The AdHaven Bullseye system, launched by 4Info in March 2013,
connects information from advertisers' own customer databases with
household, purchase and other demographic and psychographic data
from partners including Acxiom and Nielsen Catalina Solutions. The
idea is to aim mobile ads at people who are actual customers or
have had interactions with advertisers, rather than simply
targeting audiences based on the mobile apps they use. And, in
turn, clients use the system to determine whether those mobile ads
drove people to buy in their stores.
It took the firm around a year-and-a-half to develop its latest
mobile ad targeting product, and a good chunk of that time was
spent figuring out the privacy side of the equation. "Twenty
percent of our time including that of engineers was spent either in
meetings or in conversations with folks about privacy," said 4Info
CEO Tim Jenkins. "It was hundreds and hundreds and hundreds of man
hours."
In addition to incorporating privacy protections from a
technical and engineering standpoint, the process involved lots of
legal consultation and several meetings with data partners and key
brand clients -- including a large CPG brand. "We went through a
very early privacy review with one of the largest CPG brands," said
Mr. Jenkins, who would not name the company. "It was literally a
four-month review."
Sometimes project collaborators on the legal, client and
engineering sides didn't see the need to be quite as stringent
about ensuring consumer privacy as others on the 4Info team were,
said Mr. Jenkins. "There were some very unfriendly calls."
Privacy is a new conversation
Indeed, privacy simply is not top of mind for many in the ad
industry.
"I do work with a lot of pretty significant blue-chip clients
and they're more enamored of how efficient highly targeted
marketing can be," said Jessica Kernan, chief strategy officer,
North America at RAPP. However, when asked whether the same
clients express concerns about privacy when initially devising
marketing efforts, she said, "I wish I could say that they
are."
While privacy and security protections are more inherent for
financial services, healthcare clients and some retailers working
with RAPP, Ms. Kernan suggested that others such as CPG brands care
more about "how can we get more one-to-one in our
communications…. For people who are thinking about marketing
communications it's a very new conversation."
"Advertisers want to push limits," said Kirsten McMullen,
4Info's chief privacy officer, who took up that role after serving
as the firm's marketing director. "We run it by privacy counsel
first."
Despite the fact that most marketers don't always think
privacy-first, said Ms. Kernan, "I've found every marketer that
I've communicated to about it to be very receptive and thoughtful
and interested in thinking that way. … After all, marketers
are also consumers."
When data silos are desired
The primary goal for 4Info and countless other ad-tech and data
firms is to link together data points gleaned from an onslaught of
continuously-updated consumer data in the split-seconds needed to
send an ad to the advertiser's target. But 4Info wanted to do that
in a way that doesn't involve one database with a list of names,
device IDs and column after column filled with fields of data about
each individual. If the data were stored "in one massive table,"
said Mr. Jenkins, "That's too easy to hack. ... Someone could
potentially come in and cobble stuff together."
In order to operate, though, the system must stitch that data
together to find the appropriate users to target when ad requests
are made. "We have to query three different locations. Remember we
still have to do that in under 150 milliseconds. That's a big tax
on a company like ours," said Mr. Jenkins.
Though 4Info keeps some less-sensitive data, such as ad
impression logs and ad campaign creative, in cloud storage,
sensitive data sits on multiple servers in discrete locations.
Storage is one thing. The company also needed to make sure
partners including mobile app publishers, networks and exchanges
had strict opt-in policies enabling location-data collection, said
Ms. McMullen. (In most cases, users must allow location-data
collection to download mobile apps, otherwise they can't get the
app at all.) The firm also includes the ad industry's
self-regulatory opt-out AdChoices icon in all its ads, allowing
people to opt-out from future targeting through the ads
themselves.
History lessons
So why go through all the hassle? History taught 4Info a lesson,
suggested Ms. McMullen. "Nobody wanted to be the first DoubleClick of mobile."
In 1999, DoubleClick bought catalog-data firm
Abacus for $1.7 billion, and privacy advocates freaked out.
They petitioned the Federal Trade Commission, prompting DoubleClick
(acquired by Google for $3.1 billion in 2007) to announce
it would not connect personal information from Abacus with
online-browsing data. Connecting household addresses, mobile
locations, in-store retail transactions and other
offline data to target digital ads is increasingly popular
among advertisers today.
Another impetus for 4Info: a Wall Street Journal
series exposing the increasingly sophisticated capabilities of
the consumer data-tracking and targeting industry. The "What Do
They Know Series" was controversial among industry insiders, and
gave public prominence to company names and practices that had been
little known among everyday consumers.
The impact of the series on the ad industry, particularly those
handling lots of consumer data for targeting, "was extremely fresh
in 2011," said Ms. McMullen. "We didn't want to be fresh meat for
that kind of investigation," she said. "We knew we were using some
sensitive information in terms of location and device
identifiers."
Companies that felt the sting of the WSJ series included
RapLeaf, whose data-linking practices were highlighted by a 2011
WSJ article. RapLeaf changed the way it segmented audiences after
the newspaper contacted the firm,
reported the publication. LiveRamp, an offline-to-online data company
spun out of RapLeaf in 2012, was
acquired by data giant Acxiom for approximately $310 million in
cash in May. Acxiom is one of the partners that feeds data into the
Bullseye system, allowing 4Info to match mobile devices showing
household locations to advertisers' proprietary customer data like
purchase information.
Acxiom worked closely with 4Info while Bullseye was in
development, subjecting the product plans to its own internal
privacy assurance process. The data and marketing services firm put
4Info through a privacy review "even before" the partnership began,
said Jennifer Glasgow, who has headed Acxiom's privacy efforts
since 1991. "We typically get to know the privacy and product
people pretty early in the relationship," she said. "We followed it
all the way through implementation."
That review process entailed Acxiom's privacy team assessing
4Info's data-flow schematics, for example, to ensure data would not
be integrated in such a way that would infringe on individuals'
privacy. "The data flows are getting more complicated every year,"
said Ms. Glasgow.
Ms. Glasgow, herself a veteran in data privacy, suggested that
the fact that 4Info has a privacy officer on staff is rare for a
small firm -- in 4Info's case, only 37 employees. "I think [Ms.
McMullen is] something of an exception [with 4Info] being a company
of that size," she said.
Whiteboards and data diagrams
On the legal front, Ken Dreifach, a lawyer for ZwillGen came in,
observing white-board diagrams showing how data gathered by 4Info
would wind its way through the system. "The assignment was to
simply build the most privacy-sensitive data flow and data
technology, and that's what 4Info did and the company did it at
significant expense," said Mr. Dreifach, who handles issues such as
data and online advertising law, and still serves as an outside
counsel for 4Info. He has worked with the mobile data firm for two
years, and in the past worked for LiveRamp as general counsel.
Several meetings with Mr. Dreifach involved a review of how data
would be de-identified and segregated to establish technological
and legal controls preventing data from being merged in ways it
shouldn't be.
"The sticky issue would have been if they said, 'We don't want
to spend this much money on silo-ing and disaggregating data," he
said.
Most ad tech firms gathering and storing lots of consumer data
at risk of exposure through hacking or leaks don't have the budget,
resources or wherewithal to put themselves through the
privacy-by-design wringer, and it's unclear what it will take for
the industry as a whole to consider data privacy and security in
the early stages of product development.
"They all kind of need to advance together in order to resolve
the privacy challenge," said Ms. Kernan.
Of course, more
restrictive privacy legislation looms, but rather than limiting
what marketers do with data, suggested Ms. Kernan, "Perhaps there
is a requirement that companies have a privacy [officer] in their
employ…. Those things drive change within the
organization."