Category: Mobile Privacy Watch

Google’s Eric Schmidt on Mobile Marketing [Annals of Why We Need Mobile Privacy and Consumer Protection Safeguards]

Google CEO Eric Schmidt gave the keynote address at the Interactive Advertising Bureau’s “Ecosystem 2.0” conference.  As reported, he explained that [our emphasis]:

“The smartphone is the iconic device of our time,” Schmidt told the record IAB audience of 750 in Palm Springs, California. A year ago, he added, he predicted that mobile use would surpass PCs within two years. “It happened two weeks ago. And the PC is not going to catch up,” Schmidt said, as he labeled the new era, “Mobile First.”…The hyperlocal potential of mobile, Schmidt continued, means that smartphones and tablets bring a practical application to marketing that no other medium can match: A connection that will lead you to the store, open the door, and direct you to a product you need. “A RadioShack ad can tell you where you are and how to get to the nearest store.” And equipped with Near Field Communication chip (NFC), the newest generation of smartphones not only can tell you what to buy, it can enable a tap-and-pay transaction…Think of the offers mechanisms for advertisers,” Schmidt offered. “We’ve spent 20 years trying to get here. And now there’s an explosion in commerce. Particularly for the consumer who says, “I want to buy something and want to buy it right now,” he added, “We can do it.”

And, in large part, that capability means that mobile media consumption “is happening faster than all our internal predictions.”

Some 78% of smartphone internet users already use their smartphones as they shop. And, as consumer comfort with – and acceptance of – new mobile technology continues, Schmidt envisions “a world, in the very near future, where computers remember things and you never need to worry about forgetting anything. You want it to remember something and it will. And you’re never lost. No one is ever lost. You never turn off the [mobile device] and you’ll always know where you are. And where you want to go….”

The new Self-Reg Online Ad Plan–Digital “Deja-vu” All Over Again! See What they Say about the NAI Now!

In 1999, online marketers promised consumers they would protect their privacy.  Leading interactive ad companies created the Network Advertising Initiative (NAI) as a scheme to head-off proposals by the FTC that would help regulate online profiling.  Now it turns out, says the online ad industry, the NAI really couldn’t work.  So they have developed yet another self-regulatory effort.  Here’s what online marketers told Ad Week today:  “The move marks the most significant regulation the industry has imposed on companies and goes significantly farther than the Network Advertising Initiative, which held third-party advertisers needed to allow consumers to opt out. Doing so, however, was a cumbersome process.“   So the industry didn’t tell the FTC or consumers that the NAI wasn’t consumer friendly and “cumbersome.”  Yet they have used the NAI as a political bulwark to head-off consumer protection rules.  Shame on them.  Meanwhile, in the same story, it’s revealed that only now–as pressure mounts to protect online consumers—does the industry recognize protecting privacy is important:  “The guys that drive the industry have figured out this privacy stuff does matter,” said Scott Meyer, CEO of Better Advertising Project, which will help companies comply with the requirements.

The new “aboutads.info” website established by the industry fails to provide consumers serious information about cookies and behavioral targeting and profiling.  It reveals how little the industry is committed to protecting privacy and informing U.S. consumers about the process.  To see how this new plan is really designed to protect the data collection business, examine the rules for sensitive information. Beyond the children’s privacy law (COPPA) we got enacted in 1998, this scheme permits full-scale collection and use of financial and health information.   Under the “new” self-reg policies, the narrowest of definitions for respecting your financial and health information has been created:  “Entities should not collect and use financial account numbers, Social Security numbers, pharmaceutical prescriptions or medical records about a specific individual for OBA without Consent.”
Shame on them.  Online marketers spent some $3 billion last year on online financial marketing and will spend $1 billion for pharma and health related targeting in 2010. Consumer data collected by online financial and health marketers, much of which is sensitive and personal, is ok under the industry’s “new” plan.

PS:  The folks at Better Advertising need to take a course in online marketing–and change its new website so it really informs consumers about the process.  What it has now would get a C-minus in any class on online marketing.  They can start with 360 degree targeting, online and offline profiling, rich media, a serious description of online auctions, the tracking process, work on “engagement” and neuromarketing,” social media marketing, etc.  Consumers deserve better.

