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Blog
Facebook’s DSP: Will the Data Be Enough in a Programmatic World?
If Facebook is starting a DSP, then programmatic has certainly left the niche. But is the social network’s first-party data enough? Kevin Tan, CEO, Eyeota, looks at the future.
Programmatic has emerged from the outer echelons of the ad-tech world and taken its place on advertising’s main stage. The industry is now on board with what the experts have known all along – that programmatic’s real-time audience insights are the best foundation for effective campaigning. The shift from niche to normal is largely attributable to the technology’s ability to respond to what today’s marketers want and what brands need: to target campaigns on audience, not just content. But programmatic’s acceptance into the mainstream has also been helped along by the decision of technology’s most influential players to step into the arena. This month’s news that Facebook is rolling out a Demand-Side Platform (DSP) in early 2016 to perform programmatic buys using their ‘people-based’ advertising approach confirms the value of audience data-driven targeting in digital advertising. Although the details of Facebook’s DSP product (the fourth element in its ad platform business) have yet to be publicly announced, the strength of the company’s first-party audience data and cross-device insights will hold considerable appeal for marketers looking to send more messages to consumers in more places online. The move is a clear sign that programmatic has matured and that targeting audiences is advertising’s new currency. This is not only evident online, but increasingly in traditional offline channels too, such as television. In a landscape that is evolving so quickly, how will Facebook’s DSP compete? Will its first party data – undoubtedly strong, but nonetheless limited – be compelling enough for advertisers who can’t afford to miss a trick when it comes to campaigning to evermore sophisticated audiences? First-party data alone won’t be enough to reach the right people in the right place at the right time. Audience-based campaign targeting must tick all of these boxes; compromising on any area will be detrimental to success. Marketers will need to mix Facebook’s data with high-quality third-party audience data from independent providers to tailor particular messages in specific contexts to consumers – about whom they will have a complete picture. Understanding – really understanding – who consumers are and what they think of brands allows marketers to design communications strategies with a human element. This is critical in an era where consumers call the shots. Treating consumers as real people, not compilations of data, is as important as discovering real insights about them. And these insights live within a wide range of data types that go beyond the first-party nature of Facebook’s user profiles. --- Full article available at http://bit.ly/1QeiacX (link is external) -
It is no secret the consumption of media has changed. Consumers are now interacting with brands not only in-store and online but through a multitude of devices. The opportunity for brands to connect with consumers with relevant messages, in real-time has never been more prevalent, but brands are still challenged with effectively reaching on-the-go consumers. As marketers try to effectively reach consumers across channels where do the best opportunities lie? Facebook® is undoubtedly one platform that represents a huge opportunity to reach on-the-go consumers. According to Facebook’s most recent earnings report (link is external) 526 million of its monthly active users access Facebook solely on their mobile devices – this represents about 38% of Facebook’s 1.39 billion monthly active users. Have you considered how you can better target people who are highly engaged on Facebook? Even more astounding is the ability to reach the remaining 62% (864m) regardless of the device they are using. Facebook’s capabilities for cross-device targeting at the individual level are unparalleled – they are one of the few places where a person’s entire experience is in an authenticated environment, regardless of platform. The power of Facebook targeting lies within its unparalleled reach and engagement, the ability to reach real people and its large set of Facebook interests and demographics data. To further help marketers, Facebook is restructuring its partner program – Facebook Marketing Partners – in an effort to make it easier for marketers to find partners based on their specific needs. Epsilon, which first began working with Facebook nearly two years ago, is a badged Facebook Marketing Partner with Audience Onboarding and Audience Data Providers specialties. These specialties help marketers better target their customers with robust data sets. What are the benefits of this partnership? Let’s look at a couple of use cases: Custom Audiences You are a subscription service provider looking to find new customers via Facebook but don’t know where to start. Why don’t you start with your own data? Custom Audiences allow you to leverage your existing CRM data and match it on Facebook in order to better target your campaign to the right people. Working with Epsilon you can upload this data – at no cost and in a privacy safe manner—and use it to target specific offers to the right people. For example, you can use your data to exclude existing customers from your campaign. Instead, target the campaign to the right users via Facebook’s News Feed where people are actively participating, engaging and discovering new information. Partner Categories For marketers looking to more deeply fine-tune their campaigns you can overlay Epsilon data to further segment your audience and reach your ideal customer. For example, you’re a nutrition company looking to find the best customers for your new weight-loss shake. Using Epsilon’s lifestyle and interests Partner Categories you are able to target people on Facebook who are interested in nutrition, diet, and fitness, and are also on smart phone. Because Epsilon’s lifestyle and interests information is self-reported and reinforced with actual transaction data, it’s extremely accurate in providing valuable information into segmenting your target audience. --- Full article available at http://bit.ly/1HUgehQ (link is external)
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Blog
Ten Questions that the Federal Trade Commission Should Answer on Cross-Device Online Tracking of Individuals.
