Posts Tagged ‘Lotame’

Opting-in with Search and Share

April 22, 2010

The PrivacyChoice project started nearly a year ago with this goal: Help make consumer privacy choices understandable and actionable.

To this end, we created tools for users and websites to understand how behavioral information is collected. We have compiled a comprehensive public database of online tracking companies and privacy practices. Through this blog, we have provided a choice-driven perspective on developments in the ad-targeting ecosystem. We have interacted privately with scores of ad networks to make privacy disclosure and processes more effective. Driven by word-of-mouth, PrivacyChoice has facilitated opt-outs for nearly 200,000 visitors, comprising nearly 10 million opt-out transactions.

Now it’s time to explore the other choice a consumer may want to make when it comes to their online interests and advertising: the decision to opt-in.

The idea of Search and Share is simple: Enable consumers to easily capture some of the advertising value of their own searches, and put that value to use for causes they select. Consumer searches create billions of dollars in value for companies like Google. Why shouldn’t consumers have a greater stake?

How it works. Install the Search and Share browser add-on (Firefox or Chrome) and you will see an new button on Google — “Search and Share.” Use it and your search query is made available not only to Google, but also to other selected advertising companies who pay for that anonymous data, in order to target ads more effectively. All of the proceeds go to causes you select, and you stay in touch with those causes through subtle messages and tweets next to your search results. You can search in the same way as you always do, and nothing else about your Google search experience will change.

What it means for user privacy. Search and Share adheres to three key privacy requirements:

  • Anonymity. No registration is required. No email or other personal information is required or collected. Participating ad companies collect no personal information and have committed to keep users anonymous.
  • Control. The user can always choose whether to share a particular search; each instance of data sharing involves choice. (And the functionality is completely disabled when the user chooses private browsing mode.) The ‘Search and Share” button continuously reminds the user that the service is present. The cause messages that appear on search results pages confirm that a search has been shared. Uninstallation is easy, and includes a one-click opt-out from all networks.
  • Transparency. For each search they share, the user can see the companies who received it and their policies. Each participating ad company also provides consumers with a view of the interests in their profile.

Who’s behind it. A great group of folks have come together to support the Search and Share project, from Cause Ambassadors to add-on developers. We’re also grateful for the support of NAI members Lotame and BlueKai, as participating ad companies.

As a companion project to PrivacyChoice, Search and Share gives me an opportunity to see the privacy landscape through two new and important perspectives: First, that of the publisher seeking to monetize an audience of consumers, and second, that of the consumer who is comfortable with interest-based advertising and now has an even more tangible reason to engage with it.

I’ll report back as we start to promote the service and gather consumer input. Please give it a try, and learn more about the details in our FAQ. Your comments will be much appreciated.


Progress at Lotame

April 30, 2009

I can report that the folks at Lotame have been quite responsive to the the questions raised in prior posts.  Here’s the update:

First, on the deletion from their privacy policy of the promise not to use “sensitive information” for behavioral targeting, Lotame has confirmed that they do indeed consider themselves bound by the NAI rule.  They will not use such information without “opt-in” consent from the consumer.

Where we still disagree is on whether they should retain the express promise in their privacy statement. Lotame and the NAI are comfortable not including the statement, since a user can find it on the NAI site.  My take is that if that’s the policy, why not say it, since it reassures consumers and establishes a stronger record of the policy? What’s the downside?

How’s this for a compromise — Charles Curran at the NAI should create a single page in human readable form (plain english) that includes the binding NAI rules, and all the NAI members can directly link to it. 

PS I’m not talking about this page, I’m talking about a page that actually summarizes the rules in this document (PDF).  It can’t hurt to have that available for members of Congress and would-be regulators, so they can really see a commitment to consumer understanding and choice. I’ll even volunteer to write the summary!

Second, Lotame has added very useful content to their opt-out process, including links to other opt-out resources (including the privacychoice opt-out wizard).  Highly commendable and, in a competitive sense, smart — if a consumer is opting out of your ad network, why not let them opt out of competing networks as well?

UPDATE:  I just noticed that Lotame also added a very helpful and prominent opt-out button on the top page of their website. They’re setting a terrific example and I hope and expect to see more networks follow them and Media-Six-Degrees.

Lotame’s new privacy policy: incorporation by reference?

