Earlier this summer, Google began speaking to its publisher clients about a new feature called “Limited Ads” to give them the ability to serve simple ads via Ad Manager to users who didn’t give their consent to share their cookies or other identifiers.
The feature isn’t yet available, but publishers and other ad tech observers said the tool appears so limited in scope, that they still are unlikely to be able to monetize those users at all.
The tool allows publishers to serve its direct-sold ads — specifically reservation and mediation demand, but not programmatically traded inventory — to users who have explicitly opted out from accepting cookies and being shown personalized advertising.
The launch follows Google’s decision to integrate with the updated version of IAB Europe’s Transparency and Consent Framework (the current version is TCF 2.0) — an interoperable industry framework for compliance with Europe’s General Data Protection Regulation that enables users to grant or withhold consent over how publishers, advertisers and vendors process their data.
The TCF includes 12 “purposes” for which users can consent or reject to their data being processed, such as “Purpose 1” — storing and/or accessing information on a device — or “Purpose 4” — select personalized ads.
As it stands, Google says limited ads will be requested when consent for Purpose 1 is missing but publishers — using a consent management platform, displaying a choice to readers — have managed to secure consent for Purposes 2 (select basic ads,) 7 (measure ad performance,) 9 (apply market research to generate audience insights) and 10 (develop and improve products.) Or, Google says, publishers can use the “legitimate interest” lawful basis for processing personal data under the GDPR. The legitimate interest basis requires businesses to undergo a test to determine whether their interest in collecting the data outweighs the interest of the individual for not having the data collected.
Therein lies the rub. Industry observers told Digiday that it’s highly unlikely, when presented with a consent wall, that users would cherry pick for which purposes they will and won’t consent to sharing their data — they usually choose to “reject all” or “accept all.” Many consent management platforms and publishers have also decided that they will not send legitimate interest signals to vendors if users decide to hit the “reject all” button. Plus, U.K. data protection authority the ICO has already made it clear that businesses who are using real-time bidding and claiming a legitimate interest stance won’t be GDPR compliant. (French trade publication JDN also previously reported about the Limited Ads feature’s drawbacks.)
With Limited Ads, Google’s interpretation of the TCF is so hardline that it is essentially letting a user decide whether or not a website will serve them ads at all, according to Fabien Scolan, vp of advertising at French online classifieds company Leboncoin Group.
“[Google] cannot take this type of position — this is the role of the publisher,” said Scolan. “Fulfillment of GDPR [compliance] and providing the right advertising for the right person is our mission with only one mindset: respect users’ privacy. Google [cannot decide] if it will load the ad or not. [That’s] … completely crazy.”
Adrien Thil, corporate development director at ad tech company Smart AdServer, also questioned why Google needs to obtain consent signals from the user and refuses to serve non-targeted ads that don’t require any data processing.
“Our limited ads offering doesn’t rely on cookies or mobile identifiers, but does utilize data like IP addresses in the course of ad delivery,” said Google Ad Manager product manager Eric Lo via email in response to a list of questions. “We are actively working on this offering and hope to share more in the near future.”
“This could cause issues with numerous brand advertisers when it comes to doing publisher deals on this inventory,” said Dale Lovell, UK managing director and co-founder at native advertising company AdYouLike.
Google, as part of its Privacy Sandbox initiative, along with other advertising and browser companies are currently working on proposals for how advertising functionality will work on the web without the need for third-party cookies.
“We’ll continue to invest in longer term solutions to address these issues, in the interim, we want to launch a feature to help our publishers continue to monetize when a user declines the usage of cookies,” said Google’s Lo.
The global launch of the Limited Ads feature is set to coincide with the end of the TCF 2.0 implementation grace period, scheduled for November 15. Google is currently aiming to launch a feature to allow publishers to manually trigger Limited Ads on the web by the end of October.
As for alternative solutions, Benoît Oberlé, CEO of data and advertising addressability company Sirdata, said publishers with enough resources could consider two options. One would be to set a primary, non-Google ad server to deliver contextual ads when no consent is given and to call Google’s ad server afterwards, to act as a competitor to the first ad server if the user has given consent for cookies. That way, the publisher could introduce price competition between the two ad servers if consent has been given — but it could cause lags in page loading time for users. The other scenario is to use tag management to load Google Ad Manager if consent has been given, or the alternative ad server if consent hasn’t been given. However, this requires more investment, both in terms of time and cost for the publisher.
“Of course it will be a bad user experience, but it will also probably be the last user experience if publishers don’t have any money any more — they won’t be able to proceed,” said Oberlé. “As a user, you have to think about paying for content now.”
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