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Copyright 2010 PrivacyChoice LLC Page 1 DRAFT Version 1.1
privacychoice
Privacy Checklist for Behavioral Ad Targeting
This checklist is a resource for ad networks, data companies, advertisers and agencies who use online behavioral ad targeting. Tocompare the privacy practices for hundreds of ad companies, see the PrivacyChoice Index.For news and updates on industry and
governmental requirements, read the PrivacyChoice Blog.Please send your feedback to contact@privacychoice.org.
Consumer experience Weak Basic Better
Company homepage
Where curious users end up
Privacy-policy link is placed at thebottom of homepage, and opt-outlink buried in privacy policy textPrivacy-policy page and opt-outpage are both prominently linkedfrom corporate homepage
Opt-out button is placed onhomepage above the fold
Example: BlueKai
Consumer-friendly privacy policy
Statement on consumer data collected acrossnetwork (versus corporate website users)
Consumer and corporate policiesare not separated and may beconfusingComplete consumer privacystatement is separate fromcorporate privacy statement, and isconcise and easily readable
Profile information page
List of demographics, behavioral segments,queries or other data associated with the profile
None Users can see specific ad-targetingsegments associated with theircomputer, and can removeindividual segments
Example: BlueKai
User can see all targeting categories(including segments, demographicsand search queries, if applicable),and remove segments permanently
Example: Yahoo!
Tracking domain top page
What a user sees when they try to find your site based on your tracking cookie domain(when different from your company domain)
User sees site-not-found error Tracking URL redirects to companyhomepage
Copyright 2010 PrivacyChoice LLC Page 2 DRAFT Version 1.1
Stated policies Weak Basic Better
Adherence Statement
Undertaking required by self-regulatory principles
No statement of adherence Your privacy policy includes thestatement of adherence required byIAB Principles
Example: “We adhere to the
Self-Regulatory Principles for OnlineBehavioral Advertising<link>, which provide for consumer notice and choice in the collection of information about your interests and activities
.”
Your privacy policy also states thatadherence is subject to independentreviewAnonymity
Whether you collect or use personally identifiable information
No statement, or statement thatrelies on undefined terms like
“Personally IdentifiableInformation”
Your policy expressly disclaimscollection or use of categories of identifying information (email,name), without relying onundefined terms such as
“P
ersonallyIdentifiable Information
”
Example: “We do not collect or use
your name, email address or other information that could identify you
personally.”
If you collect or use identificationinformation, your policy states thatit is kept separate from behavioralinformation
Example: “
Our systems are designedto ensure that information aboutactivities or interests cannot beassociated with your name, emailaddress or other information that
could identify you personally.”
Copyright 2010 PrivacyChoice LLC Page 3 DRAFT Version 1.1
Stated policies Weak Basic Better
Sharing
Under what circumstances consumer data isshared with unaffiliated companies (beyond normal vendors and legal process)
No sharing policy is stated, or policy
is stated ambiguously (“we sharewith business partners”) or without
precise defin
itions (“we shareaggregated information”)
Your privacy policy states that onlynon-personally identifiableinformation is shared
Example: “Because we do not collect
or use information that could identify you personally (such as your name or email address), we cannot and donot share such information withothers
.”
Policy separately addresses sharingof click-stream data (such as URLsvisited, such as nytraveler.com) andsegment data (demographics or
inferred intentions, such as “NYtravel buyer”)
Example: “We only share
anonymous profile data that is inferred fromyour activities and actions. We donot share specific data about any individual actions or sites visited
.”
Your privacy policy confirmscontractual restrictions placed onshared data
Exam
ple: “Our partners and
customers are contractually prohibited from associating shared information with your name, email address or other information that
could identify you personally.”
The technical mechanisms forsharing data are explained
Example: “We m
ay share anonymousinformation by allowing our partnersto associate shared anonymous profile information with their own
cookie on your computer.”
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