Questions for Behavioral Targeting Players

Behavioral targeting promises the stars to both publishers and advertisers. Publishers are enticed by the promise of selling their less popular inventory at higher rates than they could normally earn. Advertisers, meanwhile, get extended access to valuable consumer segments when the obvious places to buy them are sold out or priced too high.

However, the data ownership issues surrounding behavioral targeting agreements are complex, and sometimes opaque. This is particularly the case with networks such as those offered by Tacoda and DRIVEpm, which promise to aggregate publisher audiences for a single campaign.

In an effort to get a grip on the various behavioral targeting companies’ exact data practices, ClickZ polled the top executives of four prominent players operating in the space. We posed the same three questions to each person with the goal of pinning down exactly what publishers and advertisers can expect will be done with data collected on their sites and campaigns.

Tacoda: CEO Dave Morgan

Q. Is it OK to use data from one advertiser’s campaign to target another advertiser’s campaign?

A. I believe that openness over the use and protection of consumer and campaign data is critical for the behavioral targeting industry.

Ultimately, the use of data from campaigns is an issue between the respective data owners — advertisers, agencies and publishers. Tacoda recommends that this be determined prior to running campaigns and the terms should be contained in the basic insertion order terms and conditions.

The publishers that we work with protect and do not re-use campaign data for retargeting in other advertisers’ campaigns. Likewise, we believe that advertisers and their agencies should do the same, and not use consumer data from one campaign for re-targeting purposes on other publishers’ sites.

Q. Is it OK to use data gathered on one publisher’s site to target on another publisher’s site?

A. It is not OK without the express permission of the publisher. This must be spelled in the T&C’s.

Q. Please spell out your exact data practices.

A. Tacoda provides technology services to publishers and does not own or collect consumer data itself. Tacoda believes that consumers have a right of notice and opt-ability before any personal data is captured and stored. Tacoda believes that spyware applications have no place in the marketplace.

Revenue Science: SVP of Marketing Omar Tawakol

Q. Is it okay to use data from one advertiser’s campaign to target another advertiser’s campaign?

A. The simple rule here is that specific customer interactions paid for by one advertiser should never be shared with other advertisers — especially competitive ones. This is not a legal point but more of an issue of trust. When brand name publishers do business with large advertisers they do so based on trust and they have certain expectations. Does Visa want American Express to be able to buy a campaign that is only delivered to people who clicked on a prior Visa campaign? Of course not. The technology exists for this to happen, but I am certain that publishers value the revenue they get from key advertisers, and this behavior would put that in jeopardy.

The simple rule stated above, however, doesn’t prevent a publisher from garnering best practices or learnings from a campaign that can be applied to other campaigns. This is normal and should happen. Publishers should optimize how they define audiences and placements based on results from campaigns. The restriction is really about sharing data at the customer level (i.e. this particular customer clicked on your competitor’s ad and if you pay me, I will let you use that data).

Q. Is it okay to use data from one publisher’s site to target on another publisher’s site?

A. Revenue Science’s publisher partners own and have complete control over the data from the behavioral targeting campaigns that they run on their site. No third party technology provider or technology service company should ever use data from one publisher to benefit another publisher without publisher consent and the right payment model.

Q. What are your general data practices?

A. These are the three rules that guide our data practices:

Revenue Science processes information as an authorized agent of its clients and provides the information directly back to them. Revenue Science never uses the data for its own purposes.

Revenue Science never collects any personally identifiable information of any of its clients’ users.

Based on a user’s behavior on a site, Revenue Science creates an anonymous user profile and groups it with others that have displayed similar behavior. Revenue Science never tracks users as individuals, but as members of a behavioral-based group — thus ensuring that the user’s privacy is strictly protected.

As we mentioned above, there should be clear data ownership models between publishers and advertisers, publishers and other publishers, and publishers and consumers. There also must be key practices for data ownership between publishers and consumers.

aQuantive’s DrivePM: General Manager Scott Howe

Q. Is it okay to use data from one advertiser’s campaign to target another advertiser’s campaign?

A. No — unless an advertiser specifically gives their permission to utilize their data (e.g. under a data cooperative).

Q. Is it OK to use data gathered on one publisher’s site to target on another publisher’s site?

A. No — unless a publisher specifically gives their permission to utilize their data (e.g. under a data licensing agreement).