1. Why has the FTC waited so long to review this serious threat to our privacy? The Federal Trade Commission’s November 16, 2015, workshop (link is external) on cross-device tracking is a examination of a very disturbing practice that emerged several years ago. The online industry’s business model of identifying specific individuals and following them on whatever device they may use (PCs, mobile, etc.), so their behaviors can be analyzed for more effective micro-targeting, is well-known. For example, companies such as Drawbridge, which “track how [an] individual user traverses the web on his or her smartphone, tablet, laptop and PC,” and analyze “billions” of pieces of data on us, has been around since 2010.[1] Cross-device targeter Tapad has been operating since 2011.[2] During the last few years there has been a veritable explosion of cross-device tracking of individuals—illustrating how our privacy has been lost regardless of what device we may use.[3] The FTC should be monitoring much more closely industry developments to expand their data-driven profiling and targeting techniques. The serious erosion of our privacy is reported daily by leading trade publications and is not a secret.[4] The commission—and other agencies responsible for consumer privacy, such as the FCC and CFPB—need to become much more proactive if they are to actually protect the public. 2. Why isn’t the FTC bringing complaints against both Google and Facebook under their respective “consent decrees” for their own cross-device surveillance of consumers? Both Facebook and Google—as the two dominant online marketing companies—have significantly expanded their own collection, analysis, and use of data from individuals for cross-device tracking. Both companies are under 20-year legal agreements with the FTC that is supposed to ensure that their practices protect our privacy.[5] But the commission has been silent regarding a major violation of our privacy, given the range of Facebook and Google cross-device practices. For example, Facebook’s acquisition of Atlas and its incorporation of new ways to engage in cross-device tracking have not been challenged by the agency.[6] Nor has the FTC pursued Google’s cross-device tracking as a consent decree matter.[7] The commission’s consent decrees are only as good as their enforcement. The FTC’s inaction regarding Facebook’s and Google’s expansion of cross-device data harvesting undermines its claims that its decrees actually protect our privacy. 3. How has the FTC’s and Department of Justice’s (DoJ) failure to stop “Big Data” mergers furthered the expansion of cross-device gathering of our information? As one of two U.S. antitrust and competition regulators, the FTC plays a key role reviewing mergers and acquisitions. Yet the agency has approved Big Data-related mergers that have further weakened consumer privacy and expanded the ability of marketers to track our behaviors across devices. While the FTC’s consumer protection and competition bureaus are separate, the commission has a responsibility to protect the public. Even with mergers reviewed by the DoJ, the FTC should speak out against deals that erode privacy and place consumers at further disadvantage through the use of Big Data. For example, Oracle was allowed to acquire both BlueKai and Datalogix—significantly expanding its sources of data used to profile Americans and to engage in cross-platform targeting. Alliance Data Systems was permitted to acquire Conversant, which bolstered its cross-device applications. The FTC should acknowledge that it is helping weaken the privacy of the American public by allowing data-driven mergers to be approved without effective consumer safeguards.[8] 4. Isn’t cross-device tracking and targeting just a part of an ever-growing commercial Big Data surveillance complex that continually gathers and uses all our information? Anyone who follows the online industry recognizes that our privacy is being continually undermined. Every major company has become its own “data broker,” harvesting all the data they directly gather on a person (when you come to their site, for example). They now merge that data with the abundance of so-called third-party information available for sale or use today. A key goal is to engage in what they call “identity management, ”which means using information on us to help influence our actions, purchases, and behaviors. Cross-device tracking is made possible through the unlimited ability companies now have to use our online and offline information without any serious consideration of our privacy.[9] 5. What is the role that Big Data companies and technologies—such as Data Management Platforms (DMPs)—play in cross-device tracking of individuals? The most powerful U.S. companies are using sophisticated data engines and analytics to gather data on individuals. The growing use of technologies such as DMPs, along with the real-time data targeting now embraced by the industry (known as “programmatic”) is at the core of cross-device practices.[10] While the FTC is aware of these practices, it has not taken any actions to protect consumers.[11] 6. Isn’t the gathering of information from our use of mobile phones, including for cross-device targeting, a major privacy violation? The answer is yes. The mobile phone is the digital spy in our pockets that we take and use nearly everywhere. Gaining access and insights from our mobile phones serves as a veritable digital gold mine for brands and advertisers. Marketers continually research how we use mobile devices, in order to help their clients identify our actual or intended location, as well other data about us (such as income, race, ethnicity, and gender). Companies such as Facebook, Google, and many others have developed ingenious ways to encourage consumers to use “apps” that, once they are downloaded, report on our actions. Google, for example, explains they can help marketers understand how to take advantage of what they call a person’s “micro-moments”--when through the use of our mobile phone we reveal we are searching for a product, store, activity or location.[12] Cross-device tracking and targeting is fueled by the unchecked data gathering from our mobile devices.[13] 7. Will the FTC address how cross-device tracking is helping marketers and brands reach us when we are in retail, grocery stores, and other “real-world” locations? As we use our phone or tablet to search for information, download coupons, or scan for price information, these signals allow marketers to learn about our location and quickly connect data they have about us. So-called “hyper-location” tracking enables companies to identify what neighborhoods we live and work in, for example. As stores deploy so-called “beacons,” Wi-Fi-networks, “geo-fences,” and other ways to connect to people in and around stores, the data they gather from our use of multiple devices becomes more complex and valuable to them.[14] Online and offline distinctions are quickly fading, as cross-device tracking merges with sophisticated data targeting services. 8. Can the FTC protect consumers from cross-device tracking when we watch video online? There is an explosion of video consumption, as more people use their mobile devices to watch online video content. Internet-delivered video to TV’s (so-called “over-the-top”) is another key way we see such programming. Incorporating our video viewing as part of the cross-device tracking apparatus is the latest way our media behaviors are being closely observed, whether we watch on small or large-screen devices.[15] 9. Will the FTC investigate how consumers are tracked and analyzed by cross-device “measurement” services? Measurement is built in to today’s tracking and targeting online system. Marketers wish to know whether we see an ad or promotional message and how we responded. Since we use multiple devices, measurement techniques now reflect an analysis of what we do on all our devices. With advances in measurement having a direct impact on our privacy, as well as with the transactions we make, the commission should investigate the impact of cross-platform “attribution” techniques now broadly deployed.[16] 10. Will the FTC call on the online industry to “cease and desist” from cross-device tracking until privacy safeguards can be proposed and implemented? The online ad lobby has—for decades—worked to keep the FTC relatively powerless to protect privacy. It has opposed calls to provide the agency with “rulemaking” authority so it could develop safeguards that would protect the public.