program areas Digital Consumer

The FTC requested that comments for the upcoming October 30, 2015 workshop on lead generation be submitted by September 20th so that issues could be addressed during the sessions. USPIRG and CDD submitted initial comments, which are attached below and also summarized. One of our findings from a recent analysis of the online "lead gen" marketplace was that digital industry leaders--including Google and Facebook--engage and support online lead generation in ways that raise substantive consumer protection concerns. USPIRG and CDD have been working for the last several years to encourage policymakers to rein-in lead generatio activities, especially those that play a role promoting financial products that can be expensive and harmful to consumers. We have written background papers on lead generation and payday loans, its use by for-profit colleges, and how Hispanics are targeted, for example. At its workshop, follow-up report and thru new enforcement activities, the FTC needs to analyze and address how contemporary online lead generation embodies a panoply of applications and tactics to acquire, use, and often share or sell a person’s personal data. Lead generation is no longer the simple process of encouraging a consumer to fill out an online form. Today, online “lead gen,” as it is called, incorporates the use of YouTube, Facebook, Twitter, search engines, mobile phones, apps, geo-location, native advertising, email, sentiment mining, data-driven audience buying (programmatic), user “scoring” methods, attribution analysis for measurement, and a network of data brokers providing instantaneous identity and other sensitive information. The commission, in its workshop, report, and follow-up activity, should focus on the leaders of the digital data marketing industry—starting with Facebook and Google but including many others—and its use of lead generation. While there are likely many “bad” lead generator actors, as the commission’s enforcement actions have already identified, we believe that the most significant threats to consumers overall arise from the growing and now endemic use of powerful, non-transparent lead-generation techniques, especially for financial products, by the leading companies in the marketplace. Unless it is subjected to some floor of enforceable consumer protection—including but not limited to transparency and real consumer choices to avoid it—lead generation will become—if it has not already—a patently unfair system of consumer manipulation and control. Few consumers know that when they are encouraged to provide data about themselves—when they seek a home, college or auto loan, for example—that the supposedly informational website promising attractive rates and up-to-date information is really in the business on capturing their personal information to be used or sold as a lead. Online lead-generation techniques are integrated into the digital medium, with many interconnected applications fostering ongoing data collection for lead-related profiling and targeted services (e.g., search, social media, financial digital marketing). The commission should note that the leading business segments for online marketing revenues and expenditures—retail, financial services, and the automotive sectors—significantly use online lead-generation tactics. So do the leaders in the digital media business—including Google, Facebook, and Twitter, for example. The commission, in its workshop, report and follow-up activity, should focus on the leaders of the digital data marketing industry and their use of lead generation

