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.


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

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

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

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

Facebook Places, 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.”

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

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

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

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

Online Ad Lobby Raising $1 Million to Help Fight Against Privacy Safeguards

The Interactive Ad Bureau [Google, CBS, Comcast, NBC, Facebook, Fox, Microsoft, BlogHer and many others] is fundraising to “undertake additional coordinated advocacy at the Federal and state level. IAB is nearly half-way to our goal of raising $1 million in cash…”  Funds will be used to support a campaign that includes “our ongoing advocacy efforts to combat legislation and regulation that could damage the interactive advertising industry.”  IAB calls this its “Consumer Protection and Education Campaign,” because it also includes a goal of a billion online ads (to be donated by marketers) used to “support consumer and business understanding and appreciation of the interactive advertising industry.”

We are sure that there will be many–such as the growing interest of the news media in the issuethat will follow this special interest money–especially as the Congress and FTC focus on protecting consumers online.

U.S. Consumers Targeted with 1 Trillion Display Ads in 2010, First Quarter

That’s right–a Trillion.  Think about all the data collected.  Facebook itself delivered 176 billion display ad “impressions,” explains comScore.  Yahoo and Microsoft sent 132 billion and 60 billion ads, respectively.  Leading online advertisers that quarter were AT&T, Verizon, Scottrade, Experian and others–so think about privacy, network neutrality, online financial marketing and consumer protection all together.  These issues are all connected.

Online Ad Industry Exec Warns of Dangers from “Targetocracy”/Urges IAB to Take Privacy Issue Seriously

We’re glad other online industry leaders see that addressing consumer privacy issues is required–instead of the denials coming from the IAB online ad lobbying group.  Doug Weaver, CEO for the UpStream Group writes in response to the IAB’s op-ed in USA Today, for example that:

I think a sustainable privacy strategy begins with acknowledgment of the problem that exists.   Facts is facts: the “Targetocracy” in our business is big, wildly overcapitalized and a little bit out of control.  What I think consumers want to hear from Randy and the IAB is “we take the issues raised by the Journal very seriously.  The issues and the technology are quite complicated, but we remain committed to rooting out the bad guys and maintaining an environment that’s rich, free and privacy focused.”

As one of the IAB’s earliest board members and one who’s contributed a great deal of time and effort toward its mission over the years, I believe it’s time for the group to act less like the Chamber of Commerce and more like the Internal Affairs Department.  There are both rogues and careless polluters in our industry and their actions poison the environment for everyone.   Not everyone wants regulation, but the consumer wants to know someone’s in charge.  Who’s that going to be?

Tracking Consumers to Identify their “Intent” to Purchase Products and Services. Safeguards Required for Predictive Behavioral Targeting

As the FTC and Congress work to create new safeguards, they must address a range of issues related to new forms of data collection, profiling and tracking.  As the WSJ series illustrates [which used information provided by my CDD], privacy is at risk in today’s digital marketing system.  The growth of so-called “predictive” behavioral targeting is one example of marketers pushing the data collection technology envelope without considering the consequences to consumers and citizens.

Yesterday, for example, display ad company Dapper released a new ad product designed to improve display marketing that incorporates “user intent determination” with the “real-time” online ad auction process that sells access to individual consumers to the highest bidder.  In its release, Dapper explains that it can:  Infer users intent: Through IntentMatch, Dapper DisplayDR goes far beyond retargeting to harvest and combine behavioral (via the advertiser’s own data or 3rd party data), semantic, contextual, geographic, and performance signals to match each product and offer to user intent and inform the bidding process. This multi-dimensional approach improves accuracy and performance, and significantly expands the reach of display efforts beyond behavioral targeting alone…Serve dynamic display ads that match products to intent and are optimized for performance: With Dapper DisplayDR, advertisers can show each consumer the most relevant offers from the Product Search Engine matched to their intent…Receive insightful analytics on a product level: Each campaign is tracked for clicks, conversions, and interaction down to the most granular level of specific products and offers.”

All of this is combined with the online ad exchange system that sells us to advertisers as if we are cattle at an auction: “Advertisers using Dapper DisplayDR can buy media at the impression level in real-time and algorithmically through the ad exchanges. Dapper DisplayDR features the first real-time bidding engine optimized for dynamic advertising, bidding the right price for every impression based on the probability and value of conversion – at scale – as determined by individual purchase intent, product preference, price, time to purchase, geolocation, and more. As advertisements run, Dapper DisplayDR integrates business rules and performance cues to price each bid efficiently. Dapper also leverages performance lifts to bid higher for the most profitable audiences…”

Google Exec on Behavioral Targeting: “massive benefit for advertisers” [note he didn’t call it “Preference” Marketing!

Online industry reaction to the Wall Street Journal privacy series, and generally, illustrate a basic disconnect in how they view the privacy concerns raised by digital profiling, tracking and targeting.  Leading online marketers frequently claim that behavioral targeting and related data-focused techniques are actually good for the consumer.  The problem, they argue, is that consumers lack basic information about the process.  Presumably, they believe, if we really understood how it worked, we would be relieved.  In truth, of course, the opposite is true.  The more one knows about the processes underlying what the online ad industry claims is a digital marketing “ecosystem,” the more a consumer and citizen should be alarmed.

In the UK, EU and in the U.S., companies like Google and Microsoft are working together on PR campaigns to convince both the public and policymakers all is well with behavioral profiling for marketing.  One Google executive in the UK recently told New Media Age that “The use of behavioural targeting is growing and is a massive benefit for advertisers wishing to serve more relevant ads. It also helps pay for content and services. But there is user confusion about how it works…Lack of understanding is the biggest problem facing behavioural targeting in the UK. There’s a knowledge gap between those who work in the industry and are familiar with terms such as cookies, remarketing and aggregated data, and users who search the web for information and goods. It’s our job, along with the rest of industry, to inform those users about how online advertising works and the choices they have.” 

But in reality, the industry–including Google–has failed to be candid with consumers and policymakers about all the data collection practices that are deployedsuch as by Google subsidiaries Doubleclick, Admob, & Teracent, for example.

Microsoft is also very bullish about behavioral targeting–especially since it’s in a global digital fight with Google to deliver data-enriched ad targeting for the biggest brands.  In the same New Media Age issue [22 July 2010], Zuzanna Gierlinska, head of Microsoft Media Network at Microsoft Advertising explains that:  “We’re not saying you should use targeting – whether that’s behavioural targeting or re-messaging – just to push conversion.  But it can have a strong brand uplift. People come into a channel, see a nice creative with high-impact imagery and then go away. But that message stays with them.”  The article goes on to explain that: It’s this ability to talk to people on an ongoing basis, and give them a better experience, that’s the key to why combining re-messaging and behavioural targeting with a standard brand buy works, argues Gierlinska. For example, with re-messaging, users are already a warm lead, while behavioural targeting tightens the focus on users who are demonstrating an interest… This positive experience benefits both conversion and brand uplift among the target audience. “Targeting benefits everyone,” Gierlinska says. “It benefits the publisher because it’s not wasting impressions or serving ads to just anyone. It benefits the advertiser because it has efficiencies with its media buy. But it’s also really beneficial to the users because they’re getting relevant messaging that’s timely and ideally helping their productivity in what they’re doing online, rather than just being served random messages.”

Much of how the industry addresses the behavioral targeting and its related data mining application are rationalizations [maybe all their therapists are on vacation or Freudians!  Just kidding].  But it reflects a failure by industry leaders to recognize a serious problem that affects the public.  That’s the same kind of `it’s all good for us, regardless of what we do’ behavior that led to the recent–and ongoing–global financial collapse.