[17] The lack of FTC authority to effectively address privacy threats is a key reason why U.S. data-driven marketers are able to expand their commercial surveillance activities. Despite its lack of power to require companies to engage in a moratorium on cross-device tracking, the FTC should use its moral authority. The commission should declare that the use of cookie syncing, probabilistic or deterministic attribution, unique identifiers, and other methods of stealthily following us from device to device should not be permitted. Leading data companies such as Google and Facebook, digital marketing trade groups such as the Interactive Advertising Bureau and Mobile Marketing Association, data brokers such as Axciom, Oracle, and Merkle, and cross-platform companies such as Tapad and Drawbridge should all be asked to support the commission’s call to stop the tracking of individuals across devices. During the period established for the data-gathering moratorium, the FTC should propose safeguards. The commission’s policies should empower individuals to decide whether and how they can be tracked and analyzed on any device. It’s time for action by the FTC. It knows that Americans confront the loss of their privacy—and it should speak out against the eavesdropping practices that enable online companies to gather data on us—whether we use a PC, mobile phone, or even TV. [1] http://adage.com/article/digital/drawbridge-raises-14-million-vc-investm... (link is external) [2] http://adexchanger.com/press-release/tapad-announces/;http://techcrunch.... (link is external) [3] http://bits.blogs.nytimes.com/2013/10/10/a-senator-raises-privacy-questions-about-cross-device-tracking/?_r=0 (link is external); http://blogs.teradata.com/teradata-applications/connecting-the-dots-at-t... (link is external) http://adexchanger.com/ad-exchange-news/data-management-platforms-are-ev... (link is external) [4] https://econsultancy.com/blog/62754-cross-device-measurement-in-google-analytics-will-turn-mobile-marketing-on-its-head/ (link is external); https://www.admonsters.com/blog/fight-fragmentation-grasping-cross-device-audience-behavior (link is external); “Mobile creativity: Track mobile performance. AdMap. September 2015. Warc.com. Personal copy. [5] https://www.ftc.gov/news-events/press-releases/2011/11/facebook-settles-ftc-charges-it-deceived-consumers-failing-keep (link is external); https://www.ftc.gov/enforcement/cases-proceedings/102-3136/google-inc-ma... (link is external) [6] http://atlassolutions.com/why-atlas/cross-everything/ (link is external); http://atlassolutions.com/2015/09/02/in-app-conversion-measurement/ (link is external); http://atlassolutions.com/2015/09/17/cross-everything-dilemma/ (link is external); http://atlassolutions.com/2015/05/11/the-4cs/ (link is external); https://www.facebook.com/business/news/cross-device-measurement (link is external); http://digiday.com/platforms/omnicom-adds-atlas-tags-doubleclick-served-... (link is external) [7] http://doubleclickadvertisers.blogspot.com/2015/06/cross-device-conversion-metrics-come-to.html (link is external); http://adexchanger.com/online-advertising/google-adds-cross-device-metrics-to-doubleclick-partially-answers-facebooks-people-power/ (link is external); https://support.google.com/ds/answer/6139741?hl=en (link is external); https://www.youtube.com/watch?v=qFodrj2Drxg (link is external); http://adwords.blogspot.com/2013/10/estimated-total-conversions.html (link is external); http://adage.com/article/digital/google-tests-desktop-mobile-retargeting... (link is external) [8] https://www.oracle.com/marketingcloud/products/data-management-platform/id-graph.html (link is external); https://www.oracle.com/marketingcloud/products/cross-channel/mobile-marketing.html (link is external); http://adexchanger.com/data-exchanges/oracle-links-cross-platform-ids-touts-data-neutrality/ (link is external); http://www.bluekai.com/mobiledmp/ (link is external); http://www.tapad.com/press-release/tapads-cross-device-data-now-integrated-into-oracle-data-cloud/ (link is external); http://techcrunch.com/2015/05/04/drawbridge-cross-device/ (link is external); http://www.conversantmedia.com/digital-marketing-product-overview (link is external); https://www.quantcast.com/audience-grid/ (link is external) [9] http://adexchanger.com/mobile/google-allows-targeted-ads-based-on-first-party-data/ (link is external); http://liquid.pch.com/press/case-for-first-party-data-in-a-third-party-world/ (link is external); http://www.krux.com/blog/data-management/cross-device-identity-management-the-path-to-one-to-one-marketing/ (link is external); http://www.merkleinc.com/what-we-do/marketing-technology/merkle-data-management-cloud/connected-recognition#.Vkjj7craNyo (link is external); http://www.drawbrid.ge/technology (link is external); [10] https://www.neustar.biz/marketing-solutions (link is external); https://www.neustar.biz/blog/cross-device-dmp-as-the-unifying-layer-in-the-adtech-stack (link is external); http://www.lotame.com/resource/the-cross-device-question/ (link is external); http://blogs.adobe.com/digitalmarketing/digital-marketing/adobe-audiencemanager-takes-cross-device-targeting-new-level/ (link is external); http://www.mediapost.com/publications/article/237039/cross-device-marketing-no-longer-hypothetical-use.html (link is external); https://radiumone.com/products/advertiser/programmatic/ (link is external); http://www.digilant.com/digilant-announces-partnership-with-crosswise-to... (link is external) [11] http://www.mediapost.com/publications/article/242295/ftc-consumer-protec... (link is external) [12] http://www.nielsen.com/us/en/press-room/2015/exelate-expands-its-mobile-user-dataset-by-billions-of-monthly-interactions-with-pushspring.html (link is external); https://www.thinkwithgoogle.com/topics/mobile.html (link is external); https://developers.facebook.com/docs/app-ads/measuring/installs-and-in-app-conversions (link is external); http://doubleclickadvertisers.blogspot.com/2015/11/active-view-updates-improved-cross.html (link is external); https://www.fiksu.com/about/news-releases/precision-audience-targeting-w... (link is external) ; https://www.kochava.com/aol-partners-kochava-expand-programmatic-targeting-attribution-mobile-apps/ (link is external); http://adexchanger.com/mobile/kochava-attempts-to-crack-the-cross-device-attribution-code/ (link is external); https://www.fiksu.com/technology/audience-targeting (link is external); http://www.pushspring.com/news.html?post=124 (link is external) [13] http://streetfightmag.com/2015/06/02/why-cross-device-matching-will-transform-the-mobile-advertising-industry/ (link is external); http://www.marinsoftware.com/resources/whitepapers/the-cross-device-targeting-playbook-for-display-advertisers (link is external); http://www.marinsoftware.com/resources/whitepapers/the-cross-device-targ... (link is external) [14] http://www.criteo.com/resources/cross-device-advertising-how-to-navigate-the-next-big-opportunity-in-mobile-marketing/ (link is external); http://developer.android.com/training/location/geofencing.html (link is external); http://www.aislelabs.com/blog/2014/04/29/aislelabs-launches-the-first-marketing-automation-platform-for-physical-retail-locations/ (link is external); http://www.huffingtonpost.co.uk/jon-buss/cross-device-use_b_6969120.html (link is external) [15] http://www.experian.com/marketing-services/cross-device-video-analysis.html (link is external); https://www.doubleclickbygoogle.com/articles/?category=video&product=all&type=whitepaper (link is external); http://www.videologygroup.com/industry-insights/P40/programmatic-tv-driving-multi-screen-conversation/#.VkjyoMraNyo (link is external); https://www.tubemogul.com/cross-channel-advertising/ (link is external) [16] http://adexchanger.com/digital-tv/comscore-dives-deeper-into-cross-platform-video-measurement/ (link is external); http://cimm-us.org/cimms-annual-summit-examines-cross-platform-media-mea... (link is external) https://www.comscore.com/Products/Advertising-Analytics/validated-Campai... (link is external) [17] https://www.democraticmedia.org/content/how-industry-lobbyists-help-kill... -
Blog
How Industry Lobbyists Help Kill Strong FTC role on privacy and consumer protection
IAB, DMA, and ANA all lobbied against FTC provisions in the financial regulatory reform bill.