The Internet as a whole has become an important part of our global public sphere. Internet provides access to a wealth of information and knowledge, and the possibility to participate, create and communicate. This public space made up of internet infrastructures is increasingly threatened from two sides; by the centralization and commercialization through the dominant positions held by giant telecom and Internet companies, as well as by an increasing trend in state regulation and censorship of the net. This poses important questions about how we choose to organize and regulate our digital societies, and how Internet governance models can be developed and implemented to ensure fair and democratic participation. When it comes to the future of the Internet, a key discussion is one of infrastructures; who owns, runs and controls them. The question of regulation, and who oversees the regulators, is made complicated by the transnational nature of the net. As much as people expect a broadly and equitably accessible Internet open to diversity, we are, slowly but surely, moving away from it. Monopolization of Internet infrastructures and services by companies such as Facebook and Google has gone hand in hand with privacy intrusions, surveillance and the unbounded use of personal data for commercial gain. As we all interact in these centralized commercial platforms that monetize our actions we see an effective enclosure and manipulation of our public spaces. Decentralization and democratization of the Internet infrastructure and activities is essential to keep a free, open and democratic Internet for all to enjoy equitably. But can the “small is beautiful”-idea be compatible with the building of state-of-the-art successful infrastructure in the future? The debates around net neutrality, infrastructure neutrality and Internet monopolies reflect the important choices that are to be made. It is essential the EU formulates a comprehensive vision on the internet that addresses the protection of civil liberties such as free speech and privacy, but also the growing commercialization of our digital public spaces and the commodification of personal data with the effect of the market encroaching on all aspects of our daily lives. Only then can it make relevant interventions regarding the Internet and its governance. Let´s discuss how to re-decentralize and reclaim the Internet for all. This conference (link is external) is organised in cooperation with Commons Network and Heinrich Böll Foundation. DRAFT PROGRAMME (TBC) 15:00-15:30 Introduction 15:30-16:45 1st panel, The big picture What, if anything, in the current model of Internet Governance is clashing with a decentralized, resilient internet viewed as a common good? And what steps should be made by policymakers to foster the best environment for decentralized, community managed projects to grow? Confirmed speakers: Renata Avila, Aral Balkan 16:45-17:00 Coffee break 17:00–18:15 Decentralised infrastructure: Examples what examples of local and decentralized projects do we have today and what are the obstacles they face? Confirmed speakers: Edmon Chung, Robbert Mica, Olivier Schulbaum 18:15–18:30 Conclusions and final remarks This conference will be live streamed at: http://greenmediabox.eu/en/live/ (link is external) http://greenmediabox.eu/en/live/>* (link is external) Background & Programme: http://www.greens-efa.eu/internet-as-a-commons-13850.html (link is external) Joint the event community on Facebook: https://www.facebook.com/events/939398269451418/ (link is external) https://www.facebook.com/events/939398269451418/> (link is external) Registration: http://www.greens-efa.eu/events/registrations/658-internet-as-a-commons.... (link is external)

Chango lets you target and retarget users wherever they spend their time on-the-go. Our intent data — to find users on desktop and reach them on mobile. Our Approach Our cross-device solutions can be used in a variety of ways, depending on your set of goals. Highlighted below is our approach to these different cross-device solutions. Scenario 1, Facebook: Retarget customers on Facebook mobile based on their previous behavior on desktop. Change’s cross-device Facebook solution is a combination of Chango’s intent data and Facebook’s cross-device data. This allows you to reach your target audience on their desktop and mobile devices as part of the same campaign. Chango identifies the target audience for the campaign. Chango messages the target audience on desktop. Change re-messages the same target audience. For the full article, visit http://bit.ly/1I5Yv9d (link is external)

What’s up with The New York Times Co. and programmatic? We’ve pondered that question before (link is external), but the publishing giant declined to speak at the time. Since then, Times SVP of Ad Products and R&D Michael Zimbalist has revealed to AdExchanger that the company intends to release more inventory cautiously into the RTB space. It also is planning an expansion of non-RTB programmatic initiatives. One such area the Times is considering is developing an audience extension buy. Much has changed at the Times in recent months. “We had a change of leadership in our sales department,” Zimbalist said. “Meredith Levien came in to head sales after a long search, and we’ve reorganized the whole department. In doing that, I stepped in and took on, in addition to my role as head of R&D, a new role in the company, which is head of ad products. We never had a formal head of ad products function before.” As part of this restructuring, the Times has consolidated a number of functions: ad ops, ad systems, product management, some of its custom development work and, of course, programmatic. Zimbalist spoke with AdExchanger on the changes. AdExchanger: What elements of programmatic has The New York Times embraced, and what elements has it decided to forego? Michael Zimbalist: There’s no area of programmatic we’re philosophically opposed to going forward with. Programmatic is now part of an overall practice. We’ve recast our thinking around programmatic as part of a total yield-management practice, which is part of ad products. So it reframed our view in the marketplace to incorporate total yield both in our direct-sold and in our overall market. That’s the setting. At the present time, we’re leaning into programmatic through our partnership with Google and Google AdX. Full interview available at http://bit.ly/1gmbzhQ (link is external)

