More on the FTC Complaint – They Don’t Even Know What Behavioral Targeting Really Is!

It amazes me really.  I have spent several weeks on this blog arguing (mostly with myself) about the clarification of behavioral targeting as really being event-based targeting.  We really don’t know much about people’s behavior.  We don’t know what they are doing on the web.  We don’t know their preferences.  We don’t know frequency, timing or much of anything other than the fact that they visited certain pages in a certain order on an advertiser’s web page.  Or maybe they visited certain pages within a network.  Whatever they did, it is event-based and have little to do with actual behaviors that translate into predictable behaviors or preferences.


Anyway, the Center for Digital Democracy (CDD) and the U.S> Public Interest Research Group (US PIRG) submit this complaint to the FTC that declare user tracking/analysis and ultimately behavioral targeting as blatant violations of personal privacy.  Even though these practices are anonymous, and do not in anyway encroach on your privacy they somehow violate your privacy.  Hmmm. 


In the complaint filing, the CDD and US PIRG cite promotional materials from Atlas which is an ad server as we know.  Atlas like most other ad servers tracks post-click responses and associates those responses back to the ads that were displayed.  So if someone clicks on an ad and then navigates through a certain series of pages that results in the selection of a product and then a purchase, that revenue is related back to the banner and site it was played on.  This information is not linked up to John Smith, it is linked anonymously in aggregated form.  Linking the click-stream data to John Smith would be associating Personally Identifiable Information (PII) and that is a violation of personal privacy.  It’s also against the law.


But none of this is clarified in the filing.  Perhaps the authors do not even know this?  Ad servers track post-click results so that an advertiser can better optimize their ad campaigns on data besides for click-thru rates.  Post-click results are more useful for direct response campaigns.


The filing also calls out 24/7 Real Media and their Pixel Tracking Technology as an example of a ‘Big Brother’ monitoring violation of privacy.  Site analysis tools, or in this case network analysis tools, help publishers figure out where users are going so that they can better position content to maximize user experience.  WebTrends is another example of a site analytics software solution that is useful in tracking web site surfing habits.  Publishers want to know where to place content and what type of content is most favored by visitors so that they can better service those visitors.  In the end, these tools benefit people.  Besides, where is the violation??  No personally identifiable information is shared.  Sites do not know who you are?  They don’t know your name, address, phone number, email address etc.  They may know your IP address – which by the way is the IP address of your ISP.  They may know your geographic location, or that of your ISP.  So it is useful for them to know the time of day that you are coming from.  Advertisers like to target day-parts, it is beneficial for, say, an airline to be able to run fare specials in certain regions at certain times of the day.  This is only possible with day-part targeting and geo-targeting.  So who is suffering here?  Where is the harm?


Fire is being called out by people who do not know how to identify the smoke.  In fact the CCD and US PIRG do not even have an accurate understanding of what these technologies actually do, let alone where the violation potential exists.

_uacct = “UA-980395-1”;