Category: Congress

Online Behavioral Profiling & Targeting of Individuals Based on their Political Interests: Privacy Safeguards Are Required for Interactive Marketing

This week an online marketing company called Resonate Networks “announced the first online ad network built for political and public affairs advertising.” According to the company, “Resonate’s ad network is powered by its proprietary Attitudinal Targeting platform that, for the first time, provides public affairs and political advertisers with the ability to identify, persuade, motivate and organize like-minded audiences online and drive them towards an actionable step—whether it is joining a campaign, contributing to a cause, or supporting an initiative.”  Resonate’s platform, they say, was “[D]eveloped by world-class research and online industry experts, Resonate’s Attitudinal Targeting platform incorporates extensive and proprietary algorithms, data modeling and analysis to map Web users’ attitudes and issue positions against their online behavior.  Attitudinal data that advertisers can leverage include…Targeting highly influential individuals with a history of taking action related to an issue of interest…”   “It’s really drilling down to people’s beliefs and where they stand on issues,” Resonate’s CEO told MediaPost.

Resonate told the Washington Post’s Cecilia Kang that the company’s approach doesn’t raise any privacy concerns.  But they are wrong.  How citizens and others are tracked, analyzed, profiled and targeted based on their political views is a privacy (and consumer protection) issue.  Both Congress and the FTC need to look closely at the growing role online profiling and targeting is playing in the political and policy arena.   

Financially backed by well-known political campaigners from both parties,  Resonate also explains that it “has developed one of the most advanced engagement models available, with the ability to not just understand who is influential, but where you can find influentials who care about specific issues.”   Here are excerpts of its pitch to corporate advertisers:

“For the first time, corporate advertisers and agencies have the power to precisely pinpoint and reach web users whose attitudes and issue positions make them most receptive to certain messages and calls-to-action…Micro-Targeting Means Higher-Performance Campaigns: Resonate Networks delivers higher concentrations of your target audiences, translating into greater exposure for your campaign among the right mix of people…Message Segmentation: The success of your campaign may require reaching different audiences with different messages: A supportive audience may receive a direct response offer, while others who are unaware of your products or their benefits may receive an educational message designed to nurture their interest over time. Reduced Budget Waste:  Resonate offers the ability to reach web users that are pre-disposed to your message or product based on their attitudes or beliefs. Conversely, Resonate can help avoid those who hold opposing or conflicting beliefs.”

In addition, Resonate says that it uses “Rich Attitudinal Data:

  • Resonate targets campaigns based on layers of detail on a range of audience attitudes, including:
    • Issues and issue positions
    • Engagement/influencer status
    • Ideology
    • Media consumption
    • Religiosity
    • Partisanship
    • Vote history”

Memo to Acting FCC Chair Michael Copps on Cable TV “Branded Storytelling”: A Tour of Embedded TV Advertising

Dear Mr. Chairman:

We are emailing you the link to this week’s Advertising Age’s story called “Designing a Custom Fit: Cable Offering more integrated, multiplatform deals.”  If you needed any additional evidence that the business model that further merges programming content with advertising requires scrutiny, debate, and safeguards (especially in the youth market), we offer the following article excerpts as evidence.  Clearly, the comedy writers are creating the marketing strategies for some of the cable programming networks.  But I’ve put a few of the best lines in bold:

Call it extreme sponsorship.

As advertisers look for maximum returns on their media investments, cable networks are offering an increasing number of creative, customized and multiplatform ways to partner with marketer brands—and to make sure viewers are paying attention.

The options for integrated marketing have gone far beyond a title sponsorship or a simple product placement. Today the buzzwords are “content-mercials,” “intromercials,” “branded storytelling” and custom marketing. Network series stars are featured in marketers’ commercials—and marketers’ products have a starring role in hit series…USA Network’s approach is to treat an advertiser’s brand as a supporting character in its multiplatform “Characters Welcome” credo. “Our network is not about one genre or one demographic. We are about characters. We celebrate the character of your brand,” says Chris McCumber, exec VP-marketing, digital and brand strategy for USA Network…

USA’s hottest show right now is “Burn Notice.” In its inaugural season, “Burn Notice” partnered with Saab 9-3 for an online game, “Covert Ops,” that allowed users to “drive” a virtual Saab all over Miami…In “Covert Ops,” “while you are playing the game, you are using the elements of Saab. The game drew more leads to Saab.com than the number of cars available to sell,” Mr. McCumber says. “The gaming area has incredible opportunities for brand integration.”…USA’s on-air integrations include using Hoover vacuums to “sweep” graphics off the screen during “Clean House.”…

On A&E Television Networks’ History, Subaru is a presenting sponsor for the upcoming “Expedition Africa: Stanley & Livingstone.”…

“We provided the explorers at certain points in the expedition [in four episodes] with the Subaru—where it made sense,” says Mel Berning, exec VP-ad sales for A&E Television Networks.

