This post is written by Max Ochoa, Turn's General Counsel. As part of his responsibilities, Max oversees our compliance with all privacy regulations.
Turn was featured this weekend in a New York Times article that covered online real-time bidding technology. In the physical edition of the paper, it was the cover story of the Sunday Business Section. Through a phone interview with our CEO and an in-person meeting, we provided our perspective to the reporter as well as a demonstration of our platform.
While we applaud the article’s attempt to educate consumers about the ecosystem that helps support the vibrant, dynamic, and largely free world of digital content, we believe it failed to accurately convey some important points. We also believe The New York Times missed an opportunity to help people who may share the very concerns the article raised.
Turn would like to give our perspective on a few of the more eye-catching ones. We also take up the educational baton from the New York Times and provide people who are creeped out by the concept of online behavioral advertising with the tools to opt-out. Read on!
YOU FOR SALE. YOU can be sold in seconds.
While this is an attention-grabbing lead, it’s also inaccurate. Turn neither condones nor facilitates targeting personally identifiable information (PII) about an individual without their prior affirmative and express opt-in consent.
What is PII? It’s specific information that enables anyone to proactively contact you, either by using the data itself (e.g., your name, address, telephone number) or by using the data as a mechanism to look up the information required to contact you (e.g., your credit card, drivers’ license or social security number).
Our technology only uses anonymous information. We also contractually require our data and inventory partners to send us only anonymous information. Furthermore, Turn is not only a member of, but also an active contributor to, the many industry groups (IAB, DAA, and NAI) that are leading the way to implement and enforce guidelines to safeguard consumer privacy. Finally, Turn voluntarily submits to periodic audits to ensure strict compliance with the industry’s rules about handling PII.
In short, “you” cannot be purchased by Turn in seconds because we don’t know who you are – just like the famous New Yorker cartoon says.
We believe there are many benefits to interest-based, relevant advertising. But if you don’t want to see it, you can opt-out! You can opt-out directly from the Turn web site, from a publisher’s web site, through the DAA or NAI websites, or through an “Ad Choices” icon directly on the advertisement itself. Keep in mind that even if you opt-out, the websites you love still need to get paid for the content you enjoy. This means you will still see ads. They just will be less likely to interest you.
We are surprised the Times never once mentioned opt-out in the article.
Yet the prospect of ubiquitous real-time bidding — online, on mobile devices and eventually on Web-enabled televisions — also hastens our transition to a totally traceable society. What we read and how we spend our spare time used to be private. Now those activities are becoming windows through which marketers scrutinize, appraise and vie to influence us for a price. Soon there may be no personal spaces left for our private thoughts.
This portion of the article imagines a golden time before the Internet, when no one knew what you were up to. This is inaccurate. Data about consumers has been gathered, used, and sold for a long, long time. Acxiom, one of the world’s largest aggregators of personal information, has been around since 1969.
Credit card companies and offline retailers like Target know a lot about you, possibly even that your teenager is pregnant before you find out. Give to one political organization, and you find yourself getting requests for donations from others you’ve never heard of.
Nearly every offer you receive in your postal mailbox at home today has been targeted with information that far exceeds the level of detail used in online display advertising. But it’s very difficult to opt-out of that level of tracking offline. Conversely, it is incredibly easy to opt out of online interest-based advertising. Just opt-out, opt-out, and opt-out.
Krux also warned Web site operators about what it called “rogue data collection.” When publishers allow third parties, like real-time bidding platforms or information resellers, to collect data on their site, the report said, those partners often bring in other data miners whose practices the sites themselves cannot control. Those middlemen may use a site’s proprietary data to help competitors, the report said.
Advertisers using the Turn platform cannot build behavioral profiles based on data that publishers send to the platform. Further, we fully endorse and abide by the IAB Standard Terms and Conditions for web-site data collection to ensure that no publisher data is leaked or used in the advertising bidding process.
We are surprised that a fellow member of the IAB would make such an ominous comment to scare prospects into adopting their commercialized tag management solution. It is a shame that Krux failed to acknowledge and support all of the efforts already taking place at the IAB to ensure the described scenario never happens.
It is becoming a huge imbalance for the ordinary user because, in the end, the ordinary user is the product.
Since the beginning of media, there has always been a tacit agreement between consumers and publishers. Consumers get free access to high quality print, TV and radio content in exchange for receiving messages from advertisers. This exchange – you get to watch CSI, we show you commercials – has funded the expansion of a multi-billion dollar industry that has entertained people with classic radio and TV series, amazing sports content, and a vibrant news industry that is a critical pillar of our society. Imagine what would have happened if all content was subscription based. Would TV have taken off as an entertainment medium if our grandparents had to pay to watch the Honeymooners, or Lucy and Desi? Would we have as many professional news outlets as we do today?
In our opinion, true imbalance would be allowing a website (high-culture or low) to succeed only if it amassed enough paying subscribers. The advertising industry enables the free and open Internet, where entertainment and editorial content is a hit or a bust based on its merits, not the economic status of its audience.