1. Privacy POV
The Media Kitchen
be brave | be inventive | defy expectations
The Media Kitchen (“TMK”), a division of kirshenbaum bond senecal + partners, is a
New York City based communications planning and buying agency. Over 100+
chefs in the Atlanta and New York “kitchens” plan and buy media on behalf of 19
clients including but not limited to Delta, Victoria Secret, PBS, Sesame Workshop,
Bank of NY Mellon, and Windstream Communications.
TMK plans and buys across all channels including television, print, radio,
OOH, and digital media (including social, display, search and mobile). We
specialize in creating new media channels. We believe big ideas can live in any
media channel and the biggest ideas live across all channels and are closely
measured and monitored. We also believe that the very biggest ideas are born from
We are active members of the Interactive Advertising Bureau (IAB).
3. What, When, & Where
Recent articles and congressional bills about Online Privacy have been published
that have caused some of our clients to ask questions about the industry (and our
very own) targeting/privacy practices.
We started to receive formal inquiries from our clients and the press right after the
Wall Street Journal released their “What They Know” section on July 31, 2010.
The digital advertising industry is self regulated. Many companies (including
TMK) follow standards set by the Interactive Advertising Bureau (IAB) and
Network Advertising Initiative (NAI).
Recent articles have called into question the targeting practices of evolving
media platforms. The use of data (1st, 2nd, and 3rd party) for online targeting
has been highlighted by the WSJ and the US Congress and weʼd like to respond
to the recent press with how we use data to help our clients.
5. Summation of Online Privacy Bill
Two U.S. congressmen have proposed online privacy bills that confront disclosure
notices, opt-in requests, and user information licenses. Rick Boucher, Chairman of
the House Subcommittee on Communications, Technology and the Internet has
been most vocal.
The new proposed legislation would require companies to get a userʼs explicit
approval (that is, it would require users to “opt in”) before they “knowingly collect”
information about a personʼs medical history, ﬁnancial records, Social Security
number, sexual orientation or precise geographic location. Other information, such
as that collected by web cookies or session logs on corporate servers, would not
require explicit consent, provided the company involved displays a “clearly-written,
collected, used and disclosed” and provided users can decline or “opt out.”
Our position: the bill seems to codify accepted practice by reputable online
companies however isnʼt likely to pass in the short term due to much debate and
6. We Believe
•  Consumers want better targeted advertising.
•  Data is necessary to better target ads.
targeted ads improve conversion and
•  Increasedmessage/placement relevancy, driven
by advanced data usage and capture, improves
the overall consumer experience.
•  Privacy has to be respected at all costs.
7. We Know
•  The data we collect and use is non-PII.
•  FTC deﬁnition of PII is very broad: The FTC believes that
PII is data "that could reasonable be associated with a
particular consumer or computer or other device, regardless
of whether the data is 'personally identifiable' in the
•  We never, nor do we ever recommend to our clients to use PII
data or store information in Flash cookies.
•  All of our 1st, 2nd, 3rd party data conforms to strict privacy
•  Consumers have the option to opt-out, however that has not
been easy and we are making recommendations to change that.
8. Before the debate goes too far, some background:
•  The following slides contain some simple exhibits
that outline much of what the privacy/targeting
chatter is about:
-  Exhibit A: Understanding Ad Serving
-  Exhibit B: Pixels, Containers, & Cookies
-  Exhibit C: Example Pixel [tag]
-  Exhibit D: Example Container
-  Exhibit E: Example Cookie
-  Exhibit F: Example 3rd Party Data Collection
9. Understanding Ad Serving
Extremely, extremely simpliﬁed
Source: Eyeblaster Description of Methodology, July 2009
10. Pixels, Containers, & Cookies
Pixels are grouped in a
container tag (.js or iFrame).
