online privacy & targeting pov
DESCRIPTION
This document outlines kbs+p/The Media Kitchen's thoughts on the online privacy and targeting conversations.TRANSCRIPT
Privacy POV The Media Kitchen
October 2010 be brave | be inventive | defy expectations
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Who
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The Media Kitchen (“TMK”), a division of kirshenbaum bond senecal + partners, is a New York City based communications planning and buying agency. Over 100+ chefs in the Atlanta and New York “kitchens” plan and buy media on behalf of 19 clients including but not limited to Delta, Victoria Secret, PBS, Sesame Workshop, Bank of NY Mellon, and Windstream Communications.
TMK plans and buys across all channels including television, print, radio, OOH, and digital media (including social, display, search and mobile). We specialize in creating new media channels. We believe big ideas can live in any media channel and the biggest ideas live across all channels and are closely measured and monitored. We also believe that the very biggest ideas are born from collaboration.
We are active members of the Interactive Advertising Bureau (IAB).
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What, When, & Where
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Recent articles and congressional bills about Online Privacy have been published that have caused some of our clients to ask questions about the industry (and our very own) targeting/privacy practices.
We started to receive formal inquiries from our clients and the press right after the Wall Street Journal released their “What They Know” section on July 31, 2010.
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Why
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The digital advertising industry is self regulated. Many companies (including TMK) follow standards set by the Interactive Advertising Bureau (IAB) and Network Advertising Initiative (NAI).
Recent articles have called into question the targeting practices of evolving media platforms. The use of data (1st, 2nd, and 3rd party) for online targeting has been highlighted by the WSJ and the US Congress and weʼd like to respond to the recent press with how we use data to help our clients.
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Summation of Online Privacy Bill
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Two U.S. congressmen have proposed online privacy bills that confront disclosure notices, opt-in requests, and user information licenses. Rick Boucher, Chairman of the House Subcommittee on Communications, Technology and the Internet has been most vocal.
The new proposed legislation would require companies to get a userʼs explicit approval (that is, it would require users to “opt in”) before they “knowingly collect” information about a personʼs medical history, financial records, Social Security number, sexual orientation or precise geographic location. Other information, such as that collected by web cookies or session logs on corporate servers, would not require explicit consent, provided the company involved displays a “clearly-written, understandable privacy policy that explains how information about individuals is collected, used and disclosed” and provided users can decline or “opt out.”
Our position: the bill seems to codify accepted practice by reputable online companies however isnʼt likely to pass in the short term due to much debate and opposition.
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We Believe
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• Consumers want better targeted advertising. • Data is necessary to better target ads. • Better targeted ads improve conversion and
benefit business. • Increased message/placement relevancy, driven
by advanced data usage and capture, improves the overall consumer experience.
• Privacy has to be respected at all costs.
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We Know
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• The data we collect and use is non-PII.
• FTC definition of PII is very broad: The FTC believes that PII is data "that could reasonable be associated with a particular consumer or computer or other device, regardless of whether the data is 'personally identifiable' in the traditional sense.”
• We never, nor do we ever recommend to our clients to use PII data or store information in Flash cookies.
• All of our 1st, 2nd, 3rd party data conforms to strict privacy policies.
• Consumers have the option to opt-out, however that has not been easy and we are making recommendations to change that.
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Before the debate goes too far, some background:
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• The following slides contain some simple exhibits that outline much of what the privacy/targeting chatter is about:
- Exhibit A: Understanding Ad Serving - Exhibit B: Pixels, Containers, & Cookies - Exhibit C: Example Pixel [tag] - Exhibit D: Example Container - Exhibit E: Example Cookie - Exhibit F: Example 3rd Party Data Collection
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Understanding Ad Serving
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Start Here
Source: Eyeblaster Description of Methodology, July 2009
Extremely, extremely simplified
Exhibit A
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Pixels, Containers, & Cookies
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Exhibit B
Pixels are grouped in a container tag (.js or iFrame).
Container tag (UAT, Floodlight) is filled with tracking pixels by agency on-behalf of media partners. Could alsoinclude web analytics or audience measurement pixels.
