“Self-regulation is about creating standards and holding members accountable for those standards,” said Robert Gratchner, chairman of the NAI board. “Having a seasoned and respected FTC attorney take the helm at NAI continues our deep commitment to meaningful self-regulation, effective enforcement of industry standards and further development of best practices in online behavioral advertising.”

As executive director, Groman will leverage over a decade of experience to tackle cutting-edge privacy issues. Groman has a deep knowledge of today’s complex policy debates around online advertising, privacy and self-regulation.

“Marc really understands the privacy issues facing consumers and businesses today, and has remarkable creativity, problem-solving and people skills,” said Jessica Rich, deputy director of the Federal Trade Commission’s Bureau of Consumer Protection. “The NAI is really lucky to get him at this critical time for privacy.”

“NAI member companies, along with the rest of industry, have been doing incredible work to advance consumer choice. In selecting Marc, the NAI has chosen a strong, respected leader who will continue to advance those initiatives,” said Alan Chapell, vice chairman of the NAI.

Groman replaces current executive director Charles Curran, who will continue to serve as an advisor to the NAI. “It has been an honor to have Chuck lead the NAI since 2009,” commented Gratchner. “During the NAI’s rapid expansion to more than 75 member companies, Chuck’s leadership enabled us to make significant progress in implementing credible compliance and best practices for companies engaged in interest-based advertising. As he leaves to pursue new challenges, I want to thank Chuck for his tireless efforts to broaden the scope of self-regulation and enhance consumer transparency and choice.”

Recommendations from personal acquaintances or opinions posted by consumers online are the most trusted forms of advertising, according to a recent Nielsen study. Ninety percent of consumers surveyed noted that they trust recommendations from people they know, while 70 percent trusted consumer opinions posted online

But what if the review is fake, done by the brands themselves? That’s what happened to Russ Taylor when he was looking for an expresso machine. (via WSJ) He noticed a DeLonghi machine received good reviews. Then he noticed the person who wrote it only did reviews, all of which were effusive in their praise, about the company.  A short Google search later, he figured out the writer worked at the company.  As he said:

“You would think that anyone involved at the managerial level in a large firm such as DeLonghi would want to avoid ruining their firm’s reputation by engaging in this type of false and deceptive activity. I would imagine it’s a violation of the Federal Trade Commission Act, as well as numerous state laws.”

This is one example why the Federal Trade Commission has continued to get involved in sponsorships and the blogosphere.  And another example of how brands misuse social media.

The FTC Guides Concerning Use of Endorsement and Testimonials in Advertising is not new. Much of the document dates to the first publication of it in 1975 with a revision in the 1980′s to create the standards by which marketers, particularly television commercials could use endorsements and testimonials. And, while television still plays a large role in marketing, the Internet’s influence has reached a critical mass, i.e. the FTC has received a large enough pool of complaints regarding certain practices that they feel it necessary to dictate allowable behavior.

In this case, the format in question revolves around blogs and bloggers. That the FTC might look to regulate bloggers in a revision to their guidelines is also not new, with mentions beginning in November 2008 with proposed changes being published and picking up again at the very end of April 2009 and throughout May. The topic has gained momentum in the past few days because of a recent AP article that was revisited on Cnet.

The AP article begins, “Savvy consumers often go online for independent consumer reviews of products and services…” “to help them find a gem or shun a lemon. What some fail to realize, though, is that such reviews can be tainted: Many bloggers have accepted perks…” and “Bloggers vary in how they disclose such freebies, if they do so at all.” It’s important because it would be the first time that FTC has proposed any sort of rules for bloggers specifically.

For the individual blogger this can sound scary. A classic example comes from an ex-coworker who started a beauty blog, and as it started to gain a little bit of a following, she started receiving not just requests to cover a product but incentives for a review, the implication being that she would write positively. Such one offs aren’t unusual. Entire companies even exist to help advertisers receive coverage from bloggers. PayPerPost for example has created an entire marketplace whereby companies can find bloggers who will write about their products or services with the advertiser having final approval of whether they will pay for a particular post.

Intellectually, this is an interesting and important topic. As mentioned in one of the articles, “If you walk into a department store, you know the (sales) clerk is a clerk,” said Rich Cleland, assistant director in the FTC’s division of advertising practices. “Online, if you think that somebody is providing you with independent advice and … they have an economic motive for what they’re saying, that’s information a consumer should know.” And unlike more traditional media where those reporting are held accountable for what they say (the exception being Fox News), in the solo journalism world of blogging, no such code of ethics and enforcement exists. Yet, as we see day in and day out, people believe bloggers.