Language strengthening the Federal Trade Commission has been removed from a newly-merged financial regulatory reform bill (link is external). The FTC provisions in the federal legislation were opposed by numerous advertising and business groups, among them the Interactive Advertising Bureau, Direct Marketing Association, Association of National Advertisers, and U.S. Chamber of Commerce. The DMA and ANA released statements praising removal of the FTC enforcement provision and suggesting their lobbying efforts helped bring about the change. The legislation was sponsored by Senate Banking Chairman Christopher Dodd of Connecticut and House Financial Services Chairman Barney Frank of Massachusetts, both Democrats. "DMA led the charge in the fight to keep these FTC expansion provisions out of the Restoring American Financial Stability Act...as the final text of the bill was negotiated by a formal Conference Committee," the organization said in a June 25 statement. The DMA went on to stress that it "will remain vigilant until the bill has been signed by the President." During the conference period, Democratic Congressmen Henry Waxman and Bobby Rush were "very forthcoming that their number one priority was going to be to reinsert the [FTC] provision," according to Chris Merida, director of congressional and public affairs for the U.S. Chamber of Commerce. House and Senate conferees who negotiated the merged bill worked from the Senate's version, which did not include the FTC language. The House version did. Merida said the push to include the provision prompted PR campaigns on both sides of fight. Mike Zaneis, the IAB's VP of public policy, said this was the "number one legislative priority" for the trade group. Despite the fact that online privacy legislation has made more headlines, Zaneis described the inclusion of the FTC provision in the financial regulatory reform bill as the "one legislative vehicle that was moving and had at least a likelihood of passing." If the FTC is given the broader authority, it could "just move unilaterally," making the threat of overreaching privacy legislation moot. --- Full article available at http://bit.ly/1NQ1Z49 (link is external) -
Blog
Rubicon Project Launches Washington, D.C. Office; Announces Key Roles Supporting Political Campaign and Advocacy Advertising
Global Technology Company Poised for Growth in Watershed 2016 Election Cycle
Los Angeles & Washington, D.C – July 22, 2015 — Rubicon Project (NYSE: RUBI) a global technology company leading the automation of advertising, announced today the opening of an office in Washington, D.C. Theresa Mueller, previously of Rocket Fuel and a recognized leader in political and advocacy digital advertising, will spearhead the growth of the new office. Digital advertising will be a major source of political ad spend in the 2016 elections, as campaigns increasingly realize the value of big data and analytics to precisely target voters and activists. According to Reuters estimates (link is external), U.S. digital political advertising could quadruple to nearly $1 billion in the 2016 election. And 85 percent of political agencies plan to use programmatic ads for their political media-buying efforts in 2015, according to a STRATA political survey last year (link is external). Recently named by Quantcast as having the largest worldwide reach of any advertising platform with an audience of more than 650 million globally, Rubicon Project’s platform has been helping candidates and campaigns reach and engage key voters for years. In opening a D.C. office, Rubicon Project brings unmatched scale and transparency to the rapidly growing campaign frontier in ad tech. Rubicon Project’s relationships with the most respected publishers and application developers will ensure that campaign ads are delivered transparently in the most premium environments. “2016 represents a watershed moment for digital advertising as campaigns and advocacy groups seek new and targeted ways to engage, persuade and ultimately turn out voters in the most competitive electoral landscape in recent history,” said Dallas Lawrence, Senior Vice President and Head of Communications for Rubicon Project, who will also serve as the company’s senior political advisor supporting campaign strategy and advocacy outreach. “Rubicon Project’s leading technology offers a key competitive advantage for campaigns seeking innovative and scalable targeting capabilities, proven big data insights and the largest audience reach of any independent advertising platform in the market today to support recruiting, fundraising, messaging and GOTV efforts throughout the primary and general election season.” Rubicon Project’s first strategic move was to hire Theresa Mueller to head political sales in the DC market. Previously, Mueller was a key member of the advertising technology company Rocket Fuel’s D.C. operations. Between the sales side and buyer side, at APCO Worldwide and Ogilvy Washington, Mueller has worked with hundreds of political and advocacy clients to craft their digital advertising strategy, including work with national political candidates, ballot initiatives, pharmaceutical, financial, healthcare, and consumer goods companies as well as a commercial airliner and a major oil company. “Rubicon Project’s growth into Washington’s political and advocacy arena is a significant development for buyers looking to benefit from both the latest digital advertising technology as well as a massive ability to reach and engage voters via the most premium media in the country,” said Erik A. Requidan, Vice President of Sales and Programmatic Strategy for Intermarkets, Inc. “The announcement that Theresa Mueller – a recognized leader in the political and advocacy digital advertising – will be leading Rubicon Project’s political and advocacy efforts is a significant win for the company. I have had the opportunity to work with Theresa over the past several years on both the buyer and seller side of the business and I have no doubt that combining her leadership with Rubicon Project’s capability to help campaigns reach, engage and persuade voters on any device at any time in any location will be a real game changer for 2016 and beyond.” ---- Full article available at http://bit.ly/1SIMxqt (link is external) -
The Collective brings top Publishers and savvy Advertisers together for the most efficient audience targeting in the mobile industry. Kochava, in collaboration with Appia, AdXcel, Altrooz and Liquid, is excited to announce the largest and first-ever collection of cross-publisher mobile audiences. How it Works Advertisers create segments via the Audience API by querying the billions of devices within the Collective and its robust data model. These segments are then matched to the best Collective media sources. Identify Your Audience Identify an audience that matches your existing users within the Collective. Build a lookalike segment that matches the attributes of your existing audience. Target Your Audience Tailor your ideal audience down to the most specific detail. Review the optimal publisher distribution based on Collective data and customize, if desired. Export your target segment across the selection of publishers with the click of a button. --- Full article available at http://bit.ly/1WM3vEJ (link is external)
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Blog
PushSpring Launches Audience Console™ to Enable Marketers to Quickly Build Custom Mobile App Audiences