The integrations highlight features such as trunk space capacity and vehicle toughness off-road. Thirty-second “content-mercials” will run in every episode…AMC is promoting its Branded Storytelling—a way for advertisers to tell their brand stories through AMC’s programming, says Bill Rosolie, AMC exec VP-sales….Examples include: Takeovers, where marketers can own an entire episode, movie or day with their messages; Matching Moments, where AMC breaks the action with a sponsored pod that directly follows relevant content; and “Matching Attributes,” where brands’ messages are connected to key movie content by using custom creative to run within the film…

Nickelodeon has made multiplatform integration central to its ad sales efforts. This year Nick teamed with Walmart for an integrated effort celebrating the 10th anniversary of the No. 1 kids show, “Sponge Bob Square Pants.” The plan included TV, print and online media backed by in-store support. The Happy Place inside its Walmart stores offered exclusive Sponge Bob merchandise. A microsite (www.spongebobhappyplace.com) requests a sign-on code, only available at Walmart stores, to allow visitors access to exclusive content.

In 2008 Nick and AT&T joined efforts on a Web site where kids could text “iCarly,” get an iCarly ringtone, view cool gadgets (such as the Palm Centro or the AT&T Slate) and see a sneak peek of the iCarly movie “iGo to Japan,” which aired last November.

source:  Designing a Custom Fit.  Nancy Coltun Webster.  Ad Age.  May 4, 2009

“Microtargeting at scale”–a look at one Behavioral Targeting Online Ad Network

We urge everyone, including the FTC and Congress, to review Ad Age’s “Ad Network & Exchange” guide published on April 20, 2009.  Much of it is online.  Here’s an except from Tribal Fusion:

“We offer:

  • Vertical expertise
  • Deep customer insights
  • Comprehensive targeting tools…Tribal Fusion works with a broad array of data sources to provide a true 360º consumer view. We aggregate data to pinpoint interests, past actions and likely future behaviors. This enables each campaign to get smarter over time, informing clients about which data points are making consumers convert.
    Microtargeting at scale

    Tribal Fusion can deliver personalized messaging to multiple niche audiences on an exceptional scale, combining consumer understanding with comprehensive targeting technologies and dynamic creative. The content of a single ad unit can be tailored by the geography, demographics and lifestyle of individual viewers, producing thousands of personalized ads in real time. Ad units with dynamic copy can perform six to seven times better than static ads.“

Cable TV’s Targeted & Interactive Ads: Benefiting from a “enormous fire-hose of data”

excerpt from Advanced Advertising.  Linda Hardesty.  Cablefax.  April 1, 2009:  “There’s a lot of technology in place for data collection,” said Ross [Doug Ross, Cisco’s VP of business development in the service provider video technology group]. “We can collect almost an unimaginable amount of data at a granular level. The industry grapples with what’s the right architecture that would make this enormous fire-hose of data more useful.”

“The challenge is the enormity of that whole set of data,” agreed Woidke [Paul Woidke, SVP and general manager of advanced advertising at Open TV – and chair of SCTE Digital Video Subcommittee (DVS) Working Group 5]. “Eighty-five percent of homes in the U.S. have some kind of satellite or wired connection with a potential return path.”

Instead of just getting Nielson data for a selected sample of homes, a cable operator could gather data from all its subs and know what people watched, when they watched it, and how they behaved in terms of pausing, rewinding and fast- forwarding.

Congressional Internet Caucus and the State of the Mobile Net: Corporate Donors Influence Group’s Agenda, Leaving Public Vulnerable to Loss of Privacy

When will members of the Congressional Internet Caucus wake up and address the role its special interest dominated “Advisory” Committee is playing?  The Caucus is holding a “State of the Mobile Net” conference on April 23.  It’s doubtful Congress will be receiving the unbiased information they need, given that the sponsors of the event are the leading companies engaged in mobile marketing and data collection.  As typical of the “business model” crafted by the Center for Democracy and Technology connected group known as the Internet Education Foundation, the event prominently acknowledges its  “Platinum” sponsors: the CTIA lobby group, Google, Microsoft and Verizon.  “Gold” sponsors are AT&T, Nokia, T-Mobile.  There is also a category called “promotional” sponsors which lists Yahoo and several others.