April 27, 2009

As first mentioned in an earlier privacychoice post, Lotame reports the good news that they have joined the Network Advertising Initiative, and as part of that move, is revising the Lotame privacy policy.  Lotame also has been added to the NAI opt out page.


It’s a smart move on Lotame’s part, and one that deserves praise. But as often is the case, I’m still left with a few questions, answers to which  I hope Lotame can provide.  (I’m posting these questions on their site as well.)

Here’s how the policy changes are explained in Lotame’s announcement:

In connection with joining the NAI, we have made some revisions to our privacy policy. Although our prior policy was generally consistent with the NAI’s standards, we simplified our language in some areas of the policy in deference to the more detailed coverage of these points in the NAI principles, which will govern our conduct. In addition, in order to demonstrate our leadership on issues of privacy, we have voluntarily adopted a specific time period of 9 months to limit our retention of the anonymous user data we collect. We are joining only a few other leading companies in our industry in taking on this type of specific and unqualified data retention policy.

Here are some areas requiring clarification:

1. Is Lotame incorporating by reference the NAI policies in their entirety, as written and interpreted by the NAI?  I don’t recall seeing that approach in many other privacy policies.

Substantively, it is of course helpful for consumers to know that a particular ad network is abiding by a standard like NAI’s rules.  But it is not helpful when a consumer has to undertake a research project to figure out what those policies may be. In this case, Lotame’s link to the NAI site still leaves the consumer to find and interpret the NAI’s policy document (a PDF that is, for some reason, buried in the news release section of the NAI site, rather than in the over view of principles). 

In short, incorporating the NAI principles by reference this way is a very weak way to inform consumers of Lotame’s privacy policies.  In fact, it would be hard to say that it satisfies the NAI’s requirement in the policies themselves that each member “clearly and conspicuously” post their policies on their website.

2. A change in the policy that is not mentioned specifically in Lotame’s announcement is the deletion of the following language from the previous policy statement:

In addition, we do not tailor ads based on behavioral categories that are deemed sensitive by the Network Advertising Initiative (NAI).

The NAI policy (in Section II(3)(iv) of the 2008 Principles) requires a consumer opt-in in order to use sensitive information for targeting; so the inference (see discussion above) is that Lotame is now bound by that rule. However, this is important enough to merit a specific statement in Lotame’s privacy policy, particularly in light of the deletion.

The Lotame experience highlights a few lessons when it comes to changes in privacy policies.  Most important, privacy policies should be versioned on websites (as Google now does), and marked to show changes from the prior version. This is particularly important when the date of a policy change may affect acceptable practices with information collected before or after that date, a situation expressly contemplated by the NAI.

Lotame’s Revised Privacy Policy: One step up, two steps back

April 22, 2009

Lotame, a behavioral targeter focused on social networks, updated their privacy policy yesterday (see full comparison below).  On balance, the new policy looks less privacy-friendly in important respects.

Here are the details:

1.  They added a reference to the Network Advertising Initiative, although as of the time of this post, they are not listed on the NAI opt-out page.  Perhaps that’s coming soon?

2.  They deleted a promise not to target based on sensitive information, including health-related information.  Pharmaceutical marketing appears to be on Lotame’s radar, having recently sponsored a conference on the topic. If this signals a plan to get more aggressive in behavioral targeting in sensitive areas like health, Lotame is swimming against the tide and tempting the regulators.

3.  On data retention, a promise only to retain user info for as long as the business need continues has been replaced by a promise to keep it only nine months after collection.  (Same question here as we had for BlueKai   — do the profiles constructed with user information live on past the nine month period, even if the cookie-based logs are trashed?)

4.  Finally, maybe this is a detail, but they deleted a statement that said, if they make material changes to their policy, those will only apply to data collected after announcement of the changes.  So, if Lotame’s practices truly have changed as to sensitive information, does this mean that they can now use my sensitive information for targeting even though  they collected it under a prior promise not to use it?

Overall, Lotame gets credit for their earlier adoption of an opt-out process with a non-unique cookie, and (once they complete it) adding their opt-out process to the NAI system.  But these new steps backward are concerning (particularly in the area of sensitive information).  If Lotame is indeed to be added to the NAI group, Charles Curran of the NAI should look closely at these changes.