The ones most worried about the changes are not surprisingly the people who rely on the incremental the most, the stereotyped single mother who earns $1000 per month through blogging, now concerned that she might make an accidental mistake to get her in trouble. It makes for an emotionally charged example in theory suggesting caution in adding the oversight but doesn’t represent reality. The FTC is not the music industry, willing to sue an individual for $20,000 per song for downloading and sharing 20 songs. Things start to get screwy, though, if bloggers can’t link to books, movies, etc. using affiliate programs. As to the specific changes, they haven’t been finalized but should be later this year.

It’s hard to say what changes will be made to existing language but clearly much effort focuses less on the medium, i.e., that it now would include enforcement over blogs, and more on the nature of testimonials and endorsements – what can be said, what can’t, and what disclosures are necessary. Two recurring themes emerge, one summarized by this statement on the November 2008 document, “Businesses are entitled to compete based on truthful, nonmisleading advertising claims, but they are not entitled to use techniques that mislead consumers.”

The second theme will sound more than familiar to those who went through the changes in ringtone marketing – the use of “clearly and conspicuosly,” e.g., “the advertisement should clearly and conspicuously disclose either what the generally expected performance would be in the depicted circumstances or the limited applicability of the endorser’s experience to what consumers may generally expect to achieve.” The challenge has been and will be what is “clearly and conspicuously,” but a litmus test could be – if you’re trying to deceive, Then that’s a problem.

Not everyone will agree, but more than not do seem to think that FTC generally strikes an appropriate balance between “protecting consumers and allowing advertisers to communicate creatively and effectively to potential customers.” (When they raid your office without warning, seizing property, that’s another story.) When the new guidelines come out, it seems that the biggest change is that those using testimonials and endorsements, in the case of weight loss, will need to know not only what you can lose (the testimonial/endorsement) but what the average person would expect to lose.

Reading between the lines, what we think we see is an emphasis on areas that have truly quantifiable results, such as weight loss. You can measure pounds, but you can’t measure wrinkles. So, we’re likely to see a crackdown on weight loss and a shift in marketing towards those where no such scale exists. Who really wins, though? Your lawyer. You’ll need one now more than ever to comply.

For an indepth look at the new Guides with commentary, see:
http://blog.seorevolution.com/2009/05/30/ftc-change-in-endorsements-and-testimonials-policy/

 Courtesy of DM Confidential editor

If behavioral targeting practitioners do not inform consumers of being behaviorally targeted or misuse the information they collect, Congressional legislation or FTC regulation could be passed. Previously on Adotas, we covered how the FTC is monitoring behavioral advertising.

The group that is currently guiding self-regulation of behavioral advertising includes the Interactive Advertising Bureau, the American Association of Advertising Agencies (4A’s), the Direct Marketing Association, the Association of National Advertisers, the Council of Better Business Bureaus (BBB), and various businesses, consumers, and stakeholders. The main concern of this cross-industry group is that the proposed principles would constrain access to information that would be beneficial to internet marketers.

Companies like Google and Yahoo also have a say, according to FTC Director Charles Harwood. Facebook, for instance, argues the need for distinction between personal and non-personally identifiable information. The company is in favor of transparent data collection and control of what happens when the data is collected. Meanwhile, Google calls for the creation of privacy laws that would build consumer trust.

The FTC encourages the existence of privacy statements on all Internet websites where any information is collected. According to Harwood, companies must adhere to their own policies. If the manner in which data is collected changes, consumers should be notified and required to provide affirmative consent before further information can collected.

“Where we found that policy is misrepresented in a company’s actual practices,” said Harwood, “the FTC has filed lawsuits to require the company to post an accurate policy and to implement strict standards to ensure that company adheres to the policy.”

Behavioral Targeting

Is opting in or opting out of behavioral advertising an effective means of privacy control? Harwood thinks it’s more complicated. It may be ineffective if consumers do not know what they opt into or opt out of. When consumers opt out, they think they are opting out of all tracking activities, which may not be the case. To consumer advocates, they may really just be opting out of better targeted ads.

So what is FTC’s take on this? It’s inherent in the guidelines that consumers should have the choice of deciding whether they want their information collected, said Harwood, but he also noted that companies do not want to give consumers that option. If companies told consumers they do not have a choice, whether or not it is a violation of the FTC Act depends on the information collected.

