Disney’s Bob Iger, Kids and Behavioral Tracking/Targeting: He Claims “Kids don’t care” about their Privacy

My friend the children’s TV activist Peggy Charren, back during the 1970’s and 1980’s, had a favorite expression when it came to dealing with self-serving media moguls who trampled on concerns about kids:  “I’d like to wash your mouth out with soap,” she would exclaim (given her tenacity, they knew she meant business).  Robert Iger, the head of Disney, is quoted in Reuters saying that: “If we could sell your behavior to an advertiser — I am actually pretty bullish about what technology is going to allow in terms of behavioral tracking. I think we are going to have information to sell to marketers.”

Unbelievably, Mr. Iger, when citing concerns over privacy, says that: “Kids don’t care,”…adding that when he talked to his adult children about their online privacy concerns “they can’t figure out what I’m talking about.”

Mr. Iger has just dramatically tarnished the Disney brand, by suggesting that it’s okay to engage in digital marketing and data collection to children and adolescents.  Not only is he thumbing his nose at the bipartisan Children’s Online Privacy Protection Act, but the growing concern health, parenting and children’s groups have regarding youth privacy and consumer protection.  Instead of Disney being a youth industry leader when it comes to digital marketing, it appears the company is shirking what its role should be.  Peggy–I hope you still have one of those bars of soap!

Viacom/MTV Uses Neuromarketing to research ads in video games [Annals of Neuromarketing]

As we explained last month in our congressional testimony on behavioral targeting and advertising, the growing reliance on neuroscience-related techniques to design digital marketing messages is a serious policy issue.  Here’s an excerpt from a recent Viacom/MTV press release on a study it commissioned:

Using breakthrough biometric monitoring, a new study by MTV Networks has uncovered the most effective strategies for marketers to reach casual gamers.  The study, “Game Plan: Strategies for Marketing through Casual Games,” found that casual games command 99 percent focused attention from consumers.  By tracking respondents’ hand sweat, heart rate, respiration, movement patterns and visual attention during game play, the research yielded a clear road map for harnessing that engagement through targeted ad formats, lengths and integrations.

“Casual gaming continues to grow as a dominant online activity, and marketers have more opportunities than ever to connect with these highly engaged consumers from nearly every demo,” said Nada Stirratt, Executive Vice President of Digital Advertising, MTV Networks.  “This study provides a blueprint on how to leverage casual games for every marketing objective from driving awareness to increasing purchase intent to building a brand.”

The study was presented today to marketers and media buyers at MTV Networks headquarters in New York.   The research revealed a number of strategies for marketers looking to connect with casual gamers:

o     Get Ahead of the Action: Video placed before action games is among the most effective use of online video, commanding up to 85 percent focused attention.
o     Shorter is Better: A fifteen second pre-roll ad before a game commands 85 percent focused attention for the duration of the ad. Significantly, longer pre-rolls can be damaging, as aided recall for these drops by more than half.
o     Get in the Game: Brand integrations, or advergames, are best for games requiring higher levels of mental processing and focused attention. In games where brands achieved fifteen seconds or more of focused attention, aided recall approached 80 percent.
o     Anticipation = Opportunity: Consumer anticipation is a powerful opportunity — the load screen, menu pages and reward screens in games represent ideal placements for brand messaging, as gamers have the highest level of cognitive processing while waiting for their game to begin.

“Game Plan” tracked eye and biometric measures of respondents as they engaged in four online gaming experiences. These included a combination of branded and unbranded games, as well as video and display advertising around the games.  Biometric signals were integrated with data obtained from eye trackers, which measured players’ visual attention and pupillary response

source: Breakthrough Biometric Research Uncovers the Most Effective Advertising Strategies for Connecting with Casual Gamers: New MTV Networks Study Reveals The “Game Plan” For Casual Gaming Advertising.  June 10, 2009

Progress & Freedom Foundation Comes to Aid of its Data-Collecting Backers (Using a `save the newspapers’ as a ploy to permit violations of consumer privacy protection!)