It’s highly unlikely that the meeting will discuss the real issues challenging consumer privacy and welfare on the mobile Internet (including, we expect, the recent CDD/USPIRG complaint filed at the FTC– which has helped launch an investigation into that market).   The Advisory Caucus is run by the Internet Education Foundation, whose board members include representatives from Google, Verizon, Comcast, Microsoft, Recording Industry of America, and the Consumer Electronics Association. So the line-up of speakers is crafted to make sure that corporate donor feathers–and their willingness to continue to financially contribute–aren’t ruffled.  On the privacy panel for the event we have, of course, a representative from CDT.   There are also mobile marketers–including Yahoo and loopt.  There is the DLA Piper law firm that advocates for industry and a lone academic. Consumers and citizens deserve better from Congress.

PS:  As an example of how incredibly biased the Advisory Committee to the Congressional Net Caucus is, look at the description and speaker line-up of its recent briefing on online advertising.  A supposed “unbiased” event,  it featured industry lobbyists and several groups funded by online marketers!  Incredibly shameful!

Advisory Committee to the Congressional Internet Caucus

Anatomy of Online Advertising: Understanding the Privacy Debate
March 30, 2009…The purpose of the briefing is to provide an unbiased foundation for understanding the various privacy issues that Congress will debate in the context of online advertising.

Panelists:

* Paula Bruening, Hunton & Williams
* Maureen Cooney, TRUSTe
* Michael Engelhardt, Adobe Systems
* Tim Lordan, Congressional Internet Caucus Advisory Committee
* Jules Polonetsky, Future of Privacy
* Heather West, Center for Democracy & Technology
* Mike Zaneis, Interactive Advertising Bureau

Google and WPP Fund Neuromarketing Research for Digital Ads: Ethical Issues and the Need for Policymaker Scrutiny [with an update on the grants!]

The Wall Street Journal and other publications report that Google and ad giant WPP will announce today the $4.6 million grants it will award for academic research designed to “improve understanding and practices in online marketing, and to better understand the relationship between online and offline media.” Among the research efforts given funds are projects that will “analyze internet users’ surfing habits to determine their thinking styles, such as whether they are most influenced by verbal or visual messages or if they are more holistic or analytical, and how to tailor ads accordingly” and an “analysis into how online ads effect blood flow to different areas of the brain. This research would seek to show the role that emotions play in decision making.”   Academics from MIT, Stanford, and Harvard will receive funds, among others. (And for those of us concerned about the role online advertising and data collection is playing in China–and impacts human rights and environmental sustainability–one of the new grants will fund “how Chinese web users respond to different online-ad formats, such as display and search ads”).

As we will tell the European Commission at the end of the month, at a workshop they have organized to discuss interactive advertising and consumer protection, the evolving role of neuromarketing with online advertising raises a number of troubling concerns–and should trigger a serious policy review.   We have not yet seen a final list of the grantees.  But Google should be funding independent research that will honestly explore the impact and ethics of online marketing.  They should be ensuring that the ethical issues of online marketing–such as the concerns raised by their new behavioural profiling and targeting system–receive a honest scholarly review.

The growing controversy over the role pharmaceutical companies are playing with scholarly research on drugs, we think, has implications here.  We believe all the academic institutions receiving these grants must vet them to ensure they truly address the real impact online ad techniques have on individuals and society.

Update:  Google & WPP made the academic research announcement–eleven grants awarded.  Here are some to ponder–and raise questions:

*  “Targeting Ads to Match Individual Cognitive Styles: A Market Test”; Glen Urban, Professor, MIT Sloan School of Management;

*  “How do consumers determine what is relevant? A psychometric and neuroscientific study of online search and advertising effectiveness”; Antoine Bechara, Professor of Psychology and Neuroscience, Department of Psychology/Brain & Creativity Institute, University of Southern California and Martin Reimann, Fellow, Department of Psychology/Brain & Creativity, University of Southern California;

*“Unpuzzling the Synergy of Display and Search Advertising:Insights from Data Mining of Chinese Internet Users”; Hairong Li, Department of Advertising, Public Relations, and Retailing, Michigan State University and Shuguang Zhao, Media Survey Lab, Tsinghua University;

*”Are Brand Attitudes Contagious? Consumer Response to Organic Search Trends”; Donna L. Hoffman, Professor, A. Gary Anderson Graduate School of Management, University of California Riverside and Thomas P. Novak, A. Gary Anderson Graduate School of Management, University of California Riverside;

*“Marketing on the Map: Visual Search and Consumer Decision Making”; Nicolas Lurie, Assistant Professor of Marketing, College of Management, Georgia Institute of Technology, College of Management and Sam Ransbotham, Assistant Professor of Information Systems, Carroll School of Management, Boston College.

