F1(c). Access to advertising targeting policies

The company should offer advertising targeting policies that are easy to find and easy to understand.

Elements:

  1. Are the company’s advertising targeting policies easy to find?
  2. Are the advertising targeting policies available in the primary language(s) spoken by users in the company’s home jurisdiction?
  3. Are the advertising targeting policies presented in an understandable manner?
  4. (For mobile ecosystems): Does the company clearly disclose that it requires apps made available through its app store to provide users with an advertising targeting policy?
  5. (For personal digital assistant ecosystems): Does the company clearly disclose that it requires skills made available through its skill store to provide users with an advertising targeting policy?

Definitions:

Advertising targeting policies — Documents that outline a company’s rules governing what advertising targeting parameters are permitted on the platform.

App — A self-contained program or piece of software designed to fulfill a particular purpose; a software application, especially as downloaded by a user to a mobile device.

App store — The platform through which a company makes its own apps as well as those created by third-party developers available for download. An app store (or app marketplace) is a type of digital distribution platform for computer software, often in a mobile context.

Clearly disclose(s) — The company presents or explains its policies or practices in its public-facing materials in a way that is easy for users to find and understand.

Easy to find — The terms of service or privacy policy is located one or two clicks away from the homepage of the company or service, or is located in a logical place where users are likely to find it.

Easy to understand / understandable manner — The company has taken steps to help users actually understand its terms of service and privacy policy. This includes, but is not limited to, providing summaries, tips, or guidance that explain what the terms mean, using section headers, readable font size, or other graphic features to help users understand the document, or writing the terms using readable syntax.

Mobile ecosystem — The indivisible set of goods and services offered by a mobile device company, comprising the device hardware, operating system, app store, and user account.

Personal digital assistant ecosystem — A personal digital assistant (PDA) ecosystem consists of an artificial intelligence-powered interface installed on digital devices that can interact with users through text or voice to access information on the Internet and perform certain tasks with personal data shared by the users. Users can interact with PDA ecosystems through skills, which are either made available by third-party developers/providers or the PDA itself.

Skills  — Skills are voice-driven personal digital assistant capabilities allowing users to perform certain tasks or engage with online content using devices equipped with a personal digital assistant. Personal digital assistant ecosystem skills are similar to mobile ecosystem apps: users can enable or disable built-in skills or install skills developed by third-parties through stores similar to app stores.

Skill store — The platform through which a company makes its own skills as well as those created by third-party developers available for download. A skill store (or skill marketplace) is a type of digital distribution platform for computer software.

Indicator guidance: In addition to providing accessible ad content policies (F1b), companies should also clearly disclose their ad targeting policies. The ability for advertisers or other third parties to target users with tailored content—based on their browsing behaviors, location information, and other data and characteristics that have been inferred about them—can significantly shape (or in some cases, distort) a user’s online ecosystem. Targeting, which can include both paid and unpaid content, can amplify offline social inequities and can be overtly discriminatory. It can also result in so-called “filter bubbles” as well as amplify problematic content, including content intended to mislead or to spread falsehoods.

Therefore, companies that enable advertisers and other third parties to target their users with tailored ads or content should publish targeting policies that users can easily find (Element 1) and understand (Element 3), and that are available in the primary languages of the company’s home market (Element 2). For mobile ecosystems (Element 4) and personal digital assistant ecosystems (Element 5), companies should disclose a requirement for apps or skills made available through their app stores or skill stores to provide users with an accessible advertising targeting policy.

Users should be able to access and understand these rules in order to make informed decisions about how they are being targeted with ads. Note that ad targeting policies can often be found in a company’s broader advertising policy. This indicator does not require companies to have a discrete policy specifically on ad targeting. It does however expect companies to have clearly accessible and understandable policies governing ad targeting on its platform or service. .

Potential sources:

  • Company advertising policies
  • Company business help center
  • Company terms of use
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