In FTC guidelines, certain kinds of PII (personally identifiable information) should be collected only if consumers opt in about consumers are required to be manually opted into. Some information should not be collected at all, said Harwood, such as medical information and information about children unless parents are involved. The NAI (Network Advertising Initiative) agrees, and proposes that information of children under 13 not be used for behavioral targeting. This is currently permitted with parental consent.

The lack of transparency from companies about how information is used collected is an issue that concerns frustrates the FTC. Beyond serving behaviorally targeted ads, companies may not be are not disclosing other uses of the information that they collect, said Harwood. Perhaps the data is combined with other sensitive PII, or even being used to engage in price discrimination, which potentially violates the FTC Act.

According to Harwood, Chairman Jon Leibowitz has indicated the FTC may issue a CIDs (civil investigative demand), a type of subpoena, to help FTC understand how behavioral targeting data is combined with other data for uses beyond serving ads. The FTC can seek court enforcement for failure to respond may lead to fines and imprisonment.

The FTC may pursue voluntary standards, but it is up to the industry to keep itself in check. Within the February 2009 release, Leibowitz stated that the “industry needs to do a better job of meaningful, rigorous self-regulation or it will certainly invite legislation by Congress and a more regulatory approach by our Commission.

Put simply, this could be the last clear chance to show that self-regulation can – and will – effectively protect consumers’ privacy in a dynamic online marketplace.”

By now, we’ve all seen the FTC’s proposed updated set of guidelines for testimonials and endorsements. There won’t be a decision until this summer but, to put it simply, marketers and the bloggers will soon be liable for what the FTC calls misleading claims. The FTC may even ask those who continue to engage deceptive practices to compensate consumers. Is this really needed? Maybe, maybe not.

However, given the current financial industry disaster, this is not an administration that’s in the mood to trust businesses to self-police. (See: U.S. Signals More Scrutiny of Mergers, Antitrust.) Consumers have taken a beating this year, and the administration will likely be more proactive than those past in doing what they feel will protect the consumer.

Admittedly, much of this is a grey area, and may be challenging to enforce. Consider: products are featured in print magazines all the time. Where do the magazines get them? From the companies’ PR people. The bloggers we talk to resent the implication that they are swayed by products, while their print counterparts are not. Frankly, it’s ridiculously subjective to even consider a distinction. At what point does successful PR stop and endorsement start?

This could go two ways.

The good:

A clear, consistent, across the board distinction between sponsored content and advertorial, and opinion and product reviews. Consumers have a higher level of trust in the blog content they consume. Bloggers and consumers frustrated by paid posts masquerading as content welcome the changes.

The bad:

The regulations create fear among bloggers to review products – at all — and fear among marketers to move in to the blogosphere. If you are a small company or a blogging team of one, will a run-in with the FTC drain all of your resources? Worse, will bad acting companies lose the checks and balances of having bloggers call out the bad actors?

Moving forward:

We’re working with brands every day on advertising campaigns across the Technorati Media network – and on blogger outreach programs. Here’s what we’re telling them.

For bloggers:

Tell your readers exactly what it is that they are reading. The majority of high authority blogs are clearly marking paid content as sponsored. For editorial, or for what you could call product placement: what is the relationship? Did the company lend you the product or give you the product? Are you working with them in other ways, such as a freelance copywriter? You’ll need to make all of this very clear. This is obviously more important when the product in question is a laptop or digital camera than when it is a bottle of detergent.

For marketers:

Provide bloggers with full and accurate product information. Encourage bloggers to disclose their relationship with you. Then, follow up to make sure they got everything right. Also important: don’t balk at labeling paid content as such. The important thing is that your message is being seen in an environment of high engagement and credibility. Your brand, and the bloggers you are working with, will have more credibility the more transparent you are.

Let’s say you make your best effort, but something incorrect is posted. How do you follow up in the long tail of the blogosphere? The good news is, from what we see on Technorati, these aren’t the posts that go viral. Linking is arguably the truest measure of a blog’s influence, and more importantly, in a world without filters or controls, linking is the control. If a blogger publishes information that is unprofessional, untrue, or a blatant (unlabeled) promotion other bloggers don’t link to it. Unless of course there is a negative backlash where, most times, it’s other blogs that are doing the calling out.

