We strongly support the objectives of the California Consumer Privacy Act (CCPA), but we have notable concerns around the likely negative impact on California consumers and businesses from some of the specific language in the law. We provide this initial comment to provide you with information about the significant importance of a data-driven and ad-supported online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your attention to several areas that can be addressed and improved through the rulemaking process. We will provide more detailed comments over the coming weeks.
Online Behavioral Advertising (OBA) Legal & Regulatory ComplianceAdler Law Group
Behavioral or targeted marketing and advertising is one of the fastest growing areas for advertising and marketing professionals. New technologies driving behavioral and contextual advertising are challenging the established methods. Many realize that limiting targeted marketing may lead to undesired and potentially disruptive consequences, including undermining the implicit bargain that drives the Internet: the exchange of value between consumers and content providers. However, legislators, regulators, and industry trade groups have expressed concerns over perceived abuses of the collection and use of personal data of online users that involve privacy issues that “go well beyond behavioral advertising.” With every technological development and opportunity, new legal and business risks present themselves. Understanding and minimizing these risks will help you maximize the opportunities. Attendees will learn 1) the current state of behavioral and contextual advertising, 2) risks and pitfalls with targeted advertising, and 3) trends in legislation and regulatory compliance.
The DASHBOARD Act would impose several data-disclosure requirements on large companies that monetize online user data. The Act assumes a market failure of information asymmetry, where consumers undervalue their personal data. However, the evidence for this claim is indeterminate, and a lack of clarity on data property rights and liability could make corresponding rules difficult to enforce.
Policy Brief : Can the GDPR help SMEs innovate for older adults in Europe?Mobile Age Project
Mobile Age project: https://www.mobile-age.eu/
This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 693319.
This material reflects only the author's view and the Research Executive Agency (REA) is not responsible for any use that may be made of the information it contains.
Online Behavioral Advertising (OBA) Legal & Regulatory ComplianceAdler Law Group
Behavioral or targeted marketing and advertising is one of the fastest growing areas for advertising and marketing professionals. New technologies driving behavioral and contextual advertising are challenging the established methods. Many realize that limiting targeted marketing may lead to undesired and potentially disruptive consequences, including undermining the implicit bargain that drives the Internet: the exchange of value between consumers and content providers. However, legislators, regulators, and industry trade groups have expressed concerns over perceived abuses of the collection and use of personal data of online users that involve privacy issues that “go well beyond behavioral advertising.” With every technological development and opportunity, new legal and business risks present themselves. Understanding and minimizing these risks will help you maximize the opportunities. Attendees will learn 1) the current state of behavioral and contextual advertising, 2) risks and pitfalls with targeted advertising, and 3) trends in legislation and regulatory compliance.
The DASHBOARD Act would impose several data-disclosure requirements on large companies that monetize online user data. The Act assumes a market failure of information asymmetry, where consumers undervalue their personal data. However, the evidence for this claim is indeterminate, and a lack of clarity on data property rights and liability could make corresponding rules difficult to enforce.
Policy Brief : Can the GDPR help SMEs innovate for older adults in Europe?Mobile Age Project
Mobile Age project: https://www.mobile-age.eu/
This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 693319.
This material reflects only the author's view and the Research Executive Agency (REA) is not responsible for any use that may be made of the information it contains.
The CCPA has a big impact on the digital ecosystem, putting guidelines on personal information collection and post-data-acquisition data usage by businesses. CCPA compliance deadline commenced January 2020 and it’s critical to know how this will impact your business in order to avoid violations. If you haven’t started redoing your privacy policy, that’s your next step now that California residents have more control over what happens to their personal information that companies collect. We had a live Q&A session where we address your most burning questions and unpack the key requirements and considerations to keep in mind in order to stay compliant. See how CCPA impacts all advertisers, not just Californians.
