In its latest decision, the Online Interest-Based Advertising Accountability Program highlighted the need to provide consumers with “enhanced notice” when data is collected for interest-based advertising (IBA) on either a desktop computer or smartphone.
Tipped off by a consumer complaint, the Accountability Program reviewed the website of sneaker retailer Finish Line and observed that data was collected by “a number” of third-party companies known to engage in IBA. A full examination of Finish Line’s compliance with all applicable requirements of the Digital Advertising Alliance’s (DAA) Principles followed.
The examination also revealed that at least one third party was collecting latitude and longitude coordinates to the sixth decimal place, the Accountability Program added.
Finish Line amended its privacy disclosures to include language that the company may collect precise location data for IBA purposes and provided full instructions to consumers for disabling the collection. In addition, the company developed a pop-up dialog box that users see after they first open the Finish Line app, which describes the collection and use of location data that takes place and provides a link to the precise location data section of Finish Line’s IBA disclosure.
“By providing an up-front notification directing users to a disclosure about the collection of precise location data for IBA purposes, Finish Line ensured that users are informed not only about the fact that their precise location will be collected, but also about how their data is used,” the Accountability Program explained in its decision.
To read the Accountability Program decision, click here.
Why it matters: “In the mobile environment as well as the desktop space, first parties must ensure that consumers are provided with enhanced notice of third-party data collection occurring on their digital properties,” the Accountability Program reiterated in the decision. “And where certain sensitive data types are at issue, companies should be especially careful to get consumers’ consent before using them for IBA. The requirement to provide timely, up-front notice to consumers sits at the heart of a self-regulatory regime that relies on respect for individual autonomy.”