Here’s an example: we worked with Sony to distribute digital cameras to bloggers attending the South by Southwest conference. The bloggers were encouraged to use the camera to upload video and photos from the event to their blogs. It was made very clear that there were no strings attached: bloggers were not required to post a product review or to post positive mentions of the camera.

They did anyway: One of our bloggers said “this camera made me a rockstar at SxSW! People came up to me to talk about it”. Another blogger said “people had heard about the program from Technorati and eagerly wanted to see the camera. They couldn’t believe how small it was, HD capable, and costs less that $200.”

The guidelines may be tough to wade through, and tough to enforce, but the actions for bloggers and marketers are simple. The qualities marketers need to embrace to succeed under the FTC’s new guidelines are inherent to the blogosphere: transparency and trust.

– Express your opinion, comment below.

Email sails as direct mail fails

Bruce Biegel:
“Since when is email revenue up to $12BB? Have seen alot of numbers in the past on email but never close to this?
Also since email arguably does not work well for marketing acquisition, and direct mail spending is primarily (70%+ usually) for acqusition – why would email be the beneficiary here?
Mail will still have its place, and a significant one until online becomes a strong targeted acquistion medium, one that can be directed to prospect and not wiating for the prospect to wave their browser.”

Jeff Reinhardt:
“Direct Mail falls as Email Rises – Does anyone notice a common word ? MAIL
Email is Direct Mail – assuming of course it is targeted and not just blasted to all. Thus Direct Mail rises as Email rises — maybe postal mail is declining.”

Twitter, a marketing fool’s hype

jack:
“it’s hype, but only for the marketers that think that social media is a one-size fits all, off the shelf solution. A simple plug and play if you will. You don’t just show up and watch the cash register start to ring. You need to engage, add value, participate, etc etc…
For those marketers willing to put the time in, social media can actually add revenue. Consumers aren’t going there with the intention of making a purchase, but that doesn’t mean it can’t happen. Just because you aren’t at a site looking for guidance, doesn’t mean you won’t accept it if relevant/meaningful guidance is offered. I’m not on twitter to get 50% off a muffin at starbucks, but if a friend retweets that promotion… well, I may stop by starbucks at on my break.
Also, your stats are about advertising on social media sites… what about brands that use social media sites to engage consumers?
Finally, here’s a recent Ad Age article regarding Naked Pizza’s success. A twitter promotion brought in 15% of their revenue one day.
http://adage.com/digital/article?article_id=136662″

Mike Saunders:
“It’s just like anything….if you don’t work it you will receive no results! It’s called NetWORKing….you don;t just show up to a Chamber meeting and get flooded with business.
With Twitter, you must work it, 3-5 relevant Tweets a day, attract TARGETED followers….but all too many times business owners set it up and stop within a week and say “Well that didn’t work”
I added a service to my Marketing Consulting called Twitter Magic that solves this.
Let me know if I can help.
www.MarketingHuddleCoaching.com/twittermagic”

Twitter affiliate linking madness

Mike Buechele:
“Jeremiah Owyang recently spoke with Shawn Collins, owner of Affiliate Summit the largest affiliate convention. They both agreed that there is more to learn before a standard can made. Also, not all affiliate links on twitter are spam which has been discussed in the affiliate industry for a while now. If someone in my community is asking about the best coffee brewers then I don’t consider sending her an affiliate link to one I recommend spam. That’s a solution to someone’s problem. Just sending out tweet after tweet with links without reference to the conversation or in line with the community’s values would be spam, like offering a community of vegans discounts on big macs.”

Two Ways to Skin a Dislay Ad

Sue:
“Well, you did make it a tag line for CPA. And your article is very smart and explaines why there is growth in CPA (cost per action marketing). At Hydra we have seen tremendous growth in this area. Advertisers are requiring the ability for accountability and better ROI.”

Affiliate Success: Trends, Trust, and Transparency

Randy Mitchelson:
“Thanks for the article Ashlee. I am constantly researching offers for exclusive placement in our Daily Dollar Newsletter (www.dailydollarnewsletter.com) which we email to our payday loan customers and have noticed more offers being labeled as “select”, etc, but the feedback I have rec’d is that it’s more the prevent fraud from the click crooks out there.”

Google Trademark Process, Shifting Burden to Brand Owners

R.J. Lewis:
“This raises once again the frequently heard question of “who really owns a brand anyway?”. Increasingly it’s not the company that holds the copyright, but the customer, the consumer, and now their reseller partners…”

The FTC steps into the social media fray – so what do we do now?

surething:
“If the government was a business it would be Bankrupt, just think about that any time you support government intervention. There is already regulation in this area, it is called the judicial system. If someone makes a claim that is untrue it should be handled through the courts.”