Intermediary Accountability in the Digital AgeRichard Austin
Examination of the accountability of Internet Intermediaries with a focus on Online Reputation, Cambridge Analytica and Facebook and Competition issues
China Mobile Advertising Landscape Report (Thomvest Ventures)Thomvest Ventures
This report examines China's digital advertising industry, with a specific focus on mobile. Our goal with this research is to grasp the many nuances of advertising technology in China – what role does programmatic play, who are the key vendors in the space, what challenges do these vendors face, and how do we expect the market to evolve over the next several years?
Grant Proposal of the Association for Consumer EffectivenessJoel Drotts
This is the current grant proposal under submission to several large corporate and private foundations and donors, by the Association for Consumer Effectiveness. The Association has become the premier consumer perspective and consumer protection organization, in the field and industry of Data Brokers. Data Brokers are the large data hungry companies that trample consumer privacy on a greater scale every day in America. The Association has been charged with the duty and mission to help prevent this from occurring even further, and if possible reverse the damage already caused to the privacy of the American Consumer Public.
CCPA is set to be the most comprehensive privacy law to date in the US and aims to give Californians more control over their personal information.
During my work at Criteo, I'm in charge of CCPA project from initialisation, planification to answer to the clients questions.
Furthermore, I took specific actions including training program, One pager and Q&A edition, as well as cooperation with other departments, such as marketing, law and sales teams.
A summary of the opportunities & challenges that lay ahead in the new data-fuelled marketing ecosystem; including the 5 key questions to ask your data tech vendor.
The CCPA has a big impact on the digital ecosystem, putting guidelines on personal information collection and post-data-acquisition data usage by businesses. CCPA compliance deadline commenced January 2020 and it’s critical to know how this will impact your business in order to avoid violations. If you haven’t started redoing your privacy policy, that’s your next step now that California residents have more control over what happens to their personal information that companies collect. We had a live Q&A session where we address your most burning questions and unpack the key requirements and considerations to keep in mind in order to stay compliant. See how CCPA impacts all advertisers, not just Californians.
Intermediary Accountability in the Digital AgeRichard Austin
Examination of the accountability of Internet Intermediaries with a focus on Online Reputation, Cambridge Analytica and Facebook and Competition issues
China Mobile Advertising Landscape Report (Thomvest Ventures)Thomvest Ventures
This report examines China's digital advertising industry, with a specific focus on mobile. Our goal with this research is to grasp the many nuances of advertising technology in China – what role does programmatic play, who are the key vendors in the space, what challenges do these vendors face, and how do we expect the market to evolve over the next several years?
Grant Proposal of the Association for Consumer EffectivenessJoel Drotts
This is the current grant proposal under submission to several large corporate and private foundations and donors, by the Association for Consumer Effectiveness. The Association has become the premier consumer perspective and consumer protection organization, in the field and industry of Data Brokers. Data Brokers are the large data hungry companies that trample consumer privacy on a greater scale every day in America. The Association has been charged with the duty and mission to help prevent this from occurring even further, and if possible reverse the damage already caused to the privacy of the American Consumer Public.
CCPA is set to be the most comprehensive privacy law to date in the US and aims to give Californians more control over their personal information.
During my work at Criteo, I'm in charge of CCPA project from initialisation, planification to answer to the clients questions.
Furthermore, I took specific actions including training program, One pager and Q&A edition, as well as cooperation with other departments, such as marketing, law and sales teams.
A summary of the opportunities & challenges that lay ahead in the new data-fuelled marketing ecosystem; including the 5 key questions to ask your data tech vendor.
The FDA’s role in the approval and subsequent review of Vioxx, a.docxmehek4
The FDA’s role in the approval and subsequent review of Vioxx, a pain medication with- drawn from the market by its manufacturer after it was associated with heart attacks and strokes, is discussed in a case at the end of this textbook.