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 & 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”

“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 and Location Marketing: Plans to `Send in the Crowds’ from Advertisers

You have to read between the lines to understand what Facebook’s new location feature is really designed to do:  Open you and your friends to be more closely tracked by Facebook and its marketing partners, including major advertisers [Fans are worth money to Facebook and their marketing partners].   On Facebook’s blog post on the new location service [which is written in typical Silicon Valley PRspeak suggesting they are doing this only to bring pleasure into your life], the key telling phrase is: “You may want to share your check-in information with third-party applications that build interesting experiences around location, such as travel planning. Applications you use must receive your permission before getting this information. Your friends will be able to share your check-ins with the applications they use to help create new social experiences with location.”

That really means Facebook already has plans to use location data to expand its marketing business (inc. from thrid part apps), which is expected to help the social network bring in $1 billion this year.  Mobile and location applications require greater safeguards for privacy, as my CDD and USPIRG petitioned the FTC to do last year [as a result the FTC has opened up a “mobile lab” examining data collection and mobile marketing practices]. Companies such as Facebook. Google, Foursquare, and others are keenly aware of the huge ad revenue opportunity from location marketing.  One Google backed location social game start-up [SCVNVR] calls this potential the “social coefficient.”  As Mobile Marketer reported, the “Social Coefficient is a score determined by the number of social interactions at a specific location…The more friends at one place or the more users participating in the challenges over time, the higher the Social Coefficient score for that particular location.”  Facebook and others understand that advertisers are willing to pay more if they can encourage friends to market to other friends. 

McDonald’s is already in discussion with Facebook to use this new service.

Google’s Mobile Ad Plans–A Key Reason Why No Net Neutrality for Wireless [Follow the Mobile Ad $$$]

Just a quick reminder to network neutrality supporters that Google has made a multi-billion dollar investment in its ability to deliver mobile ads.  That’s a key reason for its “let’s make a digital deal” with Verizon.  For example, in 2007 Google acquired  Doubleclick:“DoubleClick Mobile is an ad delivery system for mobile websites that delivers dynamic, interactive ads to mobile web pages based on specific criteria as determined by you. It supports a wide range of devices and boasts a full management and reporting suite. Now publishers can deploy mobile advertising with the same confidence and control as online display ads…DoubleClick Mobile enables you to manage and report on your mobile advertising campaign through every click. We’ve made it easy to set campaign dates, define mobile specific targeting criteria and get full reports on all mobile campaigns…records information on third-party destination sites…DoubleClick Mobile features support for a variety of ad networks to enable you to sell more of your inventory and maximize possible yield…”

This year Google acquired Admob:  “AdMob offers brand advertisers the ability to reach the addressable mobile audiences. Our innovative ad units will carry your brand messaging onto the top mobile sites. As one of the leading brand mobile advertising marketplaces, we have the products and the people to help you meet your campaign needs…Mobile advertising provides you with targeted access to mobile users, and is easy to buy and measure…AdMob stores and analyzes data from each ad request to serve the most relevant ad possible. AdMob Mobile Metrics offers a snapshot of this data to provide insight into trends in the mobile ecosystem.”

And don’t forget Google Adsense for mobile:  “AdSense for Mobile helps you earn money by displaying relevant Google ads alongside your mobile web pages or within your mobile applications.”  Or YouTube Mobile.

PS:  eMarketer got it right.  The Google/Verizon deal is about preserving mobile as a controlled digital territory: “By 2014, eMarketer expects the number of mobile internet users in the US to reach 142 million, a near tripling of 2008 levels. The total pool of internet users, which includes mobile and wired access, will increase over the same time period from 203 million to 250 million. By 2013, more than half of all US internet users will be accessing the web through a mobile network, either alone or in addition to wired usage.”

