Predictive Targeting Networking (PTN)
29/02/2012 until 28/02/2014
Initial Certification on September 10, 2009
IP addresses of Internet users visiting a website that makes use of PTN 2.1 technology are anonymised by an independent third party who serves as a proxy.
nugg.ad provides its customers with guidance on how to implement PTN 2.1 in line with data protection requirements.
Data Subjects’ Rights:
nugg.ad offers a so-called topic monitor to Internet users. By means of this new feature, users can learn about the categories they have been classified in by PTN 2.1 as well as to opt-out from / opt-in to being tracked by means of PTN 2.1. The topic monitor is available at https://mtm.nuggad.net/en.
The results of the re-evaluation demonstrated that PTN 2.1 meets the EuroPriSe interim requirements for OBA (Online Behavioural Advertising) services as stipulated in the EuroPriSe position paper on the impact of the new “Cookie Law” on certifiability of behavioural advertising systems according to EuroPriSe and the follow-up paper on this. Both documents are available at www.european-privacy-seal.eu/results/Position-Papers.
The new “Cookie Law”, Article 5(3) of the amended ePrivacy Directive, requires prior informed consent to be collected from users as a precondition for the legitimate storage of OBA tracking cookies on users’ devices. EuroPriSe’s interim requirements that take account of the announcement of a “discussion period” by the Article 29 Working Party only call for first steps towards prior opt-in (amongst others). Consequently, the recertification does not confirm compliance of PTN 2.1 with the prior opt-in requirement of Article 5(3).
PTN 2.1 is a service that offers predictive behavioural targeting to publishers and advertisers in the area of online marketing. The purpose of PTN 2.1 is to support customers in optimising effectiveness of advertisements.
Predictive behavioural targeting as offered by nugg.ad is based on a method that links web-browsing behaviour and survey results with algorithms derived from the field of machine learning. With the implementation of PTN-technology into a website, the click behaviour of a website visitor is analysed by means of http cookies and tracking pixels.
Since the initial certification of PTN 2.0 in 2009, important legal changes have taken place: Artikel 5(3) of the ePrivacy Directive (2002/58/ED) was amended to the extent that (inter alia) OBA tracking cookies may only be used on condition that prior informed consent of users has been collected. The Article 29 Working Party provided guidance on how to interpret this legal provision in its opinion 2/2010 on online behavioural advertising. In this opinion, the working party announced a “discussion period” with the OBA industry. In response to this announcement, EuroPriSe defined interim requirements for OBA services that are valid as long as the discussion period lasts (details on these requirements are provided below).
Compared with PTN version 2.0 that was subject to the initial certification version 2.1 comes with some new features (details on these are provided in the Short Public Report):
The (amended) Target of Evaluation includes:
- nugg.ad PTN 2.1 services
- processing activities on behalf of customers (website owner and publisher): Tracking of users by means of tracking pixels and cookies
- Processing activities as controller: Conduct of surveys towards Internet users and maintenance + improvement of statistic model (aggregated data) for predictions
- Provision of privacy functionalities for Internet users on the website www.nugg.ad: Landing page, topic monitor, opt-out + (ex post) opt-in functionality
- Technical and legal interfaces with customers, sub-processor (server hosting + operation of IP address anonymiser) and Internet users
- Optional features of PTN 2.1
- Standard Plus (cross publisher/ad-network use of data for statistical model)
- Campaign Management
- Use of special interest categories besides the standard interest category tag list
- Enrichment of statistical data e.g., by “Nielsen data”
The ToE does not include:
- Server hosting + operation of IP address anonymiser
- Display of ads via the respective ad server
- Processing of customers’ (website owners’, publishers’ and advertisers’) as well as sub-processor’s data for the purpose of performance of the respective contract
- Transmission of data via third-party networks (mobile network, Internet)
- Customer hardware (servers)
- Customer services (websites)
- Internet users’ hardware and software
PTN 2.1 meets the EuroPriSe interim requirements for OBA:
- nugg.ad offers its customers the possibility to display an icon at the edge of an ad. The icon links to a nugg.ad landing page (cf. below). First implementations of this icon solution are already in place.
- nugg.ad’s customers are contractually pledged to inform users about the utilisation of PTN 2.1 on their websites.
- Users are provided with the possibility to opt-out on nugg.ad’s homepage, on the landing page and by means of the topic monitor. Opting out results in nugg.ad’s tracking cookies being deleted.
- Users are provided with the possibility to opt-in on nugg.ad’s homepage, on the landing page and by means of the topic monitor.
- Life time of tracking cookies is limited to 26 weeks. If a user opts in, s/he is tracked for a maximum of 52 weeks.
- IP addresses of users are anonymised by means of a third party anonymisation service.
- nugg.ad dispenses with the use of categories that qualify as sensitive data under Art. 8 of Directive 95/46/EC and with the use of categories that are specifically designed to target children.
- The topic monitor (https://mtm.nuggad.net/en) allows users to learn about the categories they have been classified in by PTN 2.1 according to their surfing behaviour. The topic monitor is prominently linked on nugg.ad’s homepage and the landing page.
- nugg.ad makes use of controller – processor agreements that comply with the requirements of Art. 17(2) – (4) of Directive 95/46/EC (as well as with the requirements of § 11 Abs. 2 S. 2 BDSG – German Federal Data Protection Act).
Initial Certification 09/2009
PTN 2.0 is provided to operators or publishers of websites. Customers can implement the service in order to gain a better and user optimised delivery of advertisements on the website.
A customer who wants to use PTN implements a web-bug on his website that is used to track basic user behaviour on the website. Each webpage of the website is classified to a certain category (e.g., sports or culture). If a user visits a webpage, the category the webpage belongs to is counted and stored in a user cookie. This cookie has a maximum lifetime of 26 weeks.
Click behaviour data of users is enriched with information on demographics, product interests and potential lifestyle. To gain the latter information, a small, random sample of website visitors is presented an online questionnaire containing questions to pinpoint demographics, lifestyle and product interests.
Questionnaire information is stored in the nugg.ad system along with a hash code. Furthermore, the click statistics of the respective user are also stored with this hash code in the nugg.ad system. No personal data such as name or address of users is stored in the system. nugg.ad uses the above-mentioned data to build statistical models about general user behaviour based on interests.
Formerly Certified Versions