Category: Congress

Facebook Promotes its “Virtual” Currency–and its data tracking–via Cancer Charity

When big advertising and media companies want to introduce a new or expanded form of marketing, they generally found some non-profit cause.  Who can complain about the techniques used–say for mobile ads, data collection, online games–when the funds are earmarked for a worthy charity?  It’s a time honored tactic, done by the Ad Council, initiatives such as Pepsi Refresh and now Facebook.  AllFacebook reports that “Stand Up to Cancer” is asking supporters to donate using “Facebook Credits.”  It explains that:

Facebook has been making great progress in its goal of making Credits the main or exclusive virtual currency on the site, with Zynga the latest social game company to agree to an exclusive deal. Facebook makes a 30% cut when users spend Credits on virtual goods in social games such as Farmville or Mob Wars… Facebook does gain in other ways from the collaboration, besides feeling good about helping cancer research. The fundraising event will help promote Facebook Credits as a payment system, both on the site through user activity and potentially also through the hour-long celebrity fundraising telethon on ABC, CBS, Fox, NBC and some cable channels …

On the Facebook “Stand Up to Cancer” page, one can learn that “Facebook Credits are the safe and easy way to make payments on Facebook. You can buy Facebook Credits using PayPal, your credit card, or mobile phone. Please keep in mind if your donation includes Facebook Credits that you received for free, the value of your donation will be reduced by those free credits. Also, your donation may not be tax deductible, so please consult a tax professional. For this event, Facebook is waiving its processing fees and 100% of your donations go to Stand Up To Cancer.”

Facebook has ambitious plans for its Credit initiative: it “wants Credits to be the universal currency in social games on its platform.”  The social network is using Credits with a Target stores partnership.  Earlier this month, Facebook took “a step closer to establishing Credits as the exclusive payment system for virtual goods on the social networking site, wrapping up a deal with the biggest social game company, Zynga…Facebook gets a 30% cut from the game developer for all transactions via Credits.” Virtual goods, as its called, is already a major business–estimated with $1 billion sales this year.

But there are questions around Facebook Credits and other virtual currencies–on privacy, consumer protection rules, and digital marketing.  Charities and others should be more cautious when endorsing such schemes.  The FTC, EU and other regulators need to place digital currencies on a real–not virtual–policy radar.

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!

Retargeting 3.0–It tracks and observes a consumer, adds new data–and changes its sales pitch

Yesterday, the New York Times ran a front-page story on retargeting--the practice of stealthily tracking an individual user online in order to keep delivering sales pitches–including for health and financial products.  We gave the NYT lots of information, including how so-called “smart” ads technologies are now melded with retargeting–for so-called “Retargeting 3.0.“  [My CDD and USPIRG, btw, asked the FTC to investigate retargeting back in 2007 and to protect consumers].  Here’s some of what we sent to the Times.

From Criteo:“Retargeting allows you to find your previous website visitors across the Internet and display relevant banners to lead them back to your website to complete their transaction. Bringing ready-to-buy users back to your website after they have left should be a key part of your customer acquisition and conversion strategy. Criteo provides a breakthrough dynamic personalised retargeting solution…Criteo has revolutionised retargeting with the most sophisticated form of dynamic personalised retargeting. Over the past decade there has been a slow evolution of retargeting. This third generation of retargeting enables an advertiser to show each lost visitor a unique banner based on his/her very specific past interactions on the advertiser’s website. This new form of retargeting involves on-the-fly, real-time personalised banner creation and has a dramatic impact on campaign performance.”

Retargeting data now incorporates user information from outside demand side platform sources, and can the rights to retargeting you can be sold to the highest bidder via online ad exchanges, such as the one run by Google.

A recent MediaPost panel sums up how retargeting has evolved:
Re-Thinking Re-Targeting 
Re-targeting continues to be the tried and true workhorse of behavioral targeting. Tagging and retrieving someone who has already shown an interest in your business is about as simple a use of the BT model as it gets. But it is not so simple any more, and like everything else in this complex ad economy, re-targeting too is in for a upgrade. Dynamic ad creation driven by recommendation engines offers new opportunities to marketers to be even more effective. Demands for greater accountability, control over placement and clearer attribution press the ad networks and tech providers to provide new levels of transparency. And just like everyone else in the ad economy, re-targeting is working its way through questions about metrics and pricing, do marketers optimize and pay according to clicks, conversions, purchase? And what role does retargeting now play in this larger field of audience creation and the age of the DSP?

Retargeting illustrates how online marketers have deployed armies of digital private detectives to shadow us online.  They watch us closely, take notes, even learn about us, and then appear when we don’t expect it.  Consumers shouldn’t have to confront such digital surveillance.  Retargeting is “Exhibit A” in making the case to lawmakers that consumer privacy online should be protected.

Questions should also be raised about retargeting and consumer protection.  Should I get a better discount because the data collected about me indicates I spend more or live in an expensive neighborhood? Or that because they believe I am a certain ethnicity, I might spend more on certain products.  Retargeting is a non-transparent marketing technique that raises important consumer protection issues about the use of digital advertising.  Consumers require a fair deal online.