In 2010, Congress established, as part of the Dodd-Frank Act (also discussed in Chapters 8 and 14), a new consumer regulatory body, called the Consumer Financial Pro- tection Bureau. The purposes and actions of this agency are described in Exhibit 15.B. The debate over whether government should become involved in protecting consumer privacy is discussed in the next section of this chapter.
All seven government regulatory agencies shown in Figure 15.2 are authorized by law to intervene directly into the very center of free market activities, if that is considered nec- essary to protect consumers. In other words, consumer protection laws and agencies substi- tute government-mandated standards and the decisions of government officials for decision making by private buyers and sellers.
Consumer Privacy in the Digital Age
In the early 21st century, rapidly evolving information technologies have given new ur- gency to the broad issue of consumer privacy. Shoppers have always been concerned that information they reveal in the course of a sales transaction—for example, their credit card or driver’s license numbers—might be misused. But in recent years, fast-changing tech- nologies have increasingly enabled businesses to collect, buy, sell, and use vast amounts of personal data about their customers and potential customers. The danger is not only that this information might rarely be used fraudulently, but also that its collection represents a violation of privacy and might lead to unanticipated harms.
Individuals are often unaware of how much information about themselves they reveal to others as they shop, interact with friends, play games, or look for information online. A variety of technologies make this possible. Many websites place cookies—or more power- ful Flash cookies—on a computer hard drive, to identify the user during each subsequent visit and to build profiles of their behavior over time. Web beacons embedded in e-mails and websites retrieve information about the viewer. In deep packet inspection, third parties access and analyze digital packets of information sent over the Internet, such as pieces of e-mails or Skype calls, to infer characteristics of the sender. Not just retailers, but also Internet service providers such as Comcast, search engine operators such as Google, and informational services such as Dictionary.com, also track their users. So-called data aggregators purchase and combine data about individuals collected from various sources and compile them into highly detailed portraits to be sold to retailers, service providers, and advertisers.15
An example of a data aggregator is Acxiom Corporation, based in Conway, Arkansas. Acxiom, called the “quiet giant” of the industry, has built the larg ...
TrustArc Webinar_ How Data Privacy Demands Impact Your Marketing Team.pdfTrustArc
Ask any modern marketer for their favorite privacy acronym, and they will probably tell you: GDPR, LGPD, CCPA, or PIPL – and that’s before we factor in layers of data ethics or self-regulatory practices like opt-in, opt-out, CDPs and CMPs, PII and SPI, AMIs and beyond cookies. Too often, there is a lack of clear guidance for marketers on how to transform compliance requirements into Marketing practices.
Not to mention the fact that many times the legalese leaves room for broad interpretation, giving rise to questions like: Do you need consent for everything? Can your company capture consent in exchange for content? How is notice and enhanced notice being extended?
In this webinar, we explore tactics and strategies Marketing teams can implement to comply with both privacy laws and important self-regulatory programs and still achieve consumer trust and exceed business objectives.
This webinar reviews:
- Consent and marketing under current privacy laws and regulations
- What you can and cannot do to identify prospects, generate leads and convert into customers
- The key questions a marketer needs to ask their agencies and ad tech service providers
TrustArc Webinar-Advertising, Privacy, and Data Management Working TogetherTrustArc
Today, more and more companies use advertising technologies (AdTech) to reach their consumers and better understand their preferences. This can lead to multiple data protection risks. Data privacy awareness is increasing due to seismic developments in the industry brought about by key players such as Google and Apple. In parallel, global regulations set stricter guidelines around the collection, storage, and use of personal data.
This is not over. With the decisions coming out soon on analytics, how will the advertising technologies landscape adjust? Ultimately, how can advertising, privacy, and data management work together?
Our panel in this webinar explored the practical steps your organization should take to ensure that its digital advertising practices are compliant with data protection laws.