Advertisers want to reach a highly-targeted audience at scale. Effective targeting outside of search requires tracking consumer behavior and carries serious privacy concerns. With mobile devices, consumers feel more violated when bad things happen, and the limitations of such devices further complicate the situation.

Why should you care? Because this is going to get worse before it gets better. Consumers are having an unprecedentedly personal relationship with devices, from PCs to iPhones. The technologies for targeting and tracking of consumers are getting more sophisticated. The advertising value chain across all channels is getting longer and more complex.

As data collecting grows, privacy erodes. Consumer privacy groups are (rightfully) increasingly more vigilant. When greed or poor judgment cause something to go wrong in such a tense and complex setup, it has the potential to go wrong in a catastrophic way, with FTC hearings, high-profile resignations, lawsuits and the real threat of knee-jerk regulation.

The Federal Trade Commission staff released a report recently revising its online behavioral targeting principles. While this particular report focused on behavioral targeting, the general topic of targeting across channels is rising in importance for the regulatory body. In recent weeks, the FTC has received complaints from privacy groups about mobile marketers’ “sophisticated practices that allow them to track, analyze, and target millions of Americans who increasingly rely on their phones for information.”
Last fall, the FTC held hearings on the practices of NebuAd, a deep packet inspection company whose technology allows it to understand consumers’ online behavior by looking at the traffic that passes through their ISP. Last May, the then Commissioner Jon Leibowitz went on the record saying “We’re also going to police the wireless space.”

The FTC’s four principles of behavioral targeting come with good intentions but are unlikely to have a major effect. The first is transparency and consumer control. The second principle proposes reasonable security and limited data retention. The third governs material changes to privacy policies, and the fourth states that companies should obtain affirmative express consent before they use sensitive data.

While they make sense at a high level, the principles are vague to the point of being unenforceable, especially in a large industry such as online advertising where there are literally hundreds of companies engaged in behavioral and other advanced forms of targeting. For better or worse, this game will play out on the Internet as a roller-coaster of businesses playing fast and loose, privacy groups outing bad behavior, threatened or actual regulation and showcase hearings such as NebuAd’s.

The efforts of industry groups such as the Mobile Marketing Association’s mobile advertising guidelines and CTIA – The Wireless Association’s location-based services guidelines as well as mobile operators’ policing of services on their networks are praiseworthy but like the FTC’s principles they are unenforceable at national, let alone global scale. This has led to a bifurcated culture of privacy paranoia or cowboy behavior. As an example of the latter, note the many SMS marketing lawsuits around the country.

There is hope, however, that we can learn from what’s happened on the Internet and other industries that deal with volumes of highly sensitive consumer information and do a better job of developing the mobile advertising and marketing ecosystem. Well-targeted, helpful advertising to the device in your pocket can be invaluable. I use multiple forms of search, mapping and several free/ad-supported applications on my Blackberry every day. They make my life easier. iPhone and, increasingly, Android phone users have an even larger choice of services.  (I’d tell you how many apps are on my iPhone but my battery is dead, again.)

While it is easy to imagine a whole slew of Big Brother scenarios when you combine the personal nature of mobile communications with geo-tracking, it is important to acknowledge that the mobile industry has the deck stacked in its favor as far as getting privacy right. A lot of power is in the hands of mobile operators who care about customer satisfaction and privacy.

They don’t want to lose $99/mo customers in an attempt to make an extra $2/mo in targeted advertising revenue. Furthermore, tracking consumer behavior on mobile devices is difficult. Cookies and JavaScript (the key to consumer tracking on the Internet) don’t work well across devices. This is a good thing in the short run because it gives the industry a chance to come up with a workable plan before the situation gets out of hand like it did on the Internet.

In order to grow quickly, the mobile advertising industry has to aggressively innovate while addressing privacy concerns up front. This requires a new, market-based paradigm.

First, the industry must develop simple, clear and, most importantly, testable guidelines for acceptable privacy architectures and tracking/targeting behavior. Testable in this context means that it must be possible to certify within reason, on an ongoing basis, whether a vendor is or is not following the guidelines. For example, this approach works very well for the SMS ecosystem where actions leave a trail that can be tested for compliance with industry guidelines. It is possible to determine whether a mobile marketer respects a STOP message from a consumer or whether a premium SMS is sent without a prior confirmation, etc.

