Category: Digital Banking

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.”

“Digital Body Language” & Online Financial Marketing–Can Be Hazardous to Your Privacy and Fiscal Health

For the last several years we have watched with dismay the largely stealth online data collection and targeting apparatus assembled for online financial marketing.  Everything from loans, credit cards, mortgages and insurance is increasingly sold online–an entire system has developed that stealthily `-e-rates’ us, including whether we are considered good prospects for various financial products.  Such “scores” become associated with us–without our knowledge.  Online lead generation is one field that helps financial online marketers and others identify whether we are the kind of person who should be pursued for a loan, for example.  One company explains that the:  “shift to online from face-to-face sales has crippled our ability to see body language when interacting with prospects leaving us less able to connect with prospects to determine their level of interest. The solution? Savvy marketers step in to read prospects’ “digital body language” and use that knowledge to guide the buying process. What web pages did prospects click on? What emails excited their interest? What breadcrumbs are they leaving that show their paths through the buying process?  Digital body language can arm sales people with deep insights into the areas and levels of interest of every prospect. Furthermore, digital body language allows marketers to determine which leads should be passed to sales at all.”

As the FTC and Congress–and we assume state regulators–work to ensure consumer protection in the digital marketing era, online financial services must be at the top of their agenda.

Multi-Billion $ Stakes for Online Consumers in How Congress Protects Their Privacy and Transactions

It’s time for policymakers to act and protect online consumers–who are at risk confronting a largely invisible, sophisticated, and far-reaching digital marketing system.  It’s useful to see how much was spent targeting U.S. consumers online.  This is from the IAB’s 2009 online advertising revenue report [my bold]:
Retail Advertisers Continue to Drive Consumer Ad Spending –2009 Annual Results
 Retail advertisers continue to represent the largest category of Internet ad spending, accounting for 20 percent of revenues for the full year of 2009 or $4.5 billion, down from the 22 percent ($5.0 billion) reported in 2008.
 Telecom companies accounted for 16 percent of 2009 full year revenues or $3.6 billion, up slightly from the 15 percent ($3.5 billion) reported in 2008
 Leisure Travel (airfare, hotels & resorts) accounted for 6% percent of 2009 revenues ($1.5 billion) compared to the 6 percent or $1.4 billion reported in 2008.
 Financial Services advertisers accounted for 12 percent of 2009 full year revenues or $2.8 billion, down from the 13percent ($3.0 billion) reported in 2008.
 Automotive advertisers accounted for 11 percent of 2009 full year revenues or $2.5 billion, down slightly from the 12 percent ($2.8billion) reported in 2008.
 Computing advertisers represented the fifth-largest category of spending at 10 percent of 2009 full year revenues or $2.3 billion, in line with the 10 percent reported ($2.4 billion) in 2008.
 Consumer Packaged Goods and Food Products represented 6 percent of the full year 2009 revenues ($1.4 billion), in line with the 6 percent or $1.5 billion reported in 2008.
 Entertainment accounted for 4% of 2009 full year revenues ($1.0 billion), up slightly from the 4% ($917million) reported in 2008.
 Media accounted for 4 percent of 2009 full year revenues or $881 million, up slightly from the 3 percent ($764 million) reported in 2008.

[and to underscore its importance, note the definition of financial services online marketing used by the IAB:  Financial Services—includes commercial banks, credit agencies, personal credit institutions, consumer finance companies, loan companies, business credit institutions and credit card agencies. Also includes companies engaged in the underwriting, purchase, sale or brokerage of securities and other financial contracts. 

As well as the $1.5 billion spent last year on:  Lead Generation—fees advertisers pay to Internet advertising companies that refer qualified purchase inquiries (e.g., auto dealers which pay a fee in exchange for receiving a qualified purchase inquiry online) or provide consumer information (demographic, contact, behavioral) where the consumer opts into being contacted by a marketer (email, postal, telephone, fax). These processes are priced on a performance basis (e.g., cost-per-action, -lead or -inquiry), and can include user applications (e.g., for a credit card), surveys, contests (e.g., sweepstakes) or registrations. 

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 Taps Academics to Help its Lobbying in DC

Microsoft “launched an online forum January 6 for the academic community to participate in a dialogue about policy issues relating to the technology industry,” according to PR Week.  The so-called “Technology Academic Policy” [TAP] group “is aimed at journalists, Capitol Hill staffers, think tanks, and other decision makers,” explained Kathryn Neal, academic relations director for Microsoft. Academic institutions that are participating include UC Berkeley, Harvard University, Northwestern University, and Stanford Law School.  Microsoft, which hired Adfero Group in summer 2009 to support the program, also created a presence for TAP on Twitter, YouTube, LinkedIn, Digg, and Facebook. Academic participants can engage in each medium, including posting videos to YouTube, noted Neal.” Adfero Group says that it helps clients “persuade the powerful.”