This webinar reviews:
- The current practices and developments in the AdTech industry
- The laws and regulations governing AdTech
- How to address the privacy issues related to advertising technology
The data privacy changes coming down the pike are sending shockwaves through the digital marketing world. In this series, our goal is to provide digital marketers with the insights, tools, and solutions they need to adapt to IDFA and the end of cookies. We unpack the latest privacy news, discuss how to harness the power of first-party data, advise on how to build out your MarTech strategy, and more.
Google Solutions for Brands to Build a Privacy-First StrategyTinuiti
The data privacy changes coming down the pike are sending shockwaves through the digital marketing world. In this series, our goal is to provide digital marketers with the insights, tools, and solutions they need to adapt to IDFA and the end of cookies. We unpack the latest privacy news, discuss how to harness the power of first-party data, advise on how to build out your MarTech strategy, and more.
a group of locksmiths has filed a new class action lawsuit against Google, Microsoft and Yahoo. They claim the search engines (Google in particular) are deliberately “flooding” organic results with “scam locksmith listings” known to be false.
In an extensive and lengthy argument, Amazon argues that interactions with the Alexa virtual assistant are free speech. That includes both the human speech commands and the AI/robot responses. Interestingly, Amazon cites Search King v. Google for the proposition that Alexa responses are like search results and entitled to the same editorial protections accorded Google under that ruling and related case law
European Court of Justice Press Release GS Media vs. SanomaGreg Sterling
[W]hen hyperlinks are posted for profit, it may be expected that the person who posted such a link should carry out the checks necessary to ensure that the work concerned is not illegally published. Therefore, it must be presumed that that posting has been done with the full knowledge of the protected nature of the work and of the possible lack of the copyright holder’s consent to publication on the internet. In such circumstances, and in so far as that presumption is not rebutted, the act of posting a clickable link to a work illegally published on the internet constitutes a ‘communication to the public’.
Mastering Local SEO for Service Businesses in the AI Era is tailored specifically for local service providers like plumbers, dentists, and others seeking to dominate their local search landscape. This session delves into leveraging AI advancements to enhance your online visibility and search rankings through the Content Factory model, designed for creating high-impact, SEO-driven content. Discover the Dollar-a-Day advertising strategy, a cost-effective approach to boost your local SEO efforts and attract more customers with minimal investment. Gain practical insights on optimizing your online presence to meet the specific needs of local service seekers, ensuring your business not only appears but stands out in local searches. This concise, action-oriented workshop is your roadmap to navigating the complexities of digital marketing in the AI age, driving more leads, conversions, and ultimately, success for your local service business.
Key Takeaways:
Embrace AI for Local SEO: Learn to harness the power of AI technologies to optimize your website and content for local search. Understand the pivotal role AI plays in analyzing search trends and consumer behavior, enabling you to tailor your SEO strategies to meet the specific demands of your target local audience. Leverage the Content Factory Model: Discover the step-by-step process of creating SEO-optimized content at scale. This approach ensures a steady stream of high-quality content that engages local customers and boosts your search rankings. Get an action guide on implementing this model, complete with templates and scheduling strategies to maintain a consistent online presence. Maximize ROI with Dollar-a-Day Advertising: Dive into the cost-effective Dollar-a-Day advertising strategy that amplifies your visibility in local searches without breaking the bank. Learn how to strategically allocate your budget across platforms to target potential local customers effectively. The session includes an action guide on setting up, monitoring, and optimizing your ad campaigns to ensure maximum impact with minimal investment.
10 Video Ideas Any Business Can Make RIGHT NOW!
You'll never draw a blank again on what kind of video to make for your business. Go beyond the basic categories and truly reimagine a brand new advanced way to brainstorm video content creation. During this masterclass you'll be challenged to think creatively and outside of the box and view your videos through lenses you may have never thought of previously. It's guaranteed that you'll leave with more than 10 video ideas, but I like to under-promise and over-deliver. Don't miss this session.