Container tag (UAT, Floodlight)
is ﬁlled with tracking pixels by
agency on-behalf of media
partners. Could alsoinclude
web analytics or audience
Pixels “ﬁre” when page is
loaded and a “cookie” is
dropped to the browserʼs
computer in the form of a small
text ﬁle that is mapped to a
11. Example [Pixel] Tag: Quantcast/HuffPo
12. Example Container: Demdex/VMM
13. Example Cookie
14. Example: 3rd Party Data Collection
Taken from an excerpt on BlueKaiʼs website
Tag is from Motortrend.com Source Code
•  Jasmine is shopping online for air travel between New York to Hawaii. As she visits different online travel
sites who partner with BlueKai, we [Bluekai] store an anonymous cookie on her browser.
•  As a result, BlueKai marketing partners will show ads on Jasmine's computer that are relevant to in-market
Hawaii travelers. (For a limited amount of time.)
•  As a consumer, Jasmine has a choice to:
Be informed and participate:
From the BlueKai Registry, Jasmine can always get visibility into what marketers are using to serve
targeted ads and she can also participate by updating her preferences
Choose NOT to participate:
At anytime, Jasmine can optout from having her preferences in the BlueKai Registry. While Jasmine will
continue to see ads, she can rest assured that from that point on no more data will be collected or shared.
15. Two Types of “Tracking”
User ﬂow & experience
Ex. 3rd Party Ad Servers:
Ex. Measurement Systems:
At the end of the day, tracking is used to enhance the consumer experience.
16. How We Target Audiences
Instead of targeting one individual (PII)….
We target based on a set of data; creating custom
Clusters (non PII)
We then target audiences based on these clusters on
behalf of our clients using 3rd party ad serving systems
17. Best Practices: Google
Google allows the user
to view & edit how they
are categorized, opt-out,
and even shows their
Ability to edit preferences for
a more targeted user experience
Holy cow, thatʼs my cookie!
18. Best Practices: blueKai
bluekai allows users to
view & edit how they are
categorized and even
allows users to pick a
charity to donate
targeting dollars to.
Ability to edit preferences for
a more targeted user experience
Ability to select charity to donate
a portion of your targeting dollars
19. Best Practices: NAI
The NAI is the largest opt-out
aggregator for companies using
Ability to opt-out of receiving targeted
advertisements by over 20 leading advertising
networks & data providers
21. Evolving the Conversation
•  Customers donʼt want to feel taken advantage of, yet we
create situations of obfuscation
•  The only way to build trust is to be fully transparent and
inform customers what weʼre capturing and why weʼre doing
•  Full transparency around how data is collected, how its used
and whatʼs being collected is paramount if our customers
and prospects are to trust us.
22. Evolving the Conversation
•  Despite our good intentions and need to protect ourselves in
the litigious society we compete in, our vocabulary only
seems to alienate our customers.
•  Since most people donʼt know legalese we have to use the
vocabulary our customers easily understand. Anything less
will create mistrust.
23. Evolving the Conversation
•  Weʼve been taught that the small type on a contract is where
all the dangerous stuff lives yet we burry our policies at the
bottom in small type.
•  Lets bring our policies upfront and use a larger font.
24. Making Consumers Feel Comfortable With Data Collection
•  Consumers need to understand the opportunities and
implications of data collection and the advertising
industry has to drive the transparency agenda.
•  We need to continue to partner with leading privacy
groups to show consumers why and how they are being
targeted for advertisements.
•  Weʼve developed a process called the Privacy
Audit based on our beliefs and approaches to help
clients better communicate their privacy policies clearly
25. The Privacy Audit
•  Tohelp our clients determine if theyʼre privacy
statements are helping them build trust with their
customers and prospects weʼve developed our
Privacy Audit, which is designed to answer:
-  Is your privacy statement clear?
-  Does the statement explain what data is being
collected and how the data is used?
-  Is it prominently displayed?
-  Does it create a trust among customers?
-  What data is being collected and is it non-PII?
26. Contact Us
President, The Media Kitchen
Chief Digital Media Ofﬁcer, The Media Kitchen