Microsoft is playing a game of academic catch-up to Google, which funds scholars and research to help advance it’s own interests.  But there should be real independence between the academy and powerful special interests.  One will have to examine closely Microsoft’s relationship with the following academic institutions aligned with the new TAP program:

“TAP Centers – The following institutions currently contribute to TAP:

  • The Berkeley Center for Law & Technology at UC Berkeley
  • The Berkman Center for Internet & Society at Harvard University
  • The George Washington University Law School
  • The John M. Olin Program in Law and Economics at the University of Chicago Law School
  • The Program in the Law & Economics of Intellectual Property and Antitrust at Stanford Law School
  • The Searle Center on Law, Regulation, and Economic Growth at Northwestern University
  • Silicon Flatirons — A Center for Law, Technology, and Entrepreneurship at the University of Colorado
  • The Stanford Institute for Economic Policy Research (SIEPR)
  • The Toulouse Network for Information Technology, hosted by the Institut d’Economie Industrielle at Toulouse University
  • The Center for Technology, Innovation & Competition at The University of Pennsylvania Law School (CTIC)”

Google Funds Privacy Research for several leading academics & advances its mobile data collection work

We believe academics should pursue research that is independent–and not funded by vested interests.  Here are some of the academics that just received “Google Focused Research Awards.“  The check also comes with a further relationship with Google [“These unrestricted grants are for two to three years, and the recipients will have the advantage of access to Google tools, technologies, and expertise.]

Privacy:
Ed Felten, Princeton
Lorrie Cranor, Alessandro Acquisti and Norman Sadeh, Carnegie Mellon University
Ryan Calo, Stanford CIS
Andy Hopper, Cambridge University Computing Laboratory
and: Use of mobile phones as data collection devices for public health and environment monitoring: Gaetano Borriello, University of Washington and Deborah Estrin, UCLA

Where Does Google and Microsoft Really Stand–with the IAB and ad lobby or for Consumer Protection?

Both Google and Microsoft serve on the executive committee of the Interactive Ad Bureau, a trade association fighting against consumer privacy proposals in Congress and the FTC.  The IAB just sent a letter signed by other ad and marketing industry lobbyists opposing Obama and congressional proposals to expand the ability of the FTC to better protect consumers.  My CDD just sent emails to officials at both Google and Microsoft asking them to clarify where they stand on the IAB’s letter [see below].  Do our two leading online marketing leaders support financial and regulatory reform, including protecting privacy?  Or does the IAB letter–and Google and Microsoft’s own role helping govern that trade lobby group–really reflect their own position against better consumer protection? Not coincidently, the IAB’s PAC has expanded its PAC contribution giving to congress.

Why does the IAB and other ad groups want to scuttle a more capable FTC?  Think online financial products, including mortgages, pharmaceutical operated social networks, digital ads targeting teens fueling the youth obesity crisis, ads created by brain research to influence our subconscious minds, a mobile marketing system that targets us because it knows our location, interests and behavior.  The IAB is terrified that a responsible consumer protection agency will not only peek under the ‘digital hood,’ as the Obama FTC is currently doing.  But actually propose policies and bring cases that rein in irresponsible and harmful business practices.  So Microsoft and Google:  who are with?  Consumers or the special interest advertising lobby?
*****

letter to Google:  22 January 2010

Dear Pablo, Jane, Peter and Alan:

As you may know, the Interactive Advertising Bureau recently sent a letter  to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Google serves on the executive committee of the IAB’s board.  For the record, does Google support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Google disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Google state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

letter to Microsoft:  22 Jan. 2010:

Dear Mike and Frank:

As you may know, the Interactive Advertising Bureau recently sent a letter to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Microsoft serves on the executive committee of the IAB’s board.  For the record, does Microsoft support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Microsoft disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Microsoft state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

Facebook Teams with JP Morgan Chase in Campaign Targeting Charities. But what about the bank’s role in the financial scandal?

As we have reported, banks and other financial institutions are using digital marketing techniques, especially social media, as part of their PR efforts.  Banks want to reposition themselves as our friend, and hope we will forget their role in helping bring us the greatest financial disaster since the Great Depression.  In it’s current voting contest for charities, “Chase Community Giving” will award $1 million to the charity getting the most votes (with $4 million doled out to others).  One of the advisors for this effort is Facebook’s exec in charge of its PR and lobbying Elliot Schrage.

Nothing said, of course, of Chase’s role in the economic crisis, including the bail-out funds it received [click here to see the Facebook/Chase video]. Meanwhile, Chase gets Facebook’s help, likely including lots of data on user behavior.