Key Takeaways:
How to use the Video Matrix
How to use additional "Lenses"
Where to source original video ideas
SEO as the Backbone of Digital MarketingFelipe Bazon
In this talk Felipe Bazon will share how him and his team at Hedgehog Digital share our journey of making C-Levels alike, specially CMOS realize that SEO is the backbone of digital marketing by showing how SEO can contribute to brand awareness, reputation and authority and above all how to use SEO to create more robust global marketing strategies.
When most people in the industry talk about online or digital reputation management, what they're really saying is Google search and PPC. And it's usually reactive, left dealing with the aftermath of negative information published somewhere online. That's outdated. It leaves executives, organizations and other high-profile individuals at a high risk of a digital reputation attack that spans channels and tactics. But the tools needed to safeguard against an attack are more cybersecurity-oriented than most marketing and communications professionals can manage. Business leaders Leaders grasp the importance; 83% of executives place reputation in their top five areas of risk, yet only 23% are confident in their ability to address it. To succeed in 2024 and beyond, you need to turn online reputation on its axis and think like an attacker.
Key Takeaways:
- New framework for examining and safeguarding an online reputation
- Tools and techniques to keep you a step ahead
- Practical examples that demonstrate when to act, how to act and how to recover
Short video marketing has sweeped the nation and is the fastest way to build an online brand on social media in 2024. In this session you will learn:- What is short video marketing- Which platforms work best for your business- Content strategies that are on brand for your business- How to sell organically without paying for ads.
AI-Powered Personalization: Principles, Use Cases, and Its Impact on CROVWO
In today’s era of AI, personalization is more than just a trend—it’s a fundamental strategy that unlocks numerous opportunities.
When done effectively, personalization builds trust, loyalty, and satisfaction among your users—key factors for business success. However, relying solely on AI capabilities isn’t enough. You need to anchor your approach in solid principles, understand your users’ context, and master the art of persuasion.
Join us as Sarjak Patel and Naitry Saggu from 3rd Eye Consulting unveil a transformative framework. This approach seamlessly integrates your unique context, consumer insights, and conversion goals, paving the way for unparalleled success in personalization.
For too many years marketing and sales have operated in silos...while in some forward thinking companies, the two organizations work together to drive new opportunity development and revenue. This session will explore the lessons learned in that beautiful dance that can occur when marketing and sales work together...to drive new opportunity development, account expansion and customer satisfaction.
No, this is not a conversation about MQLs and SQLs. Instead we will focus on a framework that allows the two organizations to drive company success together.
The digital marketing industry is changing faster than ever and those who don’t adapt with the times are losing market share. Where should marketers be focusing their efforts? What strategies are the experts seeing get the best results? Get up-to-speed with the latest industry insights, trends and predictions for the future in this panel discussion with some leading digital marketing experts.
Everyone knows the power of stories, but when asked to come up with them, we struggle. Either we second guess ourselves as to the story's relevance, or we just come up blank and can't think of any. Unlocking Everyday Narratives: The Power of Storytelling in Marketing will teach you how to recognize stories in the moment and to recall forgotten moments that your audience needs to hear.
Key Takeaways:
Understand Why Personal Stories Connect Better
How To Remember Forgotten Stories
How To Use Customer Experiences As Stories For Your Brand
Videos are more engaging, more memorable, and more popular than any other type of content out there. That’s why it’s estimated that 82% of consumer traffic will come from videos by 2025.
And with videos evolving from landscape to portrait and experts promoting shorter clips, one thing remains constant – our brains LOVE videos.
So is there science behind what makes people absolutely irresistible on camera?
The answer: definitely yes.
In this jam-packed session with Stephanie Garcia, you’ll get your hands on a steal-worthy guide that uncovers the art and science to being irresistible on camera. From body language to words that convert, she’ll show you how to captivate on command so that viewers are excited and ready to take action.