There will be cases, however, where it is very difficult to determine what has happened in the past or even to enforce guidelines in real-time. The prime example is behavioral targeting across a network of dynamic mobile Web sites. Nothing stays the same: the ads change and the sites’ pages change all the time. To handle unenforceable guidelines the industry needs a second strategy of containment. Collecting and aggregating consumer information across sites for the purposes of ad targeting carries significant privacy risks but it can also be done thoughtfully, with due consumer protections and in dialog with privacy advocates. If the mobile industry allows hundreds of vendors to do this, it will lead to the impossible to police situation on Internet but with much higher risk of regulation and consumer backlash.

The second strategy involves allowing one or more industry-wide tracking and targeting services to emerge which act as containers for sensitive consumer information. These services will have to sign up to stringent policies of transparency and disclosure, deploy sophisticated security and data anonymization technologies as well as offer simple, centralized consumer services for privacy disclosure, review and deletion of collected profile information, opt-in, opt-out, etc. In exchange, advertisers, ad networks, publishers, aggregators and mobile operators will receive “clean”, i.e., privacy-safe, targeting services without ever having to touch sensitive information and without having to endure the scrutiny of privacy watchdogs. This is an important value proposition.

Both the testable certification and the privacy-safe targeting services must be provided by independent, third party, for-profit entities whose business models are tied to the overall growth of the mobile advertising market and not any individual participant’s success. This is the only way to bring in the investment necessary to make this work safely and effectively at network scale yet at the same time ensure good behavior that is in the interest of the whole industry as opposed to any single player. That’s why this cannot be done by operators or ad networks or mobile publishers or industry associations whose data aggregation efforts typically lack the sophistication and protections necessary to reduce privacy and embarrassment risks.

The good news is that the technology to deliver massively-scalable, privacy-safe targeted advertising across the mobile Web, SMS/MMS and applications is within reach. I know entrepreneurs who are working in this space and am hearing encouraging feedback about their work from privacy professionals, operators, publishers and advertisers. The more interesting question is whether the mobile industry will grasp the crossroad it is at, realize the time-sensitive nature of the opportunity and act quickly.

– Express your opinion, comment below.

Here are some of the responses:

“The commission embraced a narrow intellectual framework as it examined online marketing and data collection for this proceeding. Since 2001, the Bush FTC has made industry self-regulation for privacy and online marketing the only acceptable approach when considering any policy safeguards (although the Clinton FTC was also inadequate in this regard as well). Consequently, FTC staff—placed in a sort of intellectual straitjacket—was hampered in their efforts to propose meaningful safeguards.” – Jeff Chester, Exec. Director, Center for Digital Democracy.

“The FTC did a punt” on the question of sensitive information regarding health, finances or children…”Instead of specifically saying how this information should be treated, the FTC encouraged the industry, consumers and privacy advocates to develop more specific standards to address the issue. This area is very difficult and we were looking to the FTC to help set specific standards. The bottom line is that the FTC fell down on the job.” – Pam Dixon the executive director of the World Privacy Forum.

“There are some populations, namely children and teenagers, that are so vulnerable that we should say ‘hands off’, don’t target these groups. They are not sophisticated or cognitively able to make decisions in a meaningful way about their data. It’s predatory to take their information and target them when they are not aware of what they are giving up,” – Corie Wright, a senior counsel with the Institute for Public Representation.

In the Federal Trade Commission’s 48-page Staff Report on Behavioral Advertising, there are four principles, which are voluntary at this point.

- Transparency and Consumer Control: websites must allow users to clearly understand how the site plans to use behavioral targeting. There is also a recommendation to give users a simple method to opt-out of the site’s targeting tools.

- Reasonable Security, and Limited Data Retention, for Consumer Data: Companies should also retain data only as long as is necessary to fulfill a legitimate business or law enforcement need.”

- Affirmative Express Consent for Material Changes to Existing Privacy Promises: A company must protect consumer data. If they are bought or merge with another company, those protections must be intact unless consumers agree to the changes. If the company revises its policies on privacy, they must receive users’ consent before implementing the new rules.

- Affirmative Express Consent to (or Prohibition Against) Using Sensitive Data for Behavioral Advertising: If companies want to collect “sensitive” personal data, it must get permission before it starts collecting.

– Express opinion, comment below.