This report from Internetnews.com on the Progress and Freedom Foundation’s “Congressional” briefing illustrates how desperate some online marketers are that a growing number of bi-partisan congressional leaders want to protect consumer privacy.  So it’s not surprising that some groups that are actually financially supported by the biggest online marketing data collectors in the world would hold a Hill event to help out the friends who pay their bills.

It should have been noted in Ken Corbin’s that Google, Microsoft, Time Warner (AOL), News Corp. (MySpace) financially back the Progress and Freedom Foundation (PFF).  Other behavioral data targeting `want to be’s’ who monopolize U.S. online and other platforms are also backers:  AT&T, Comcast, NBC, Disney/ABC, Viacom/MTV/Nick, etc. For a list, see here.

PFF and some of its allies deliberately distort the critique of consumer and privacy groups.  We are not opposed to online marketing and also understand and support its revenue role for online publishing.  But many of us do oppose as unfair to consumers a stealth-like data collection, profiling and ubiquitous tracking system that targets people online.  One would suppose that as a sort of quasi-libertarian organization, PFF would support individual rights.  But given all the financial support PFF gets from the major online data collectors, how the group addresses the consumer privacy issue must be viewed under the `special interests pays the bills’ lens.

PFF and its allies are playing the ‘save the newspaper’ card in their desperate attempt to undermine the call for lawmakers to protect consumer privacy.  Newspapers and online publishers should be in the forefront of supporting reader/user privacy; it enhances, not conflicts, with the First Amendment in the digital era.  Finally, PFF’s positions on media issues over the years has actually contributed to the present crisis where journalism is on the endangered species list.  This is a group that has worked to dismantle the FCC, eliminate rules designed to foster diverse media ownership, and undermine network neutrality.

PS:  The article quotes from Prof. Howard Beales of George Washington University (and a fCV,ormer Bush FTC official with oversight on privacy).  Prof. Beales was on the PFF panel.  Prof. Beales, according to his CV has served as a consultant to AOL and others (including  Primerica and the Mortgage Insurance Companies of America).  Time Warner, which owns AOL, is a PFF financial backer.  All this should have been noted in the press coverage.

Online Consumers Require Real Privacy Safeguards, Not the Digital Fox [AAAA, ANA, BBB, DMA & IAB] in Charge of the Data Hen House

The self-regulatory proposals released today [2 July 2009]  by five marketing industry trade and lobby groups are way too little and far too late. This move by the online ad industry is an attempt, of course, to quell the growing bi-partisan calls in Congress to enact meaningful digital privacy and consumer protection laws. It’s also designed to assuage a reawakened Federal Trade Commission–whose new chair, Jon Leibowitz, recently appointed one the country’s most distinguished consumer advocates and legal scholars to direct its Bureau of Consumer Protection (David Vladeck). The principles are inadequate, even beyond their self-regulatory approach that condones, in effect, the “corporate fox guarding the digital data henhouse.” Effective government regulation is required to protect consumers. We should have learned a painful lesson by now with the failure of the financial industry to oversee itself. The reckless activities of the financial sector—made possible by a deregulatory, hands-off government policy–directly led to the current financial catastrophe. As more of our transactions and daily activities are conducted online, including those involving financial and health issues–through PCs, mobile phones, social networks, and the like–it is critical that the first principle be to ensure the basic protection of consumer privacy. Self-dealing “principles” concocted by online marketers simply won’t provide the level of protection consumers really require.

The industry appears to have embraced a definition of behavioral targeting and profiling that is at odds with how the practice actually works. Before any data is collected from consumers, they need to be candidly informed about the process–such as the creation and evolution of their profile; how tracking and data gathering occurs site to site; what data can be added to their profile from outside databases; the role that data targeting plays on so-called first-party websites, etc. In addition, the highest possible consumer safeguards are necessary when financial and health data are involved. Under the loosey-goosey trade industry principles, however, only “certain health and financial data” are to be treated as a “sensitive” category. This would permit widespread data collection involving personal information regarding our health and financial concerns. The new principles, moreover, fail to protect the privacy of teenagers; nor do they seriously address children’s privacy. (I was one of the two people that led the campaign to enact the Children’s Online Privacy Protection Act).