Top 3 Ways to Align Sales and Marketing Teams for Rapid GrowthDemandbase
In this session, Demandbase’s Stephanie Quinn, Sr. Director of Integrated and Digital Marketing, Devin Rosenberg, Director of Sales, and Kevin Rooney, Senior Director of Sales Development will share how sales and marketing shapes their day-to-day and what key areas are needed for true alignment.
Monthly Social Media News Update May 2024Andy Lambert
TL;DR. These are the three themes that stood out to us over the course of last month.
1️⃣ Social media is becoming increasingly significant for brand discovery. Marketers are now understanding the impact of social and budgets are shifting accordingly.
2️⃣ Instagram’s new algorithm and latest guidance will help us maintain organic growth. Instagram continues to evolve, but Reels remains the most crucial tool for growth.
3️⃣ Collaboration will help us unlock growth. Who we work with will define how fast we grow. Meta continues to evolve their Creator Marketplace and now TikTok are beginning to push ‘collabs’ more too.
SMM Cheap - No. 1 SMM panel in the worldsmmpanel567
Boost your social media marketing with our SMM Panel services offering SMM Cheap services! Get cost-effective services for your business and increase followers, likes, and engagement across all social media platforms. Get affordable services perfect for businesses and influencers looking to increase their social proof. See how cheap SMM strategies can help improve your social media presence and be a pro at the social media game.
The session includes a brief history of the evolution of search before diving into the roles technology, content, and links play in developing a powerful SEO strategy in a world of Generative AI and social search. Discover how to optimize for TikTok searches, Google's Gemini, and Search Generative Experience while developing a powerful arsenal of tools and templates to help maximize the effectiveness of your SEO initiatives.
Key Takeaways:
Understand how search engines work
Be able to find out where your users search
Know what is required for each discipline of SEO
Feel confident creating an SEO Plan
Confidently measure SEO performance
In this presentation, Danny Leibrandt explains the impact of AI on SEO and what Google has been doing about it. Learn how to take your SEO game to the next level and win over Google with his new strategy anyone can use. Get actionable steps to rank your name, your business, and your clients on Google - the right way.
Key Takeaways:
1. Real content is king
2. Find ways to show EEAT
3. Repurpose across all platforms
Digital marketing is the art and science of promoting products or services using digital channels to reach and engage with potential customers. It encompasses a wide range of online tactics and strategies aimed at increasing brand visibility, driving website traffic, generating leads, and ultimately, converting those leads into customers.
https://nidmindia.com/
Joint ad trade letter to ag becerra re ccpa 1.31.2019
1. January 31, 2019
The Honorable Xavier Becerra
Attorney General, State of California
1300 I Street
Sacramento, CA 95814
Dear Attorney General Becerra:
As the nation’s leading advertising and marketing trade associations, we collectively
represent thousands of companies, from small businesses, to household brands, across every
segment of the advertising industry, including a significant number of California businesses.
Our members engage in responsible data collection and use that benefit consumers and the
economy. We believe privacy deserves effective protection in the marketplace.
We strongly support the objectives of the California Consumer Privacy Act (CCPA), but
we have notable concerns around the likely negative impact on California consumers and
businesses from some of the specific language in the law. We provide this initial comment to
provide you with information about the significant importance of a data-driven and ad-supported
online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your
attention to several areas that can be addressed and improved through the rulemaking process.
We will provide more detailed comments over the coming weeks.
I. The Data-Driven and Ad-Supported Online Ecosystem Benefits Consumers and Fuels
Economic Growth
The free flow of data online fuels the economic engine of the Internet, creating major
consumer benefit. For decades, online data-driven advertising has powered the growth of the
Internet by funding innovative tools and services for consumers and businesses to connect and
communicate. Data-driven advertising supports and subsidizes the content and services
consumers expect and rely on, including video, news, music, and much more, at little or no cost
to the consumer. Companies also collect data for numerous operational purposes including ad
delivery and reporting, fraud prevention, network enhancement, and customization. These uses
are necessary for a seamless cross-channel, cross-device consumer experience and a functioning
digital economy.