The digital video world will converge on Anaheim, Calif., this week for the sixth annual VidCon, a three-day extravaganza that's grown from 1,400 YouTubers and their rabid fans, to 20,000 strong, with top-tier creators from Vine, Vimeo, Tumblr and Meerkat, just to name a few. Some of the biggest brands on the planet will also be in attendance. It's no wonder. While about 90 percent of video viewing is still on TV, according to Nielsen, 18- to 34-year-olds—a demographic coveted by advertisers—are increasingly cutting the cord. "It takes a very different media mix today to reach that audience than it did 10 years ago," explained Jenny Schauer, media director at Digitas. She believes YouTube, and increasingly Facebook, are uniquely positioned to reap the rewards of brand videos. "Taking content from a brand and putting it right in front of consumers in the News Feed, that's where Facebook is really strong." Meanwhile, at VidCon, YouTube will take its own well-deserved victory lap. An exhaustive study released today by video marketing firm Pixability digs into viewability, reach and growth of the top 100 global brands as determined by Interbrand (see above chart for the top five brands on YouTube and the top 100 global brands online (link is external)). The veritable treasure trove of data is a marketer's dream: YouTube's channels count 73 million subscribers, with subscribership up 47 percent year over year. Full article available at http://bit.ly/1TLmI9U (link is external)

July 20, 2015 — Over the last several years, publishers and advertisers have continued to adopt programmatic buying and selling of digital inventory into their media strategies; however, within the complex programmatic ecosystem there has been a lack of consensus around the definition of programmatic and its associated types and formats and the size of the programmatic market in comparison with the overall internet advertising market. This study, commissioned by the IAB, seeks to estimate revenue associated with programmatic selling and buying of advertising and establish a benchmark for measuring the growth of programmatic. Read the full report, attached.

Call it something dry like "data on-boarding" or something marketable like "connectivity." Whatever it's called, Acxiom-owned LiveRamp (link is external) is doing a lot more of it than a year ago. The company currently "on-boards" or connects 20 billion consumer records representing individuals or households each month, or around 240 billion per year. That's a big leap from the 3 billion customer records it brought to the web in March 2014, up from 1.3 billion in March 2013. Those records contain consumer data generated offline, such as information from auto leads, retail transactions or banking relationships. The digitized data is used by companies who want to communicate with their current customers via email or targeted digital ads, optimize website pages or measure the impact of digital ad campaigns on offline sales. More than 200 marketing-technology platforms are integrated with the LiveRamp system -- part of Acxiom's newly-named Connectivity division -- meaning the data can be plugged into all sorts of ad targeting, email marketing, site optimization and campaign analysis tools. Acxiom reported that Connectivity revenue rose 367% to $22 million in fiscal Q4 2015. The growth is a result of more awareness of data onboarding, said James Arra, VP-strategic partnerships for LiveRamp. But it's also the May 2014 Acxiom acquisition (link is external) that has facilitated business with clients that may have been out of reach when LiveRamp was still an indie, such as highly regulated financial services firms. Full article available at http://bit.ly/1SpFtgN (link is external)

Real-time Bidding (RTB), a key component of the programmatic advertising revolution, represents a massive platform change in the way we advertise online by bringing the relevance and efficiency of search to display. RTB spend will reach 429 million GBP this year (eMarketer) as budget moves away from more traditional channels. If advertisers consider RTB for display there are a couple of tips to help get it right: Advertise to the individual not the ‘segment’ Every customer is slightly different from the next. With this in mind the traditional marketing method of grouping customers into ‘buckets’ does not always make sense. For example, consumers within the “mums” segment will be vastly different. A mother with a newborn will have hugely different needs to one who is just about to send their eldest off to university. Everyone has unique demographic traits – income levels, hobbies, family statuses, interests, etc. Grouping customers into segments relies, partly, on human perception, but driving performance is not always intuitive in the same way. RTB means targeting at the impression level as opposed to traditional media buys of large chunks of inventory. Therefore, there is a unique opportunity to target individuals – segments of one. Machine learning and the application of algorithms make this possible. In the past guesswork decided the majority of ad buys and creative execution, now, through machine learning, we can use computers to impact specific performance goals. Fresh data is key for reaching and influencing consumers While the number of data sources available for advertisers is never-ending advertisers must remember that not all data sources are created equal. The time between collecting the data and using it is an important factor. Commonly datasets used in RTB can be over a week old, this means they are stale and fail to identify the right customer at the right point in their purchase journey. Find out more at http://bit.ly/1LefbPr (link is external)

