Rocket Science for Digital Advertising

Our concern for Privacy

Dominic Trigg

Outline Building on the Information of my distinguished colleagues

Rocket Fuel and why privacy is important

Privacy Landscape of Behavioral Networks – Rocket Fuel’s Perspective

UK Cookie Law

International Privacy Insights

Our Approach to this

Rocket Fuel, Inc.Rocket Science for digital advertising

» Founded: 2008» People: 167 » Offices: 11» Data centers: 5 (US, Europe, Asia)» Customers: 709» Campaigns: 1,849» Revenues: $44.5M in 2011» Growth: > 2.7x revenue growth every year

Technology company driving outstanding results for digital marketers

97%

83%

92%

64%33%

54%

Exchanges now allow reach of billions of consumersSo Privacy has become a worldwide issue for us

We buy audience via a huge numbers of networks and sites So Privacy concern translates into a Europe wide issue for us

AdExchange

Global Exchange Partner Sample

Market Example Data Provider

United Kingdom

Germany

The Netherlands

France

Data providers come in all shapes and sizes in Europe Using Data Providers that are trustworthy is absolute necessity

Privacy Landscape of Behavioural NetworksRocket Fuel’s Perspective

Clearly, Privacy Now Has AttentionSpectacular Missteps have raised sensitivity

Behavioural Networks are right in the middle of itTherefore, we believe

Consumers want better targeted advertising

Data is necessary to better target ads

Better targeted ads improve conversion and benefit businesses

Increased message relevancy, driven by advanced data usage and capture, improves the overall consumer experience.

Consumer privacy is important and has to be respected but content needs to be paid for.

Transparency is essential

Privacy PrinciplesBuilding blocks to identify actionable strategies

Education Transparency Consumer Control

Data Security Material Changes Sensitive Data

Accountability

Offering Consumers a ChoiceEducation

Educate consumers and businesses about OBA and Privacy

Explain user data collection and describe how consumer choice and control may be exercised

Offer consumers a simple way to control what information is shared

Informing Consumers about what happens and give them controlTransparency and Consumer Control

Enhanced notice link Companies should give clear, meaningful and prominent notice on their data collection,

sharing, and use practices

First and third party responsibilitiesConsumers choice whether their data is collected, used and transferred Ability given to users on website or within ad unit

Most importantly are Trust in proper Stewardship of DataData Security

Implement reasonable safeguards to protect data that is collectedRetain data only as long as necessary to fulfill a legitimate business need“Anonymise” any personally identifiable information

Rocket Fuel’s data retention policy

keeps consumer data for 30 months

Other Important but less defined PrinciplesMaterial Changes, Sensitive Data and Accountability

Material Changes Opt-In for Sensitive Data

Accountability

• Recognize that privacy concerns are real and create new responsibilities for every digital player’s handling of data

• Children, especially young children

• Collection of financial account information, prescriptions, or medical records

• Develop and implement policies and programs to adhere to the principles

• Involves systematic or random monitoring of programs for compliance

UK Cookie Law

Protecting Consumer Rights - UK

UK Interpretation

Cookie DirectiveBreaking down the UK Cookie Law

»Deadline: May 2012»Disclose collection and use of data»Opt out option for behavioral advertising.»ICO made suggestions for third party cookie providers

Make efforts to take Confusion Out Of Cookie DirectiveWhat is Rocket Fuel doing?

» We now serve every behaviorally targeted ad with the Ad Choices icon

International Privacy Insights

A European DAA

• The “Your Choices” Program• Provides transparency about OBA data collection

and usage across the EU organized by the IAB UK.• It is based on a framework published by European

Advertising Standard Associations (EASE) and supported by the European IAB. • Implemented in 22 European countries, including

Western Europe & The Baltics • Rocket Fuel is a registered member of the Your

Choices program and is compliant with data transparency and collection rules

European Union Privacy Directive Background

European Union E-Privacy Directive 2002/58/EC • Passed July 2002, amended December 2009• Requires user consent to be obtained for information stored or

accessed on user’s terminal equipment• Prior to obtaining consent, users must be provided with clear

information about the purpose of the storage or access• Member states initially given implementation deadline of May 2011• European Commission recently updated implementation deadline to

June 2012

EU Privacy Directive Requirements• Requires user consent, suggests users must Opt In to cookie storage• Applies directly to first parties (publishers), suggests some responsibility

for third parties• Doesn’t apply to “strictly necessary'” cookies ( Ecommerce , enhanced

experience)

EU Member States That Have Acted

Member State

Legislative Status

Details Opt In / Opt Out

Implementation Options

Enforcement

UK Cookie Law passed 5/25/2011, parties have 1 year to comply

1st/3rd party cookie provider must prove user consent

Opt In • Site Notification• Site Header/Pop-

Up

Enforcement Begins 5/26/2012

Germany Legislation drafted but is farthest from implementation

Explicit consent required, implementation requirements being debated

Opt In • Site Notification• Site Header/Pop-

Up

Unknown

Netherlands Upper house of Dutch Senate yet to ratify

1st/3rd party cookie provider must prove user consent

Opt In • Site Notification• Site Header/Pop-

Up

7/1/2012 if ratified

Denmark Awaiting implementation of draft bills

Consent via browser settings

Opt In • No Action Taken Unknown

Finland Finnish parliament implemented in 2011

Consent via browser settings

Opt In • No Action Taken N/A

Rocket Fuel’s Approach

We are careful and conscious of how we transfer data across bordersWe ensure that direct publishers and exchanges we obtain inventory from are 100% compliantWe provide all users with a second opportunity to opt out when third party cookies are being servedWe work with the third party OBA vendor Evidon to ensure OBA icon is serving correctly, in line with all regulationsWe maintain the ability to work with any third party ePrivacy vendor that any client requires

Conservative and Responsible on Behalf of Our AdvertisersRocket Fuel applies the following to every campaign

Interpretations of Business ConsequencesRocket Fuel’s estimate of impact based on strategy chosen

The E-Privacy Directive is ambiguous on how and when user consent is to be collected. Possible interpretations include:

Option Opt In/Opt Out? Technology Cookie Loss

No Action Taken Opt Out Web Browser 0%

Ad/Your Choices Notification

Opt Out NAI/DAA/Evidon/Rocket Fuel

2%

Website Notification

Opt Out Site Message 10%

Site Header/Pop-Up

Opt In Accordion Header/Pop-Up

50%