The failure to develop adequate safeguards for sensitive consumer information illustrates, I believe, the inability of the ad marketing groups to seriously address online privacy. The so-called “notice and choice” approach embraced by the industry has failed. More links to better-written privacy statements don’t address the central problem: the collection of more and more user data for profiling and targeting purposes. There needs to be quick Congressional action placing limits on the collection, use and retention of consumer data; opt-in control over profile information; and the creation of a meaningful sensitive data category. Consumer and privacy groups intend to work with Congress to ensure that individuals don’t face additional losses due to unfair online marketing practices.

[press statement by the Center for Digital Democracy]

Microsoft uses brain research to improve ads in online games, including for Doritos [annals of neuromarketing]

excerpt:  “…in-game ads have begun to move out of the “experimental buy” bucket and into the media plan because advertisers now realize that ads in games produce results…Measurement is very important…Earlier this week, the Interactive Advertising Bureau (IAB) released new in-game advertising guidelines for public comment to establish a common methodology for counting impressions and to simplify the process of buying and selling in-game advertising… Microsoft’s advertising arm also has been involved in a study that examines the emotional reactions consumers have toward advertising campaigns in and around video games. The first phase of the study — conducted with EmSense, a neuroscience company — compares the findings with similar results from television commercials. The companies discovered that the interactive elements in the video game ad campaigns evoke stronger emotional connections with consumers and more positive emotional associations with the brands.

EmSense analyzed several different advertising campaigns on Xbox 360 games, Xbox Live and MSN Games. Some brands involved in the study include Doritos, Kia, Sprint, Hyundai and Microsoft.

In-Game Ads In The Ad Game.  Laurie Sullivan.  Online Media Daily.  June 16, 2009

PS:  Among the in-game ad categories [excerpt] proposed by the IAB include (and I kid you not!):

 3.1.1.1 Valid Ad Impression:
The threshold for a valid Ad Impression is a cumulative exposure to an ad of ten (10) seconds.   An In-Game Measurement Organization may accumulate ad exposures of shorter time lengths to achieve this Ad Impression threshold…

3.1.2.2 Lighting
Only ads that are visible within the virtual game environment with sufficient lighting during darkness should be counted.

3.1.2.3 Maximum Ad Angle Relative to Game Screen
The angle of the ad must be no greater than 55 degrees relative to the game screen.

The Growing Role of Advertising in Online Video (and a Pitch by Google for Greater Ad into Content Integration)

As advertisers continue to exert greater influence in online programming content (and as we prepare for what will eventually be a digital version of the 1950’s Quiz show scandals), we are tracking this trend.  Here is an excerpt from Screenplays magazine on a recent Internet “upfront” conference held by ad company Digitas:  Across the board the message was that advertisers aren’t interested in backing web content without having access to precisely the right performance data…Measuring engagement…is a big component of tracking ROI…Carls Jr. recently rolled out an online video campaign with eight YouTube stars, said Alex Levy, director of Branded Entertainment at Google.  “Brands increasingly have an appetite for web content and the DVR has made everything old new again.  We have to keep figuring out how to integrate into the content itself, she said.

New York Web Confab Reveals Hurdles Agencies Have Set for Video Ad Metrics.  Screenplays.  June 9, 2009

Google’s YouTube Pushes Carls Jr. Burgers. 53 grams of fat/870 calories/It’s #1 Video Ad for the Week

Take a look at this YouTube branded ad campaign for Carls Jr.  Look at the nutrition information.  The ad, says Visible Measures, is at the “number one spot on the Top Ad Campaigns chart this week showcases vloggers from the Nigahiga comedy group chomping down for Carl’s Jr.’s How To Eat A Burger campaign, which features the Portobello Mushroom Burger. The campaign grabbed a record-breaking 3.3+ million views…”

MTV uses Neuroscience to Analyze Ads for Games: Examining “the optimal way of connecting to this audience when they’re that rabid and that engaged.”

