So now that you know what Behavioral Targeting is and how it is being regulated, has your opinion changed at all? Do you think that Behavioral advertising is a good thing – serving relevant ads to people who are likely “in market” for a particular product or service? Or a bad thing – an invasion of privacy of the highest degree?
As an “insider” or someone who actively uses and pitches Behavioral Advertising to our roster of Pepperjam clients, I think Behavioral Targeting is a great method of advertising across the internet. As a marketer our goal is to best serve our clients and provide for them the best possible ROI, and our use of behavioral targeting has given us a greater potential for achieving our clients’ goals. Having the ability to target our prospective consumer based on their past web surfing history, we can more accurately gauge what products or services this consumer would be “in market” for.
As a real world example, we have a client, Brigade QM, who specializes in products tailored to the military, government, police, and Special Forces. They also carry outdoor supplies and tactical goods that people in security can use. For the last three months we have been running a Behaviorally Targeted campaign for them on a large Behavioral Ad Network. We conveyed to our Behavioral Network that our goal was to back into a specified CPA goal. We targeted several verticals including Military, government, Men’s vertical, News and Reference, Sports, and Gaming – focusing in on users whose cookie history conveyed interests in military or security equipment. Since the beginning of the campaign in April, our client has received over 600 sales (having successfully backed into their CPA goal), and has generated nearly $7 dollars in revenue for every dollar ($1) they spent. WOW!
As you can see, Behavioral Targeting is effective in our industry. As it stands right now, Behavioral Targeting is not, in my opinion, a privacy concern. These Behavioral Ad Networks are not data mining users personal information, rather they are using a consumers nonpersonally identifiable cookies to determine what interests they might have and serve them ads accordingly. In many ways it is no different than receiving coupons for relevant items from the grocery store or CVS.
However, given the technology that does exist for these Behavioral Networks to collect, use and sell our personal identifiable information, it does give even us marketers pause for concern. Allowing Behavioral Networks access, without consent to this information is dangerous and yes, an invasion of privacy.
But I do not agree with the manner in which Assemblyman Richard Brodsky is approaching this concern. As it stands right now, the NAI, the IAB and the FTC are all in the process of either self regulating or formally regulating these practices. To implement Mr. Brodsky’s regulation on a state by state basis would be exasperating. The bill is far stricter than the IAB and FTC guidelines and would create an extensive regime of consumer notice and choice for Behavioral Ad Network tracking of different types of consumer online activity. The bill also calls for:
- Absent obtaining a consumer’s prior affirmative consent, Behavioral Ad Networks would be prohibited from collecting personally identifiable information online in some situations (when merged with certain other previously collected data).
- Consumers would have the right to opt-out of any online tracking involving non-personally identifiable information.
- The bill would require clear notice by advertising companies on their own sites of their profiling activities, the types of data they collect, how they use the data, the opt-out process, and the length of time the data is retained.
- The bill would require advertising companies to contractually require the sites to whom they provide services to include notice and opt-out options.
I believe that this sort of regulation puts far too much responsibility on the consumer and will make the user’s internet experience a negative one. Imagine for a second being a consumer and on every webpage that you visit having to consent or deny that site to collect your nonpersonal information and/or your personal information. Or prior to being directed to a desired website’s page having to first read what information of yours is being tracked and giving that person a chance to opt out. Your time spend on the internet could double just from this process alone!
Moreover, the biggest concern I have is the availability of free content on the internet. Many sites are able to afford being free content sites, like the New York Times, because they sell advertising. Take that option away from publisher sites and say goodbye to free content. “Consumers enjoy cost-free online content; competitive pricing and product comparisons; education and information gathering tools; communications, such as free email and telephone services; social networking environments and online safety tools all because of online advertising,” said Randall Rothenberg, president and CEO of the IAB. “Research shows consumers value free Internet services highly and prefer advertising that is relevant to their interests, but want guarantees that their personally identifiable information won’t be misused.”
I think the best outcome would be for the industry to keep self regulating itself, rather than having these strict regulations in place. People like their free content and ads that are relevant to their interests. I believe the bill pending in the New York State Assembly unnecessarily burdens the consumer with opt-ins or opt-ins, especially considering the headway the industry is making to alleviate privacy fears through proactive self regulation.