SEATTLE (September 28, 2015) PushSpring, the first and largest independent app-based mobile audience platform, today announced the launched of a beta version of the PushSpring Audience Console™ that allows selected mobile app owners, marketers and agencies to quickly build custom audiences to reach mobile app(s) users at significant scale. PushSpring’s Audience Console provides advertisers and app publishers with mobile app audience data for more than 100 million unique device IDs in the US, and leverages billions of mobile app data signals and industry standard audience segments to develop PushSpring Personas. Within the PushSpring Audience Console, advertisers and app publishers can select from 150 pre-built audience segments, app genres or custom segments to compare and build audiences across four categories of consumer dimensions: Life Stage, Interest & Activity, Intent and Demographic. Marketers can also use PushSpring’s Audience Console and its custom segment creation tool to identify unique characteristics of their own app audiences and augment that first party data with PushSpring Personas to create more highly targeted segments, based on validated attributes. “PushSpring’s Audience Console enables our partners to independently and easily create custom target audiences based on our own Personas, app presence or ownership, demographics, and device data such as type, platform, carrier, and location. PushSpring customers can then export IDFA and AAID custom audiences for nearly immediate use in their campaigns across available partner platforms such as Google’s DoubleClick Bid Manager, The Trade Desk, and Centro DSP,” says Karl Stillner, PushSpring’s Chief Executive Officer and Co-Founder. “We will collect feedback during the Beta phase to refine the Audience Console to effective audience targeting and ease-of-use.” o enhance the accuracy of Personas, PushSpring distills billions of validated, mobile device-level data signals such as device make/model, operating system, apps on device, language setting, and location data. These can be matched to census and other third party data to deduce income, age, gender, and many other consumer attributes. PushSpring’s primary signals for Personas are app ownership and changes in app ownership. For example, real estate buyers and mortgage shoppers are typically categorized when a device ID shows the presence or recent installation of real estate buying and mortgage calculator apps. PushSpring’s underlying source data is unique because it includes signals from apps that do not serve ads. For example, PushSpring is able to provide validated signals that identify whether a device has the presence of ad-free apps like Fidelity Investments or United Airlines, etc. App genre segments and real-time custom segment creation are also included in PushSpring’s data offerings. --- Full article available at http://bit.ly/1Pf1SQY (link is external) -
In a deal being announced today with one of the world’s largest aggregators of mobile user identities and behaviors, Nielsen’s eXelate unit will dramatically expand its footprint of data identifying mobile users. The deal is significant because eXelate is already one of the dominant data management platforms (DMP) and exchanges enabling brands and publishers to identify and target consumers with digital ads online -- and increasingly in mobile. It is also significant because it enables Nielsen’s eXelate to dramatically increase its coverage of the mobile user universe at a time when the power of identifying and targeting mobile users appears to be shifting to so-called “walled gardens” -- especially Google and Facebook -- that are able to leverage their user log-ins and extend their reach to the universe of mobile apps and users that integrate with it. The agreement with Seattle-based PushSpring will enable both companies to make more of a market out of PushSpring’s data, which processes “billions of monthly mobile app and device-level signals.” Company executives said they didn’t know exactly how much the deal would boost eXelate’s coverage of the mobile user universe, or even how big the universe actually is -- after factoring for the complex nature of cookie and device inflation, redundancy and deflation factors. But they offered to come up with an estimate and provide it to MediaPost in the near future. --- Full article available at http://goo.gl/mlF2kT (link is external)
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37th International Conference of Data Protection and Privacy Commissioners Amsterdam, The Netherlands We join together this week in Amsterdam, celebrating the success of Max Schrems in the case before the European Court of Justice concerning Safe Harbor. NGO leaders around the world have expressed support for Max’s courageous legal battle, and we have praised the landmark judgment of the Court. The Court of Justice reaffirmed the fundamental rights of privacy and data protection in our modern information economy. The Court made clear the responsibility of national data protection agencies to safeguard fundamental rights. We also recognize the important work underway by privacy officials, civil society, and innovators around the globe to safeguard personal freedoms. The challenges to privacy and data protection are never ending. We acknowledge and thank those who work to make our lives a little safer and a little more secure. Within the NGO Community, we have worked for many years to advance the right to privacy. Beginning in 1999, the TransAtlantic Consumer Dialogue (TACD) first called attention to the weaknesses of the Safe Harbor regime. We urged lawmakers to update privacy laws and address growing concerns among consumers about data abuse. Ten years later, the Public Voice gathering at the Commissioners conference in Spain issued the Madrid Privacy Declaration, widely endorsed by NGOs and experts around the world. More recently, civil society leaders on both sides of the Atlantic have called for new legal protections to end mass surveillance and to restore trust and confidence in the digital economy. It is against this background that we express concern about the conference this year in Amsterdam. We were surprised and disappointed that the conference organizers this year focused on a report recommending actions that would do little to change the business or government behavior that threatens privacy and data protection. The report recommends no substantive changes in law. Particularly after the Safe Harbor decision, the “Bridges report” is remarkably out of touch with the current legal reality and what we need to do to address it. The failure of the Amsterdam conference to engage with the many new challenges, from “Big Data” to drone surveillance, is also a lost opportunity. The practical consequence of focusing instead on failed policies, such as self- regulation, will be to make more difficult the work of the privacy experts around the world who could have otherwise benefitted from a meaningful discussion about how to move forward on legislation, aggressive enforcement, and other steps that are long overdue. Yes, they are difficult; all the more reason why we need to act now. Digital rights organization and consumer NGOs call on the Data Protection Commissioners to refocus their attention on the need to update and enforce privacy law. There is a long tradition of civil society engagement with the annual conference. There has always been a “constructive tension” between the Data Protection commissioners and civil society. But we have always shared a common goal – the strengthening of fundamental rights and the protection of privacy and data protection. Toward those objectives, we remain united. We look forward to conferences that actively support and encourage discourse with civil society about the future of privacy and data protection. --- Full statement in the attached document.