Q. Please spell out your exact data practices.

A. All DRIVEpm cookie-level data is stored by Atlas DMT and is warehoused for the exclusive use of DRIVEpm and its publisher and advertiser partners.

When DRIVEpm purchases inventory from a publisher or agrees to sell publisher inventory on a revenue share basis, DRIVEpm assumes ownership of this placement. Naturally, DRIVEpm tracks performance of these placements and owns any corresponding analysis. While this information is occasionally used to infer cookie gender, it is not used for any other targeting purposes without the publisher’s approval. Under no circumstances will DRIVEpm remarket or utilize publisher information as it pertains to an individual publisher (e.g. resell or create a segment of “X publisher” cookies) without that publisher’s written approval.

Publisher specific data not related to purchased placements is owned by DRIVEpm’s publisher partners but may occasionally be utilized for that publisher with that publisher’s permission. Such data is most typically collected through the implementation of action tags or data pass-backs between the publisher and DRIVEpm. In such situations, DRIVEpm will obtain specific approval around what data is collected, when it will be utilized and how the contributing publisher will be compensated for its data contribution. This agreement will typically be contained in an insertion order between the specific publisher and DRIVEpm that details out the data and usage terms.

AlmondNet: CEO Roy Shkedi and VP of Business Development Michael Benedek

Q. Is it okay to use data from one advertiser’s campaign to target another advertiser’s campaign?

A. We assume that your question relates to how we believe AlmondNet clients should use our solutions since we ourselves as a matter of policy do not compete with our publisher clients by working directly with advertisers.

We have a number of concerns with [this scenario]:

How will the publisher’s advertisers react? Data ownership is a sensitive issue and an unsatisfied advertiser will not likely be a repeat advertiser.

Is such targeting effective? Advertisers are seeking to develop long-term, profitable relationships with customers. If the targeting that you describe works against this objective, it does not serve the publisher’s interests.

Is it ethical? We believe that the targeting you describe definitely runs the risk of presenting the publisher in a very shady light.

Q. Is it OK to use data gathered on one publisher’s site to target on another publisher’s site?

A. In order to get behavioral targeting off the ground, we need to make it simple and we need to make it scale. Right now, some of the vendors in our space are encouraging their publisher clients to pinpoint advertising to such an extent that they run into problems of scale. How can any publisher make money when they are targeting campaigns to an audience of only 12 people?

We believe that the first step to making behaviorally-targeted campaigns a viable and significant proportion of a publisher’s ad revenue is to keep things simple. I.E. [A publisher] should offer advertisers [a way] to reach high-value section audiences within the publisher’s remnant space where low value inventory is available. The return from these campaigns in terms of effective CPM will undoubtedly be higher than the return the publisher can earn from contextual/behavioral/remnant programs offered by behavioral targeting vendors, other vendors, or ad networks.

Once the publisher has used behavioral targeting to sell as much of its low-value inventory as possible by delivering relevant ads to high-value audiences outside the high-value/low-inventory sections of its own site, it makes sense for the publisher to look outside its site and use behavioral targeting to enable its own advertisers to reach their target audience within the unsold inventory of other sites that it chooses to partner with.

…[E]ach publisher can retain ownership of its audience data, advertiser relationships [and] pricing and acquire a new revenue stream outside its own site by delivering relevant ads to its audience wherever that audience goes within the unsold space of partner publishers.

Q. Please spell out your exact data practices.

A. We believe that the publisher owns the data.

As mentioned above, the only way behavioral targeting will scale is if we enable each publisher to sell its advertisers access to its audience, wherever the audience happens to be. This model benefits all constituencies, since the publisher with the advertiser relationship sells more impressions, the publisher with the unsold inventory receives an access fee, the advertiser receives access to its audience everywhere, and the surfer/consumer sees relevant ads all the time.

We believe this is the only model that can work since it is the only model that allows each publisher to control its data and pricing, while expanding its existing advertiser relationships. The alternatives, which include allowing behavioral targeting vendors to cookie a publisher’s audience and offer this audience to its own advertisers in competition with the publisher, are not in the publisher’s interests. Once a publisher allows its behavioral targeting vendor or an ad network to cookie its audience, the publisher loses control over its pricing by setting up a competitor to its own sales force that will offer the publisher’s inventory for a lower price, at the publisher’s expense!

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