PS:  Here’s how Google explains its retargeting service–which in typical Silicon Valley meets George Orwell fashion, it calls “remarketing’ [for the Google Content Network]: “Remarketing is extremely effective because it targets a highly-relevant audience. With it, you can target users who:

  • have visited your website or viewed specific product categories on your site
  • didn’t convert or who abandoned their shopping cart
  • have converted (in order to up- or cross-sell to them)

If you’re already driving traffic to your site through other means, like contextual targeting or your search ads, remarketing is a great complement to those efforts to increase your return-on-investment (ROI).”

and we believe in fair play.  Here’s what Microsoft says its “remessaging” service can do:   “After consumers visit your site, see one of your campaigns or click through on an ad, remessaging offers several ways to continue the conversation and ensure that your message is seen by the people to whom it matters most.  With site remessaging, you can re-engage a consumer to complete a purchase or further engage with your brand. Creative remessaging drives brand perception, awareness, and favorability, and enables advertisers to re-engage audiences who have seen or clicked on an existing campaign. Email remessaging complements email assets such as newsletters by placing tags and accessing the same email recipients to reinforce your message to a loyal audience.”

and Yahoo!:  “…Enhanced Retargeting, which combines standard site retargeting with dynamic ad generation. For example, users who visit an airline website to check offers for flights from SFO-JFK can be served a personalized offer for that specific flight when they visit a page within the Yahoo! Network. In a recent trial, a market-leading online travel company saw a 230% increase in total bookings and a 651% increase in click-through rate when comparing Enhanced Retargeting to their traditional retargeting campaign.  Recognizing the need for more focused audience segmentation and improved control, Yahoo! Search Marketing will offer advertisers Enhanced Targeting capabilities for Sponsored Search and Content Match programs. New features are designed to extend the advertiser’s control over where and when an ad is shown at both the campaign and ad group level, including what time of day and day of the week an advertiser would like campaigns to run (ad scheduling) and what age and gender they’d like to reach (demographic). Advertisers will be able to vary their bids for different segments in order to increase their ability to reach the desired audience.”

Rules Required for Data-mining and Consumer Protection: A good offer for you– but not for your neighbor!


As Congress and the FTC focus on 21st Century consumer protection safeguards to address the digital marketplace, a guiding principle should be accountability and transparency.  Advanced computer systems for both business and government far out-strip the ability of a single consumer to understand–let alone control–how their information is collected and used.  We need to have fair marketing rules so some people–because of their income, where they live, what the spend and what on and especially–race/ethnicity–find themselves confronting the emerging discriminatory web.  Take what Stream Base Systems does for e-commerce–and ask yourself: wouldn’t you want to understand how such real time data tracking and mining is used to determine prices and offers made for you? [excerpt]:

As Internet transactions and data volumes continue to skyrocket, more and more traditional eCommerce and Web 2.0 businesses need to monitor and instantly react to all user activity in real-time in order to ensure a positive customer experience, high customer retention rates, and greater profit…

  • Website Monitoring: With clickstream and transaction rates soaring, a growing number of high-traffic e-businesses are seeking to monitor and react instantaneously to website-generated real-time events. StreamBase enables e-Businesses to analyze and react to clickstreams in real-time, which in turn enables the immediate delivery of personalized cross-sell or up-sell offers, or online product merchandising customized to the real-time activity of site visitors.  By analyzing current web activity data and correlating this with stored customer history data, personalized offers can be generated that match the Web customer’s current interests and activity.


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.

Facebook Places, Brands, Ads & Data

We have been raising concerns about privacy and location data collection and targeting–including with our colleagues at USPIRG.  Facebook’s new location feature is designed to generate more user data that can be used by Facebook and its affiliates to bolster ad and brand targeting.  I want to excerpt this post from one of Facebook’s developers–Vitrue–which illustrates how soon companies like McDonald’s will work with Facebook to harvest local data and our behaviors:

“…A user will open up their mobile Facebook app and be able to see shops, restaurants, parks, areas, etc. that they are near.  They can then check-in to that location.  If a location doesn’t exist, the user can simply create it.  A story about where that person checked-in will be published to their profile and subsequently their friends’ news feeds…Facebook’s massive user-base is a distinct advantage and is likely to generate location-based activity orders of magnitude greater than other companies already in the space. As the leading social network, Facebook is able to capitalize upon the users existing friends, and use their collected demographic and preference data to show users places that it thinks is relevant to them, instead of just places nearby.

How Will Brands Take Advantage of Facebook Places?

With all of these users checking in to locations, what does that mean for brands?  Well if your brand has brick-and-mortar locations, your brand can claim these digital “Places”, turning the locations into Facebook Place Pages.

Brands can choose to merge a Facebook Place Page with an existing Facebook Page, if one exists, and if prompted– the option may not be widely available yet as Facebook is rolling it out over a period of days…

At this time Facebook does not recommend merging your Places with your Page if you are a national or global marketer with more than one location, like a McDonald’s or GAP.  They recommend managing the Places separately and have stated that a solution that will help these types of brands is planned for the future…Currently, Facebook CEO Mark Zuckerberg says they aren’t looking to monetize Facebook Places right now, but that doesn’t mean that they can’t in the future.   With Facebook collecting all of this location-based data, it seems like Facebook could allow brands to place highly targeted Facebook ads on the Places Facebook pages.  For example, if your brand’s products are sold in grocery stores, you could potentially place your ads on certain grocery stores’ pages to be viewed by people who’ve checked in.”

In another words, in the world of mobile and location ad targeting, our data will provide marketers with real-time sophisticated insights giving them a rich history of where we spend time and what we do [go to the bank, buy at the pharmacy, eat fast food, etc].  Such “360 degree” targeting, as the online marketers call it, require the appropriate privacy safeguards.

Google: Creating a “dynasty” in online data ad targeting

From the Connected Marketing Week in SF, via ClickZ:  Google is simultaneously attempting to fill the role of ad exchange, ad network, DSP (through its Invite Media acquisition), and media agency…Michael Rubenstein, president of AppNexus and the former head of Google’s ad exchange efforts, said Google has been admirably fair and transparent. But he said that could change.”Google is putting together the pieces to form a dynasty,” he said. “So far they’re behaving pretty well as far as keeping the ecosystem open to everybody, probably because they need to. But we’ll see what happens over time as they accumulate more market power.”