is designed to block ads from appearing next to controversial content…protecting brands from potentially damaging negative associations resulting out of negative content adjacencies.”  But questions should be raised now about how decisions will be made placing videos and other content on so-called censoring “whitelists” [which are really blacklists]. How will it ultimately affect the diversity of controversial content online?  Does YouTube further go from a quasi common carrier to an environment where, as we already see, Google favors some content over others?   Will the online medium be further transformed to reflect the TV model, with consequences to serious journalism and independent content?  The questions are larger than what Google does.  But given Google’s network neutrality flipflop and its online ad and data collection ambitions, a debate about the impact of so-called “brand protection” on the future of the online media is in order.

Future of Privacy Forum: Funded by Facebook and other online data companies [Need to disclose when discussing social networks and privacy department]

In an August report, the Future of Privacy Forum told its supports that [our bold]: “We welcome Bering Media as a new sponsor of FPF… Thanks to our existing sponsors for their on-going  support: Adobe, AOL, AT&T, The Better Advertising Project, BlueKai,  Deloitte, eBay, Facebook, Intel, Lockheed Martin, Microsoft, The  Nielsen Company, Qualcomm, TRUSTe, Verizon and Yahoo.”

When the Forum was launched, we feared that its role was to serve as a kind of quasi-research organization that sanctioned the online data collection status quo. So far it has failed (like most in the online ad industry), in our opinion, to provide an accurate analysis of the online data collection landscape–which would, of course, alienate its corporate backers.  But whenever the Forum speaks to the press (as it recently did on Facebook Places) or policymakers–it must first identify these financial connections.

PS:  Forum co-founder and corporate attorney Chris Wolf identifies how his group isn’t really focused on privacy from a public interest and democracy perspective.  In his Hogan Lovells law firm blog he writes that the Future of Privacy Forum is “focused on advancing consumer privacy in ways that are business practical.”   Business Practical!   That means created by lobbyists for their special interests.

Kmart targets teens online, via Alloy Media Digital Marketing: Time for FTC & Congress to Protect Adolescent Consumers, inc. Privacy

Teens are ground zero for the digital marketing industry, worldwide, since they are seen as the “always-on” online generation.  Companies such as Microsoft, AOL, Sulake, MTV/Nick and many others closely research the digital behaviors of youth–all so they can be better targeted online.  This week, Kmart became the lead sponsor for a new online series featuring “product integration” and produced by tween/teen targeting company Alloy Media [now owned by Zelnick Media].  Here’s what Ad Age reported [excerpt]:This week, Alloy debuts “First Day,” its first wholly original series for the web and a branded-entertainment vehicle for Kmart, which will use the program to promote three of its back-to-school product lines: Bongo, Rebecca Bon Bon and Dream Out Loud…Josh Bank, Alloy Entertainment’s East Coast president, saw “First Day” as a creative challenge to build a series’ concept around Kmart’s brand brief. The eight-episode series follows main character Cassie…as she’s forced to relive her first day of high school over again, “Groundhog Day” style…Although Kmart and its products are never addressed by name in “First Day,” each episode will be supported by display and video pre-roll video ads highlighting the participating retail lines, with links to Kmart’s own micro-sites to purchase the products seen in the series. “First Day” will also receive heavy promotion via click-to-expand video ad units from Alloy properties such as Gurl.com, Alloy.com and Teen.com, and exclusive web partnerships with Meez.com, Candystand and Fanpop among others. Kmart’s media agency, MPG, and digital agency, Digitas, helped broker the deal and create the media plan with Alloy.”

Here’s how Alloy Digital explains what it delivers for marketers:  “Nobody knows the youth market better. As a pioneer in the digital space, Alloy connects with millions of young consumers online through highly trafficked websites and premium original web programming. What does that mean for you? Access to the highest concentration of teens, tweens and young adults available online. And comScore agrees – the Alloy Digital Network has ranked #1 in its category for the past year…At Alloy, our sole mission is to identify and develop innovative spaces and tactics to ensure your brand message reaches an engaged audience.”  They explain to advertisers that they know their youth target well: “We know who they are. Socialites, gamers, skaters, fashionistas – we’re all about what they’re into, where they hang out, who they are “socializing” with and … we know where to reach them. Our networks are unparalleled. No other company can deliver this level of specificity, on this large a scale and with this degree of focus. We are where they are, and so is your message.”

And it’s time to wake up FTC and state a-g’s–let alone parents.  Look at how Alloy tries to capture its youthful target via these interactive marketing tactics:
Display: Standard IAB units, interstitials

  • Full rich media capabilities
  • Targeting by geographic and demographic

Video pre/mid/post-roll

  • Targeting by geographic and demographic

Custom Integrated Programs:

  • Homepage Domination
  • Custom Video Programs
  • Sweepstakes & Contests
  • Advertorials, Quizzes, Editorial Sponsorships, Polls
  • Custom Games
  • Virtual World brand immersion programs
  • Social Media integration within Facebook, Twitter, and YouTube

and in searching for partners to help them target youth, Alloy explains:
As a select member of the Alloy Digital Network, you can increase your ad revenue, raise your site visibility, traffic and buzz among users…

Become a Partner Member – Does your site have what it takes to be a part of the network? Established audience? Ad-friendly? The requirements are:

  • Minimum 100k monthly unique visitors
  • Content targeting 12-34 demo…”

Teens should not be the focus of non-transparent and unfair online marketing tactics, including data collection.  This is part of the current federal privacy and fair rules for online marketing, especially for youth, debate.  Stay Tuned!