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.

Google’s Federal Sales Division– “in position to capture Uncle Sam’s spending”

John Letzing of Marketwatch wrote an interesting story last week on Google’s DC-based federal sales division.  Microsoft and many others have long sold technology related products to government.  But as consumer database and online advertising companies, including Google, seek to secure federal contracts, what goes on should be transparent to the public.  Here’s a few excerpts from Mr. Letzing’s fine article, which we urge you to read in its entirety:

“…Google is increasingly well positioned to tap at least one big spender to be found amid the economic malaise: the federal government…Some $20 billion in additional, wide-ranging federal spending is expected to go into technology as part of the recently-passed stimulus package…while the proposed 2010 budget should include at least three times as much for tech-related projects…Google, which in December leased 15,000 square feet of office space for a Washington-area outpost, pitches “search appliances” to agencies, or pieces of hardware installed within a network to facilitate quick access to internal documents and databases…Google has at least one key supporter of [Google] Apps in the new administration. On Thursday, President Obama named Vivek Kundra as the government’s chief information officer. In his former capacity as the District of Columbia’s chief technology officer, Kundra switched its public agencies to Google Apps from Microsoft…There may be even more evidence of Google’s federal bounty, if sales to classified intelligence agencies such as the National Security Agency were made public.”

Google in position to capture Uncle Sam’s spending:  Federal agencies testing Google tools; a key fan is Obama’s new tech hire.  John Letzing.  Marketwatch.  March 6, 2009

Google Does Behavioral Targeting. Why Is It Trying to Fool Users & PolicyMakers By Claiming it’s “Interest-Based” Advertising? [Annals of Commercial Surveillance]

Google has finally fully entered the behavioral targeting business, although they are trying to disguise it through an Orwellian change of language by calling it “interest-based” advertising. The world’s largest and most dominant online ad system is expanding its data collection and targeting activities whenever we search, view videos or read blogs.  This isn’t really about, as Google’s blog suggests, “more interesting” ads for consumers. It’s about a further expansion of Google’s already considerable data-mining and interactive marketing and data-tracking/targeting arsenal, which now also includes using neuroscience for its YouTube ads.  Google is further endorsing a global culture with data collection, profiling and targeting at its core.  No matter how Google attempts to frame it as “better for you ads,” digital advertising is designed to influence our behaviors in non-transparent ways.

This announcement, which was done so Google can better incorporate all the behavioral targeting technologies it acquired when it bought online ad targeting giant DoubleClick, is also designed to help head-off the enactment of privacy laws in the US and EU (Google isn’t alone here.  Microsoft, Yahoo and others are in a global race in attempt to preserve the data collection status quo under the cover of industry self-regulation).  Giving consumers access to their (incomplete and likely to constantly be revised with even more targeting categories) profile has to be viewed with such a perspective–it serves as a smokescreen so Google can broaden its data collection and targeting (and become even more dominant in the global online ad business).  Instead of having the default be no data collection without prior expressed informed consent, Google has created the system as an flawed opt-out.  Missing from what users should know and control in their profile are the applications online marketers use to develop the ad so it can more effectively target (and collect data), including: neuromarketing, viral videos, rich immersive media, social networks, online product placement, etc.

Yesterday, Google should have called on Congress, the EU and other governments to enact meaningful consumer privacy safeguards.  While it is entirely to be expected that as the world’s largest online ad company Google would fully embrace behavioral targeting,  it’s also unfortunate.  Eventually–and we hope soon–responsible shareholders, such as socially conscious investment funds, and global regulators will hold Google–and other online marketers–more accountable to the public.

But stay tuned for the next entry, on what Google, Microsoft and Yahoo have done to evade privacy safeguards for behavioural targeting in the UK!

Why TRUSTe Can’t Be Trusted: A Failure to Address Behavioral Targeting

TRUSTe, a group which has helped industry stave off regulatory privacy safeguards, released a survey today that–surprise!–says people really aren’t that concerned about behavioral targeting.  We have reviewed the survey questions they asked–and they failed to really inform those interviewed about how behavioral targeting truly works (including the context for interactive advertising).

This kind of research raises questions about TRUSTe’s ability to engage in serious scholarship.  If they are going to conduct any future research, they need to engage the services of independent academic experts with a knowledge of the field, and who aren’t connected to industry.

The so-called survey released today has to be viewed as part of the online ad lobby effort to ward off federal and state consumer protection/privacy rules.