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This unique interdisciplinary conference is taking place October 23-26 at the intimate venue of the Oudemanhuispoort in the heart of Amsterdam, The Netherlands. It is organized by the Amsterdam Platform for Privacy Research (APPR), an initiative of the University of Amsterdam with active participants from such diverse disciplines as philosophy, law, economics, informatics, social sciences, medical sciences and media sciences. APC 2015 will bring together leading experts in the field of privacy who will formulate, discuss and answer the challenging privacy questions that lie ahead of us. APC 2015 offers both parallel and keynote sessions. Confirmed keynote speakers are: Anita Allen, Bill Binney, Julie Brill, Gabriella Coleman, Amatai Etzioni, Viktor Mayer-Schönberger, Deirdre Mulligan, Helen Nissenbaum, Peter Schaar, Max Schrems, Ashkan Soltani and Latanya Sweeney. For the full conference program, please click here. (link is external)
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Leading the digital resolution Today consumers move seamlessly between their desktop, laptop, mobile phones, and other connected devices. Depending on which site a consumer visits, what they're doing, if they're on an app or a mobile browser, there are different identifiers used. Because there isn't a consistent way of identifying consumers, marketers often see these people as different people, or, in some cases, not at all. Digital identification is the key to understanding the consumer journey, and the Identity Manager (link is external) accomplishes this via device recognition and digital identification resolution. Device recognition Device recognition is accomplished through a comprehensive statistical device-level identifier. Our proprietary statistical ID expands audience visibility where cookies and other identifiers are ineffective. This is a privacy compliant way to identify the uniqueness of a device based on statistical analysis. Digital identification resolution The process of digital identification resolution enables a customer to recognize, connect and resolve identification data to understand consumers across their devices and environments. Customers use their own data in conjunction with device recognition capabilities to reconcile the information to correspond to a single device, or a group of devices utilized by an individual or household. Benefits of device recognition and digital identification resolution include: Synchronized anonymous ID – Our proprietary statistical ID gives customers the ability to recognize the same device anonymously across all digital touch points in the ecosystem. Bridging capabilities - connect web events and app events coming from the same device. Technology and platform agnostic - works with all types of devices regardless of type, browser, platform, or other environments, including emerging technologies. --- Full article available at http://bit.ly/1GolPwf (link is external)
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Drawbridge understands consumers. A lot of companies can say that, but we take it a step further. In fact, we can actually predict consumer behavior. Is that even possible? Because we know how people use their devices to get information about things they are interested in, we understand their patterns, tendencies, intentions and goals even before they do. This enables us to provide our customers with the most comprehensive understanding of their customers, on a one-to-one basis. Drawbridge has built the first effective cross-device identity technology. We bridge data from personal computing devices, mobile devices, and emerging devices to reach more than one billion consumers across more than three billion devices. The Drawbridge Connected Consumer Graph is constructed using machine-learning algorithms that observe and process vast amounts of data. Identity: The Drawbridge Connected Consumer Graph includes more than 1.2 billion consumers connected across more than 3.6 billion devices to date, with accuracy verified at 97.3%. This cross-device identity framework forms the base of the entire Drawbridge platform. Data: Drawbridge enables marketers to enhance their understanding of consumers for cross-device marketing purposes – extending desktop data across mobile devices and vice versa. This holistic consumer view is achieved by layering first- or third-party audience segments, location attributes, CRM data, and other custom attributes with the Connected Consumer Graph. Reach: Drawbridge has built a proprietary cross-device targeting, pricing, and optimization engine, as well as a cross-device bidder to maximize consumer reach across devices. Attribution: Drawbridge provides brands with a complete, 360-degree view of their audiences, giving marketers the ability to measure cross-device influence and attribute consumer actions online and offline. --- For more about Drawbridge visit http://bit.ly/1ZXmOzr (link is external)
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Mondelez International has renewed its global partnership with Facebook, originally signed in March 2014. Like the first contract, this one spans 52 countries and allows Mondelez to opt into beta-testing programs on Facebook and Instagram. In this new phase, Mondelez said, the companies will be focusing on the fastest-growing consumer behaviors — video consumption and mobile commerce — working together to create and deliver video content to drive impulse snack purchases. Mondelez and its agencies will work with a dedicated, full-time Facebook creative strategist to develop native, scalable video content for the platform that can optimize social engagement. The partnership, brokered through Dentsu Aegis Media, also calls for Facebook to develop playbooks, Webinars and e-learning modules that create a unified approach to developing content for the platform across Mondelez brands. The global snack and candy maker was unambiguous about its goals: To make Facebook its largest digital storefront and to position Mondelez as an e-commerce leader, with particular focus on driving online sales for its "power brands" in key markets including the U.S., U.K., India and Australia. “The partnership with Facebook is a core element of our fearless marketing vision which aims at accelerating growth through transformational marketing,” said Dana Anderson, SVP and CMO at Mondelez, in the deal announcement. “Investing in large-scale media partnerships enables us to connect our brands with consumers in new creative ways.” “Facebook is the number one player in mobile, and its ability to reach Millennial consumers, our primary target audience, is what makes our partnership so invaluable,” added Cindy Chen, Mondelez's global head of e-commerce. “Used by consumers and distributors alike, Facebook is the ideal channel for cracking the code on how to ‘sell a cookie online,’ creating a true social digital commerce model with the potential to become our largest digital storefront.” --- Full article available at http://bit.ly/1Nk7eH6 (link is external)
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Micro-moments are transforming the way consumers shop. Retailers have to win micro-moments to win omni-channel shoppers. As we head into the holiday season, Google's VP of Marketing, Lisa Gevelber, shares three ways retailers can be moments-ready, using examples from those that have seen success. This past summer, America fell in love with women's soccer. My two daughters were among the most avid fans, and they, like millions of others, got swept up in the moment. During one match, smartphone in hand, I searched for the team jersey one of my daughters "had to have." Conveniently, an ad for a Megan Rapinoe jersey—her favorite player—appeared, signaling that the jersey was in stock at a local retailer just a few miles from our house. This upcoming holiday season, shoppers will have plenty of these micro-moments (link is external)—intent-driven I-want-to-know (link is external), I-want-to-go (link is external), I-want-to-do (link is external), and I-want-to-buy (link is external) moments. These moments are big opportunities for retailers; 82% of smartphone users say they consult their phones on purchases they're about to make in a store,1 and one in three has purchased from a company or brand other than the one he or she intended to because of information received in a micro-moment.2 So, are we as brands delivering on these moments? A new Harvard Business Review Analytic Services (link is external)(HBR-AS) report (link below) sheds some light: "Most executives will have their hands full optimizing and integrating their channels, but one thing is for sure: Mobile—increasingly the entry point to a business—is the place to begin." And a recent Google-commissioned Forrester Research (link is external) study of more than 200 mobile and digital decision makers echoes this: 70% of companies say that mobile has urged them to transform their businesses and experiences. --- Full article available at http://bit.ly/1Pl15gc (link is external)