Pixels “fire” when page is loaded and a “cookie” is dropped to the browserʼs computer in the form of a small text file that is mapped to a single domain.
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Example [Pixel] Tag: Quantcast/HuffPo
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Exhibit C
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Example Container: Demdex/VMM
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Exhibit D
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Example Cookie
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Exhibit E
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Example: 3rd Party Data Collection
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Exhibit F
• Jasmine is shopping online for air travel between New York to Hawaii. As she visits different online travel sites who partner with BlueKai, we [Bluekai] store an anonymous cookie on her browser.
• As a result, BlueKai marketing partners will show ads on Jasmine's computer that are relevant to in-market Hawaii travelers. (For a limited amount of time.)
• As a consumer, Jasmine has a choice to: Be informed and participate:
From the BlueKai Registry, Jasmine can always get visibility into what marketers are using to serve targeted ads and she can also participate by updating her preferences
Choose NOT to participate: At anytime, Jasmine can optout from having her preferences in the BlueKai Registry. While Jasmine will continue to see ads, she can rest assured that from that point on no more data will be collected or shared.
Taken from an excerpt on BlueKaiʼs website Tag is from Motortrend.com Source Code
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Two Types of “Tracking”
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Media Side Site Side
Measuring “merits” Reach/frequency De-duplication Audience segmentation
User flow & experience Optimizing site
At the end of the day, tracking is used to enhance the consumer experience.
Ex. Measurement Systems: Ex. 3rd Party Ad Servers:
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How We Target Audiences
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Instead of targeting one individual (PII)….
We target based on a set of data; creating custom Clusters (non PII)
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We then target audiences based on these clusters on behalf of our clients using 3rd party ad serving systems
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Best Practices: Google
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Ability to edit preferences for a more targeted user experience
Holy cow, thatʼs my cookie!
NAI compliance
Google allows the user to view & edit how they are categorized, opt-out, and even shows their cookie string.
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Best Practices: blueKai
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Ability to edit preferences for a more targeted user experience
Ability to select charity to donate a portion of your targeting dollars to…
bluekai allows users to view & edit how they are categorized and even allows users to pick a charity to donate targeting dollars to.
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Best Practices: NAI
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Ability to opt-out of receiving targeted advertisements by over 20 leading advertising networks & data providers
The NAI is the largest opt-out aggregator for companies using ad targeting.
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Evolving the Conversation
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Legalese Laymans Buried Upfront
Privacy Transparency
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Evolving the Conversation
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• Customers donʼt want to feel taken advantage of, yet we create situations of obfuscation
• The only way to build trust is to be fully transparent and inform customers what weʼre capturing and why weʼre doing it
• Full transparency around how data is collected, how its used and whatʼs being collected is paramount if our customers and prospects are to trust us.
Privacy Transparency
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Evolving the Conversation
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• Despite our good intentions and need to protect ourselves in the litigious society we compete in, our vocabulary only seems to alienate our customers.
• Since most people donʼt know legalese we have to use the vocabulary our customers easily understand. Anything less will create mistrust.
Legalese Laymans
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Evolving the Conversation
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• Weʼve been taught that the small type on a contract is where all the dangerous stuff lives yet we burry our policies at the bottom in small type.
• Lets bring our policies upfront and use a larger font.
Buried Upfront
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Making Consumers Feel Comfortable With Data Collection
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• Consumers need to understand the opportunities and implications of data collection and the advertising industry has to drive the transparency agenda.
• We need to continue to partner with leading privacy groups to show consumers why and how they are being targeted for advertisements.
• Weʼve developed a process called the Privacy Audit based on our beliefs and approaches to help clients better communicate their privacy policies clearly and overtly.
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The Privacy Audit
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• To help our clients determine if theyʼre privacy statements are helping them build trust with their customers and prospects weʼve developed our Privacy Audit, which is designed to answer:
- Is your privacy statement clear? - Does the statement explain what data is being
collected and how the data is used? - Is it prominently displayed? - Does it create a trust among customers? - What data is being collected and is it non-PII?
Barry Lowenthal President, The Media Kitchen (212) 337-4712 [email protected] Darren Herman Chief Digital Media Officer, The Media Kitchen (212) 337-4543 [email protected]
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