Online Ad Lobby and Chamber Celebrate Victory over Consumer Protection & FTC

Yesterday, the online ad lobby [IAB, ANA, DMA]–working with Chamber of Commerce–scored a major political victory by forcing the Financial reform bill conference committee to drop proposed provisions that would have strengthened the FTC.  Under the House bill, the FTC would have been given the same kind of regulatory authority most federal agencies have [APA rulemaking].  Marketers and advertisers are celebrating their win, because it keeps the FTC on a weakened and short political leash.  While consumer protection is significantly expanded because of the CFPB and new financial rules, the FTC is to remain largely hamstrung.  The online marketing and advertising lobby [including ANA, DMA–see below] were afraid that the newly invigorated FTC under Pres. Obama would require the industry to protect privacy online and also become more accountable to consumers engaged in e-commerce.   I heard IAB and Chamber are dancing in the streets! Congressmen Barney Frank, Henry Waxman and Sen. Rockefeller deserve praise for working hard to protect consumers, including their proposal on the FTC.

Here’s what two of the ad groups placed on their sites about the FTC issue:

Progress on FTC Enforcement Provisions in Wall Street Reform Conference

June 23, 2010

The marketing and media community has made substantial progress on defeating the broad expansion of FTC powers that is included in the House version of the Wall Street reform bill.  But we still need your assistance to keep these provisions out of the final bill.

Yesterday the Senate conferees presented an offer on the bill that rejected the new FTC powers that are in the House version.  Chairman Dodd indicated that while he may support changes in the Magnuson Moss rulemaking process, there is no Senate provision and these issues are too complex and important to be resolved in the context of the Wall Street reform bill.  Conferees hope to finish the conference this week so the final bill can be cleared for the President’s signature next month.

The House conferees may still continue to push for these provisions, so it is very important that marketers contact the Senate conferees to express our appreciation for their support and to urge them to remain strongly opposed to these new powers for the FTC in this bill.  Contact information for the Senate conferees is located here and our letter to Senate conferees is available here.  Please let the Senators know if you have plants or operations in their states.

ANA took part in a very important meeting yesterday with Senate Commerce Committee Chairman Jay Rockefeller on these issues.  We argued that these issues are very important to the entire marketing community and deserve careful consideration outside of the context of the Wall Street reform bill.  The Chairman strongly indicated that he will continue to push for changes in the Magnuson Moss rulemaking procedures this year.

If you have any questions about this matter, please contact Dan Jaffe (djaffe@ana.net) or Keith Scarborough (kscarborough@ana.net) in ANA’s Washington, DC office at (202) 296-1883.

http://www.ana.net/advocacy/content/2418

DMA Asks Financial Reform Conferees to Keep FTC Expansion Out of ‘Restoring American Financial Stability Act’

June 10, 2010 — The Direct Marketing Association (DMA) today was joined by 47 other trade associations and business coalitions in sending a letter to each of the conferees on H.R. 4173, the “Restoring American Financial Stability Act” (RAFSA), urging them to keep language that would dramatically expand the powers of the Federal Trade Commission (FTC) out of the final bill.

As the House and Senate conferees work to reconcile their versions of the financial regulatory legislation, the associations — which represent hundreds of thousands of US companies from a wide array of industry segments — expressed strong opposition to provisions in the House version of the bill that would expand the FTC’s rulemaking and enforcement authority over virtually every sector of the American economy.

“The balance struck in the Senate bill is the right one,” said Linda Woolley, DMA’s executive vice president, government affairs.  “That bill makes the most sense in the context of financial reform legislation, maintaining the FTC’s existing jurisdiction without expanding its rulemaking and enforcement authority over industries and sectors that had nothing to do with the financial crisis.  Issues of FTC expansion deserve their own due consideration and debate in the more appropriate context of an FTC reauthorization, as has been done in the past.”

DMA and the other associations strongly believe that granting the FTC broad new authority is not a necessary or relevant response to the causes of the recent recession and, therefore, asked the conferees to oppose the inclusion of any provisions that would expand FTC authority, rather than making changes to the Commission that would have a fundamental impact on the entire business community and the broader American economy.

For more information please visit www.dmaaction.org.
http://www.the-dma.org/cgi/dispannouncements?article=1449

Microsoft to Advertisers: “Behavioural targeting is transforming the capabilities of online advertising”

In a recent post, Microsoft extolled the virtues of using its behavioral targeting service profiling mobile phone users.  It explained that “campaigns can target individuals based on their online behaviour, including the sites that they visit, the actions they take and the terms they enter into search engines. In the US behavioural targeting on mobiles has already delivered increases in click-through rate of 215% for the fashion and beauty sector, 97% for airlines and 76% for auto advertisers.”