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If he were alive today, department store magnate John Wanamaker, who famously wondered which half of the money he spent on advertising was wasted, would be doubly frustrated. The odds are that he’d still be misspending—even though the tools and techniques that can finally solve his conundrum would lie within his reach. Digital’s potential—the delivery of relevant advertisements to interested users at opportune times—has enticed marketers since the earliest days of the World Wide Web. More recently, programmatic buying of display advertising has promised to extend the benefits of digital advertising by using instantaneous data in a real-time environment to reach individuals with relevant messages. In practice, however, a variety of factors undercut digital advertising’s capabilities. Tests conducted by The Boston Consulting Group show that although current techniques are often effective, companies have an opportunity to achieve significantly better engagement and performance by adopting the latest data-driven approaches—in ways that enhance both relevance and the consumer experience. (See “About This Report.”) Advertisers and agencies are leaving money on the table because of inexperience with these new capabilities, inconsistent campaign execution, and a fragmented approach to campaign development and delivery. --- Full article available at http://on.bcg.com/1m5ghCf (link is external)
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New York, NY October 1, 2015 – Overall M&A activity across the media, information, marketing, software and tech-enabled services sectors was red-hot during the first three quarters of 2015, with 1,758 transactions announced at a total value of $106.2 billion year to date. Both deal volume and value showed solid gains over the same period in 2014, when 1,636 deals totaled $96.8 billion in value. With the M&A market continuing its surge, deal activity inched closer to a level not seen since the pre-recession period in 2007, according to The Jordan, Edmiston Group, Inc. (JEGI) (www.jegi.com (link is external)), the leading independent investment bank across these core markets. Large Deals in 2015 YTD Twenty transactions in these sectors surpassed $1 billion in value through Q3 2015, including the: Fidelity National Information Services $5.1 billion acquisition of financial software and services provider SunGard Verizon $4.8 billion acquisition of digital media company AOL Cox Automotive $4.5 billion acquisition of DealerTrack Technologies, a provider of web-based marketing solutions to the automotive retail industry Media General $3.1 billion acquisition of diversified consumer media company Meredith Audi, BMW and Daimler $3.1 billion acquisition of Nokia’s HERE, a provider of maps and location content for navigation, location-based services and mobile advertising applications Verisk Analytics $2.8 billion acquisition of Wood Mackenzie, a global energy, metals and mining research and consultancy group QVC $2.5 billion acquisition of zulily, the online retailer of merchandise for women, children and housewares SS&C Technologies $2.5 billion acquisition of Advent Software, a provider of vertical applications for the financial services industry McGraw Hill Financial $2.2 billion acquisition of SNL Financial, a provider of analysis and business intelligence on financial institutions Expedia $1.7 billion acquisition of online travel site Orbitz LinkedIn $1.5 billion acquisition of Lynda.com, a provider of online educational videos for individuals to learn business, software, technology and creative skills Nikkei $1.3 billion acquisition of global business news provider The Financial Times TPG Capital, Fosun Industrial Holdings and Caisse de dépôt et placement du Québec joint $1.2 billion acquisition of consumer entertainment shows creator Cirque du Soleil Software & Tech-Enabled Services With overall M&A activity booming, the Software & Tech-Enabled Services sector has been leading the charge. Given the rapid advances in global technology, coupled with the increasing convergence of media, marketing, data and technology, companies are investing heavily in growing their software and technology capabilities through M&A. The most active sector by far, Software & Tech-Enabled Services accounted for more than half of the deal volume and value, with 1,091 transactions totaling $58.1 billion. The chart on the left in the included PDF shows a breakdown of deal volume by sub-sector within this red-hot sector. Application software was the most active sub-sector, with nearly one-third of the Software & Tech-Enabled Services sector deals. Other active sub-sectors were IT services & distribution (17% of the deals), mobility (12%), IT outsourcing (10%) and information management (9%). The chart on the right shows a further breakdown of the segments within the application software sub-sector. Vertical applications accounted for the highest deal volume (31%), followed by enterprise resource planning (18%), customer relationship management (15%) and business intelligence (13%). --- Full article available at http://bit.ly/1jkdrt0 (link is external) Full JEGI press release, attached.
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Aims to Be the World’s Single Largest Integrated Set of Consumer, Purchase and Media Data; Foundation for Breakthrough Prescriptive Analytics, Software and Technology CHICAGO and AUSTIN, Texas — April 21, 2015 — Information Resources, Inc. (IRI), a global leader in innovative solutions and services for consumer, retail and over-the-counter health care companies, announced today the launch of IRI Shopper Marketing Cloud™, expected to be the world’s largest integrated consumer, purchase and media data set built inside IRI’s leading Liquid Data™ technology platform and powered by its recently announced Q-IRI™ prescriptive analytics engine for comprehensive planning, targeting, activating and measuring by fully linking media to store-level or online purchase. “We are at the beginning of a consumer buying revolution, one that will change how consumers shop and make decisions in fundamental ways over the next decade,” said Andrew Appel, president and chief executive officer, IRI. “IRI is focused on transforming the entire shopper journey by helping companies grow and by helping consumers make better buying choices. This integrated data, analytics and technology will help manufacturers and retailers unlock new pockets of growth and do it faster than ever before.” Arming CPG companies with an incredibly powerful platform for growth, IRI Shopper Marketing Cloud encompasses the whole portfolio of data sets and insights, focusing on media, social and purchase. Media Data Sets To ensure the most comprehensive media data, IRI has expanded its ongoing collaboration with Rentrak and comScore to move beyond tracking ad exposure and include full integration of cross-media TV and digital campaign tracking powered by IRI’s ProScores™ purchase propensity models. Social Data Sets IRI also is expanding the ability to understand and leverage the impact of social sentiment on consumer activation and sales activities, and will be announcing an exclusive partnership that will guide CPG companies through targeting, activating and measuring campaign efforts. Consumer and Media Consumption Data Sets Leveraging valued relationships with retailers, IRI has continued to make huge investments to improve the ability to track purchases online and offline at a granular level. Working closely with retailers to help them connect with consumers, IRI Shopper Marketing Cloud offers enhanced performance by linking the same media and social data to retailers’ frequent shopper databases for unique insights and in-store activation. It also tracks what media consumers have been exposed to and what products they have purchased. --- Full article available at http://bit.ly/1ZkycVz (link is external)
