The Federal Trade Commission has posted the comments in their ongoing review of the Child Online Privacy Protection Act (COPPA). The act provides privacy rules that, among other things, require parental consent for the collection of data from children or from users of online services directed at children.
The delivery of online advertisements involves no more “contact” with an individual by a network advertiser than the advertising department of a city newspaper has with its subscribers as a result of including inserts tailored for locals residing in particular suburban neighborhoods.
Their goal is trying to make sure that their data collection and use practices do not qualify as an online service that collects personal information under COPPA.
They are misleading the Federal Trade Commission. Interactive advertisers tout abilities to track and contact consumers throughout the web. They build profiles based on this tracking and augment these profiles with data from other sources.
Here’s how IAB member AudienceScience describes their capability:
The Audience Gateway for Advertisers Enables Marketers To:
- Engage with customers based on their behaviors and interests
- Reach target audiences wherever they go across the Web
- Send prospects relevant messages based on where they are in the buy cycle
Here’s how IAB member Google describes their retargeting techniques:
After driving traffic to your site with search ads, you can then remarket to those users who reach your site by showing them tailored ads on sites throughout the Google Content Network.
Here’s an example of how it works. Let’s say you’re a basketball team with tickets that you want to sell. You can put a piece of code on the tickets page of your website, which will let you later show relevant ticket ads (such as last minute discounts) to everyone who has visited that page, as they subsequently browse sites in the Google Content Network. In addition to your own site, you can also remarket to users who visited your YouTube brand channel or clicked your YouTube homepage ad.
You can also run a number of remarketing campaigns at the same time. For example, you could offer discount game tickets to users who’ve previously visited your tickets page, advertise VIP hospitality packages to users who clicked on your “How to get to the arena” page, and advertise a sale on team merchandise to users who previously visited your YouTube brand channel.
IAB Member OwnerIQ describes its abilities as:
OwnerIQ enables advertisers to target consumers based on what they own, what they have expressed an interest in owning (“Intenders”)… or both!
[W]e use our proprietary MostIQ Advertising Platform to reach consumers who have the appropriate Ownership Signals as they travel the web — on over 250,000 web sites, with creative designed to appeal to the Target Segments.
Their retargeting page explains, using a neat graphic, the 4 steps:
- Shoppers visit your site
- They leave your site and travel the web
- OwnerIQ identifies your prospect and presents them your message
- Your prospect is brought back to your site
IAB member Criteo also has a retargeting product:
Retargeting allows you to find your previous website visitors across the Internet and display relevant banners to lead them back to your website to complete their transaction. Bringing ready-to-buy users back to your website after they have left should be a key part of your customer acquisition and conversion strategy.
This is not contact like your newspaper delivery targeting your neighborhood.