excerpt:  “…MTVN  conducted a three-day study of more than 60 gamers at a biometrics lab in Las Vegas; they showed the players various ads and games, all while examining stats like heart rate, respiration, movement patterns and visual attention. Interestingly, they found that 15-second pre-rolls were the most effective way to garner a player’s “focused attention”—beating out 30-second spots, in-game display ads, and even overlays. Pre-roll ads commanded up to 85 percent focused attention, MTVN’s study found, meaning that the vast majority of the viewers paid full attention to the ads…“The question we wanted to answer was do ads need to be more disruptive to be effective?” said Jason Witt, GM for MTVN’s Digital Fusion ad unit. “We can always stick a bigger ad in front of somebody. And we found that you don’t have to be more disruptive, by and large. The proof is that 15-second pre-rolls were the most effective.” The study also found that game ads had 8x higher unaided brand awareness over online display ads in general, and fueled a 12x higher intent to purchase…So for us, the goal is to see what’s the optimal way of connecting to this audience when they’re that rabid and that engaged.” 

source:  Need To Reach Casual Gamers? MTV Says 15-Second Pre-Rolls Work Best.  David Kaplan.  paidcontent.org.  June 10, 2009.

Google Promotes Carls Jr. via special YouTube Ad Deal: But “won’t be marked as ads”

excerpt via Adweek:

Justine Ezarik might not be a household name, but the 25-year-old has a cable TV-size audience… Thanks to Google, she’s also now part of Carl’s Jr.’s effort rolling out this week to sell the Portobello Mushroom Six-Dollar Burger to young men. The search-engine giant drafted Ezarik and eight other popular YouTube creators to participate in an ad campaign for the fast-food chain on the video-sharing site…

The YouTube stars were chosen not only for their creative flair, but for the networks of followers they can mobilize. Ezarik, for instance, not only has 94,000 subscribers to the iJustine YouTube channel — the nine YouTube celebs combined total 3.8 million subscribers on the site — but also boasts 590,000 followers on Twitter and 25,000 Facebook fans…Google is adding such deals to its advertising arsenal as it attempts to turn the video site into a moneymaker… Other new tools include tying advertiser videos to search results and matching high-profile creators like Seth MacFarland with brands…

The Carl’s Jr. videos will live on a dedicated YouTube channel, the creators’ pages and in ad units across sites in the Google ad network. They won’t be marked as ads on the YouTube pages, but will carry a notice they were paid for by Carl’s Jr. Each video also invites users to upload their own videos of how they eat a burger.

source:  Carl’s Jr. Makes New Kind of Network Buy:  Burger promo leans on vast reach of YouTube content creators.  Brian Morrissey.  Adweek.  June 1, 2009

Behavioral Targeting Merges with Social Media Marketing for Individual Profiling [Annals of Behavioral Targeting]

As a growing number of people recognize (and taking advantage of), behavioral targeting is part of the social media marketing business model.  Such an approach illustrates why policymakers across the globe must address what is a largely stealth commercial surveillance system.  It has implications for the collection of data on individuals by government as well [my bold].

Here’s a excerpt from a recent announcement by WPP owned 24/7 Real Media Inc.:  “the leading global digital marketing company, has begun a pilot program to integrate social media engagement metrics into its behavioral targeting application. These social media engagement metrics will augment existing behavioral targeting attributes to drive robust advertising response and conversion.  Working with companies such as NuConomy, an innovator in social media measurement, select 24/7 Real Media advertisers are now leveraging non-traditional metrics such as comments, ratings, video plays, and link sharing to customize advertising, increase responsiveness and drive purchases.”

and Nuconomy says that:
By tracking engagement and site activity at the individual user level, NuConomy’s module automatically builds rich behavioral profiles, or interest maps, for each user – such as who is posting comments on bikes or sharing music recommendations with friends. This level of detail gives publishers a deeper understanding of user behavior so they can optimize their sites and marketing messages for different audience segments, even different individuals.”

PS:  We see that the folks over at the AT&T, Yahoo, AOL, etc. backed Future of Privacy Forum has engaged WPP to help its new research effort designed “to develop a variety of [privacy] notices that will resonate with consumers and begin to test them with users.”

We suggest that as its initial effort, the Forum require WPP to make public all the various methods it uses to collect data from consumers.  Such a list includes WPP’s ad networks, online games, mobile, cable broadband platforms, social media, etc.  That would provide the research initiative a good place to begin, if its effort is to be taken seriously.