As a result of this advertising-based model, the Internet economy in the United States has
rapidly grown to deliver widespread consumer and economic benefits. According to a recent
study conducted for the Interactive Advertising Bureau (IAB) by Harvard Business School
Professor John Deighton, the U.S. ad-supported Internet created 10.4 million jobs in 2016,1
and
1
John Deighton, Economic Value of the Advertising-Supported Internet Ecosystem (2017) https://www.iab.com/wp-
content/uploads/2017/03/Economic-Value-Study-2017-FINAL2.pdf.
2. the data-driven ad industry contributed $1.121 trillion to the U.S. economy that year, doubling its
contribution over just four years and accounting for 6 percent of U.S. gross domestic product.2
Consumers have enthusiastically embraced the ad-supported model, and they have
actively enjoyed the free content and services it enables. They are increasingly aware that those
services are enabled by data collected about their interactions and behavior on the web and in
mobile applications, and they support that exchange of value. In fact, a Zogby survey
commissioned by the Digital Advertising Alliance (DAA) found that consumers assigned a value
of nearly $1,200 a year to common ad-supported services, like news, weather, video content, and
social media. A large majority of surveyed consumers (85 percent) stated they like the ad-
supported model, and 75 percent indicated that they would greatly decrease their engagement
with the Internet were a different model to take its place.
II. Our Members Have Long Been Champions of Consumer Privacy
Consumer trust is vital to our members’ ability to successfully operate in the marketplace,
and they take that responsibility seriously by engaging in responsible data practices. A prime
example of this commitment is through the Digital Advertising Alliance YourAdChoices
Program. The DAA created and enforces a self-regulatory code for all companies that collect or
use data for interest-based advertising, based on practices recommended by the Federal Trade
Commission (FTC) in its 2009 report on online behavioral advertising.3
The Principles in that code provide consumer transparency and control regarding data
collection and use of web viewing data, application use data, and precise location data.
Importantly, the YourAdChoices Program and the DAA Principles are a novel kind of industry-
led initiative whereby all companies engaging in the described practices are subject to
established privacy safeguard obligations. Also, the DAA Principles are independently
monitored and enforced. To date, more than 90 compliance actions have been publicly
announced.
The DAA Principles include rules around the collection and use of web viewing data for
advertising and restrictions for purposes beyond advertising;4
strong prohibitions on the use of
such data for eligibility purposes for employment, insurance, credit, and healthcare treatment;5
and detailed guidance around the application of the Principles in the mobile6
and cross-device7
environments. Most recently, to provide users with increased transparency about the source of
2
Id.
3
DAA, Self-Regulatory Principles for Online Behavioral Advertising (July 2009); FTC, FTC Staff Report: Self-Regulatory
Principles For Online Behavioral Advertising (Feb. 2009).
4
DAA, Self-Regulatory Principles for Multi-Site Data (MSD) (Nov. 2011).
5
DAA, MSD, 4-5 (Nov. 2011); DAA, Application of Self-Regulatory Principles to the Mobile Environment, 31-32 (Jul. 2013).
6
DAA, Application of the Self-Regulatory Principles to the Mobile Environment (Jul. 2013).
7
DAA, Application of the Self-Regulatory Principles of Transparency and Control to Data Used Across Devices (Nov. 2015).