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Today we’re launching cross-device reporting for Facebook ads, enabling advertisers to see for the first time how people are moving between devices — across mobile apps and the web — before they convert. Reporting for a multi-device world Imagine seeing an ad for a product on your mobile phone while in line at the bank. Do you immediately make a purchase on your phone? Probably not. But perhaps you go back to your office later that day and buy on your desktop computer. Such cross-device conversions are becoming increasingly common as people move between their phones, tablets and desktop computers (link is external) to interact with businesses. Facebook already offers targeting, delivery and conversion measurement across devices. With the new cross-device report, advertisers are now able to view the devices on which people see ads and the devices on which conversions subsequently occur. For instance, a marketer can view the number of customers that clicked an ad on an iPhone but then later converted on desktop, or the number of people that saw an ad on desktop but then converted on an Android tablet. Full article available at https://www.facebook.com/business/news/cross-device-measurement (link is external)
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Recent moves by Google (link is external) and Facebook have left some industry observers declaring this the dawn of a “walled garden” era of ad tech (link is external) — one in which brands and agencies need to use a platform’s ad tech when purchasing that platform’s media. But the agency holding company Omnicom Group has found a novel use for Atlas: Checking Google’s math. It has begun adding Atlas tracking pixels to measure ads served by DoubleClick, Google’s ad serving competitor, to compare each product’s results against one another, according to executives familiar with the agency’s ad tech plans. It marks the first major test for the nascent Atlas and the people-based measurement system it has been espousing as a replacement for cookie targeting. This could be the start of more competition for DoubleClick, according to several ad tech executives. Adding Atlas tags to DoubleClick-served ads will get Omnicom two distinct reports on its ad campaigns: one from Atlas, which measures campaign performance against Facebook login data, and another from DoubleClick, which employs cookies for measurement. Despite signing a deal last September to become the first agency to use Atlas — the ad server Facebook bought in February 2013 and re-released last fall — Omnicom has yet to convince many clients to start using Atlas for ad serving. That means they have yet to tap into Atlas’s unique targeting capabilities, which includes Facebook’s trove of users data. This is a way to utilize Atlas without abandoning DoubleClick. Facebook has pushed Atlas with what it calls “people-based (link is external)” marketing, which it claims will not only be more accurate for desktop campaigns than cookies but will provide the long-sought-after solution to mobile’s cookie problem (link is external). Cookies are functionally useless on mobile, making targeting mobile users difficult. Because Facebook has so many users who log in to their accounts on both desktops and mobile devices, they have a unique data set that could potentially solve marketers’ cross-device advertising woes. Google, for its part, spent much of the last three years requiring users to create a Google Plus account when signing up for various Google products, such as Gmail, in a move that was widely considered a way for it to move away from cookie-based tracking. The requirement was lifted this past September (link is external). Indeed, cross-device tracking was a major motivation behind the Facebook-Atlas deal. But before Omnicom starts using Atlas’ ad server for those unique targeting capabilities, it wants to make sure Atlas actually identifies audiences the way it claims. And that means using Atlas to measure campaigns that are still served by DoubleClick. --- Full article available at http://bit.ly/1J3cj4j (link is external)
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Blog
Safe Harbor on Data Declared Illegal: Message to U.S.—Time to Enact Privacy Law that Protects Americans and Supports Global Data Protection
Case illustrates why FTC is legally unable to effectively protect the public and why Safe Harbor cannot be "fixed"
Today’s historic decision by the European Court of Justice, which overturned the purposely ineffective “Safe Harbor” deal enabling data to flow to the U.S., is very welcome. As one reads the court’ (link is external)s findings, it’s clear that for the EU, fundamental and human rights include the right to have your personal privacy protected. That means from both governmental surveillance (such as the NSA and other intelligence agencies) and also with commercial Internet companies—as Google or Facebook. Advocates always recognized (link is external) that the Safe Harbor agreement brokered by the Clinton Administration was a digital privacy `house of cards.’ All U.S. companies needed to do was to sign up for some inadequate principles that allegedly would protect the EU public. The Federal Trade Commission was supposed to investigate problems. But as CDD demonstrated last year in its complaint to the FTC on how leading U.S. companies were thumbing their data collecting noses at Safe Harbor, the system doesn't really do much of anything. Safe Harbor is run by the U.S. Department of Commerce, whose political loyalties (and revolving door) lie with the data collection industry. The message to America from the EU is clear: enact comprehensive privacy legislation. It has to meet (and should try and exceed) the high bar set by the EU. It can’t be the weak (link is external) and self-regulatory based “Privacy Bill of Rights” proposed this year by the White House. It has to define strong and enforceable rights, including limiting Big Data style collection—which is now a pervasive part of our online landscape. The law should empower an independent privacy commissioner and give the FTC real regulatory clout. The U.S. also should endorse the EU’s framework (link is external) on privacy that is supported by many countries around the world. In its decision, the European Court of Justice reaffirmed what its Advocate-General has explained earlier. That the U.S. Federal Trade Commission does not have the statutory authority and legal powers to protect a person's privacy as required by the EU. In the EU, privacy is a "fundamental right." In the U.S., consumers have really very few such rights online. The court explained yesterday (in referring to the 2000 decision by the EU approving the Safe Harbor deal with the U.S.) that: " Decision 2000/520 does not contain any finding regarding the existence, in the United States, of rules adopted by the State intended to limit any interference with the fundamental rights of the persons whose data is transferred from the European Union to the United States, interference which the State entities of that country would be authorised to engage in when they pursue legitimate objectives, such as national security... Nor does Decision 2000/520 refer to the existence of effective legal protection against interference of that kind. As the Advocate General has observed (link is external)in points 204 to 206 of his Opinion, procedures before the Federal Trade Commission... are limited to commercial disputes..." The Business lobby has consistently fought against legislation that would empower the FTC to regulate privacy and other commercial practices. Consequently, while the commission does what it can (and is very active working to help the public), it cannot address the fundamental issue. U.S. companies gather and use our information in far-reaching, non-transparent and often troubling ways (think all the secret "scoring" of people that goes on to assess how to treat them; or the use of race, ethnicity, income and location used to track and target us, regardless of device, etc.). Safe Harbor cannot be fixed without the U.S. enacting comprehensive privacy legislation that brings it in sync with the EU. The time to do so is way best due. Kudos to Max Schrems (link is external), who brought the case, and is a tireless and effective privacy campaigner. See BEUC (link is external), PI (link is external) and TACD (link is external) statements as well.