Last week during the DoubleClick Leadership Summit (link is external) (DLS), we introduced cross-device measurement across all of our DoubleClick advertiser products. Today, as the first post of our week-long DLS series, we're excited to announce that these cross-device metrics will be rolling out to all DoubleClick advertisers in the next week. Mobile continues to reshape how consumers engage on digital: they are increasingly turning to the nearest device to act on an immediate need in the moment and then seamlessly shifting their attention from screen to screen to complete their journey. With the path to purchase becoming increasingly fragmented, it’s essential marketers understand how consumers interact with their brand across all devices. When marketers have access to cross-device insights, they will also make the best decisions about how to invest their marketing dollars. With this launch, advertisers can access cross-device metrics in all buying tools within our platform -- DoubleClick Campaign Manager, DoubleClick Bid Manager, and DoubleClick Search. Full article available at http://bit.ly/1I2qppH (link is external)

The Center for Digital Democracy (CDD), through its counsel, requests the following documents under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, related to enforcement of the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq.: All annual reports submitted to the Federal Trade Commission (FTC) by COPPA safe harbor programs for the reporting period of July 1, 2014 through June 30, 2015 as required by the COPPA Rule, 16 C.F.R. § 312.11(d)(1), including, for illustrative purposes, reports from the following safe harbor programs: Aristotle International Inc. Children’s Advertising Review Unit (CARU) Entertainment Software Rating Board (ESRB) iKeepSafe kidSafe Seal Program (kidSAFE) Privacy Vaults Online (PRIVO) True Ultimate Standards Everywhere (TRUSTe) CDD asks that if any of the requested records are stored electronically that the FTC provide the requested records to CDD in their native electronic format as required under FOIA. 5 U.S.C. § 552(f)(2). Request for Fee Waiver or News Media Fee Benefit CDD asks the FTC to waive all fees associated with this request because disclosure of the records is in the public interest or, alternatively, to limit any fees charged to CDD to reasonable duplication fees because it is a noncommercial request by a member of the news media. 5 U.S.C. §§ 552(a)(4)(A)(ii)(II), 552(a)(4)(A)(iii). CDD is entitled to a waiver of all fees associated with this request under FOIA’s public interest standard and relevant FTC regulations. 16 C.F.R. § 4.8(e). The regulations permit the FTC to waive all fees associated with a particular request when a requester demonstrates that (1) “disclosure will likely contribute significantly to public understanding of the operations or activities of the government” and (2) “that the request not be primarily in the commercial interest of the requester.” 16 C.F.R. §§ 4.8(e)(2)(i)-(ii). CDD’s request qualifies under both prongs of the FTC’s public interest fee waiver standard. First, disclosure of the annual reports provided to the FTC by COPPA safe harbor providers and any related correspondence will contribute significantly to the public’s understanding of the FTC’s oversight of private entities tasked with enforcing federal law. COPPA was designed to protect children’s privacy online, an issue of significant public importance that concerns parents, consumers, lawmakers, and the general public. The instant request concerns data on how actively private safe harbor providers are policing COPPA compliance by their members. Relatedly, the records will also disclose whether and how the FTC performs its oversight role with respect to the safe harbor programs.1 From the reports, the public can scrutinize both the safe harbors’ performance and the FTC’s actions in administering the safe harbor program under COPPA. Because CDD intends to publish the requested documents, the public at large will benefit from better understanding whether and how the FTC is protecting children’s privacy online. Full complaint attached.