3. the political advertising they see online, the DAA released guidance on the application of the
Principles of transparency and accountability to political advertising. 8
The main avenue through which consumers receive disclosures and choices is through the
DAA’s YourAdChoices icon , which is served in or near ads over a trillion times per month
worldwide. The YourAdChoices icon provides transparency outside of the privacy policy, and
clicking on it allows consumers to access simple, one-button tools to control the future collection
and use of data for interest-based advertising. Consumer awareness and understanding of the
program continues to increase, and a 2016 study showed more than three in five consumers (61
percent) recognized and understood what the YourAdChoices Icon represents.9
The effectiveness of the Self-Regulatory Program also has been recognized by the United
States government. At a 2012 White House event, Obama Administration officials including the
then FTC Chairman and Secretary of Commerce publicly praised the DAA’s cross-industry
initiative. The DAA approach has also garnered kudos from the leadership at the FTC under both
recent administrations for the program’s pioneering privacy work.10
III. Consumers & Businesses Would Benefit from Clarification Concerning Certain CCPA
Provisions
While our members strongly support the CCPA’s intent to give consumers a choice about
how their personal data is shared, we are concerned about the negative impact of certain sections
of the CCPA and believe the law could be clarified through rulemaking to provide improved
consumer protection and guidance to business. Such issues as the scope of the definition of
personal information, the potential elimination of loyalty programs due to the non-discrimination
requirements, and others continue to be not only problematic for the advertising community, but
will also result in unintended harm to consumers. We highlight a few of our concerns here, and
will provide more detailed comments on these points and others in the coming weeks.
• Section 1798.115(d) of the CCPA prohibits a company from selling consumer personal
information that it did not receive directly from the consumer unless the consumer has
received “explicit notice” and is provided an opportunity to exercise the right to opt out
of that sale. We urge the AG to recognize that a written assurance of CCPA
compliance is sufficient and reasonable.
8
DAA, Application of Self-Regulatory Principles of Transparency & Accountability to Political Advertising, (May 2018).
9
DAA, Consumers' recognition of the AdChoices Icon -- and understanding of how it gives choice for ads based on their
interests -- continues to rise (Sep. 29, 2016) https://digitaladvertisingalliance.org/blog/icon-you-see-yeah-you-know-me-0.
10
The White House recognized the Self-Regulatory Program as “an example of the value of industry leadership as a critical part
of privacy protection going forward.” The DAA also garnered kudos from then-Acting FTC Chairman Maureen Ohlhausen who
stated that the DAA “is one of the great success stories in the [privacy] space.” In its cross-device tracking report, the FTC staff
also praised the DAA for having “taken steps to keep up with evolving technologies and provide important guidance to [its]
members and the public. [Its] work has improved the level of consumer protection in the marketplace.”
4. • Sections 1798.105 and 1798.120 of the CCPA allow consumers entirely to opt out of
the sale of their data or delete their data; but the law does not explicitly permit a
business to offer a consumer the choice to delete or opt out regarding some, but not all,
of their data. We request that the AG clarify that businesses may offer reasonable
options to consumers to choose the types of “sales” they want to opt out of, the
types of data they want deleted, or to completely opt out—and not have to just
provide an all-or-nothing option.
• Section 1798.110(c) of the CCPA arguably requires a business’ privacy policy to
disclose to a consumer the specific pieces of personal information the business has
collected about that consumer. We ask the AG to clarify that a business does not
need to create individualized privacy policies for each consumer to comply with
the law.
Without clarification and adjustments, these and other ambiguities in the law could result in
reduced choice and privacy for consumers, rather than expanding it, as the law intended. We
stand ready to work with you to find solutions to these and other issues as you prepare for its
implementation. To the extent that there are needed changes in the CCPA to protect consumer
privacy and other important interests that cannot be rectified by this rulemaking, but are better
suited for legislation, we urge you to make such recommendations to the California Legislature.
Sincerely,
Dan Jaffe
Group EVP, Government Relations
Association of National Advertisers
202-296-2359
Christopher Oswald
SVP, Government Relations
Association of National Advertisers
202-296-2359
Clark Rector
Executive Vice President-Government
Affairs
American Advertising Federation
202-898-0089
David Grimaldi
Executive Vice President, Public Policy
Interactive Advertising Bureau
202-800-0771
Alison Pepper
Senior Vice President
American Association of Advertising
Agencies, 4A's
202-355-4564
David LeDuc
Vice President, Public Policy
Network Advertising Initiative
703-220-5943