Last Updated:   March 6April 21, 2009

Lotame and Consumers:  Our services are designed to provide consumers with relevant advertising and content at Web sites you visit. These marketing activities help to underwrite the cost of the content and services made available to you online. 

As part of Lotame’s commitment to respect privacy concerns and implement industry-recognized standards, we are a member of the Network Advertising Initiative (NAI). Lotame complies with NAI’s Self-Regulatory Principles which are designed to inform consumers about data collection and advertising practices across multiple web sites and provide the ability to opt out. For more information or to opt-out of behavioral advertising by Lotame or other NAI member companies, please visit the NAI web site at

 Data We Collect and Use:  To deliver our services, we collect, organize, and use data reflecting your interactions with a variety of Web sites.  The information we use includes items such as the date and time you visited a Web site, your browser information, your IP address, your browsing behavior, and interests you express or imply at social networking sites or other Web sites you visit. We recognize your computer over time by setting a unique browser cookie which your browser relays to our servers when you visit Web sites that are our customers.  We analyze this non-personal information and organize it into anonymous user profiles, groups, and audiences, based on factors such as age, gender, geography, interests and online actions.  We and our customers then use these anonymous user profiles, groups, and audiences to design and deliver targeted advertising campaigns or other relevant content.  We and our customers also use this data for other related purposes (for example, to do research regarding the results of our online advertising campaigns or to better understand the interests or activities of Web site visitors.)

The behavioral categories we use to tailor the ads you may see or for related purposes do not use personal information such as your name, address, e-mail address, phone number, birth date or social security number.  Our technology and services are designed to limit our use of consumer data to anonymous, non-personal information.  In addition, we do not tailor ads based on behavioral categories that are deemed sensitive by the Network Advertising Initiative (NAI).  
Opting Out:  We provide you with the ability to opt-out of our use of information about your previous browsing  to tailor the ads you see.  You can opt-out by clicking here here and following the instructions provided.  Note that after choosing to opt-out, if you use a different computer or a different browser, or if you delete or block browser cookies, you may need to repeat the opt-out steps.  Most web browsers also enable you to block browser cookies. You can refer to your web browser’s documentation to get more information on how to block or delete cookies directly through your browser settings.  
Data Sharing:  When you visit a Web site that shares information about your activity with Lotame, we will use that information to tailor relevant ads to you at that and other Web sites you visit, or for research and analysis.  We may also share non-personal information with companies such as advertisers, agencies, ad networks, or exchanges to enable them to analyze user behaviors or to tailor the ads that you encounter.
There are other limited circumstances in which we may share data.  We may provide access to the non-personal information we collect to service providers who are assisting us with storage, analysis, or other services.  These service providers are subject to confidentiality restrictions, and are not authorized to utilize the information in any way other than to provide their services to us.  If our company is sold, assigned, transferred, merged, files for bankruptcy protection, or undergoes some other change to its corporate form, information may be transferred as part of that transaction or change.  In these instances, we will take steps to ensure that our data is maintained in accordance with this privacy policy.  In special cases, we may also be required to release information in order to comply with requests from law enforcement, government agencies, and similar entities, or to otherwise protect our clients and users.  
Data Retention:  We retain the anonymous user data we collect only for so long as it assists us in fulfillingup to nine (9) months from the business needs described of its collection.    
Security:  Lotame has implemented security measures which are reasonably designed to protect the user data which Lotame collects from unauthorized access, disclosure, or modification.
The Web Site:  Lotame collects non-personally identifiable usage data at, which we use to improve our web site and services.  In response to requests for information, Lotame also collects voluntarily-supplied personal contact information.  We do not share, sell, rent or trade any contact or personally identifiable information with third parties (except with service providers in the manner described above).  If you would like to update, delete, or revise any personal information you submitted to us through, please send your request to  

Changes:  We reserve the right to revise this privacy policy at any time.  If we change the policy, we’ll notify you by posting the new policy here, changing the date at the top, and indicating on our homepage that the privacy policy has been updated.  If we make any material changes to the policy, the material changes will only apply to data we collect after we post and announce the revised policy.  

Contact Us:  To contact us with any questions, comments, or suggestions, please email us at or write to us at the address below.  

Lotame Solutions, Inc.
6085 Marshalee Drive
Elkridge, MD 21075