DAA Rolls Out Long-Awaited “AppChoices” Mobile Opt-Out Solution

Published On February 26, 2015 | By Ken Dreifach | Mobile Privacy

The Digital Advertising Alliance (“DAA”) this week rolled out its long-awaited “AppChoices” mobile advertising solution, intended to complement the current “AdChoices” icon, DAA Consumer Choice pages, and opt-out programs. These programs currently enable third-party web and mobile ad targeting companies to place icons in ads across the online ecosystem, directing consumers to the www.aboutads.info opt-out page and other opt-out channels.

The new app, originally developed from a Ghostery prototype, is available for free on the Google Play, Apple App Store, and Amazon Store. The app is intended to help third-party platforms fulfill the DAA self-regulatory principles requirement of choice – in particular, to provide the sort of granular choice that allows consumers to opt out of targeted advertising on a platform-by-platform basis.

The currently favored method for most third-party mobile advertising platforms is to rely on and honor device and platform based opt-outs. For instance, on an iOS 8 device, consumers can limit the delivery of tailored advertisements with relative ease: (1) Open Settings; (2) tap “Privacy”; (3) tap “Advertising” and (4) turn “Limit Ad Tracking” to ON. On Android devices, the “Opt out of interest-based ads” setting is located in Google Settings (rather than device settings), under “Ads.” In each case, these options are generally considered to be reasonably intuitive to users, accessible, and uniform.

The new AppChoices application, however, would give consumers further, more granular choice – permitting them to choose to opt-out of some mobile ad platforms and service providers, but not others. For instance, consumers might wish to opt-out of anonymous cross-device, but not geographic-based, ad tailoring. Or, consumers might wish to opt-out of a particular company’s tracking solution after reading a negative media report.

What’s the “Best Practice” for Mobile Opt-Out?

The AppChoices solution no doubt will be an additional, useful tool for many consumers who are particularly sensitive about targeted advertising – and who are sufficiently informed and proactive to find and download it. For many consumers interested in privacy, on the other hand, the device settings controls already provide a sufficient way to express their opt-out preferences (albeit in “all or nothing” fashion).

For this reason, some ad platforms have taken a wait-and-see approach toward App Choices – which launched with 18 listed companies. Some platforms have determined that from a practical and policy standpoint, the device settings choices currently provide a sufficiently easy, accessible and intuitive opt-out option for consumers. As of today, the NAI Mobile Application Code of Conduct supports this view (at p. 3), stating that these device-level controls are sufficient:

Opt-Out Mechanism is an easy-to-use mechanism by which users may exercise choice to disallow Cross-App Advertising with respect to a particular browser or device.

Commentary: An industry-standard mechanism for expressing choice regarding Cross-App Advertising has not yet been established. In lieu of this mechanism, member companies will be required to maintain or describe how to access an opt-out mechanism that is (1) reasonably easy for users to use and (2) durable, as appropriate given the nature and characteristics of the technology and use. These standards will evolve in step with the technologies available for allowing users to express choice. Platform-provided choice mechanisms that satisfy the above requirements are sufficient to meet the definition of Opt-Out Mechanism.

AppChoices Participants:  Who’s Listed?

At launch, the listed AppChoices participants are ActionX, BlueCava, BlueKai (Oracle), Datalogix, Drawbridge, eXelate, Millenial Media, LiveRamp, Lotame, MediaMath, OpenX, PlaceIQ, RocketFuel, Tapad, Ubimo, xAd, Xaxis, and ZiffDavis.

There are a few common threads among participants that chose to list:

  1. Several of the listed companies provide innovative data solutions that employ cross-device and cross-channel marketing and targeting capabilities. For instance, Drawbridge, Tapad and ActionX each provide cross-screen technologies – resolving and inferring common (anonymous) user identities across mobile and web platforms.
  2. Others, like Datalogix and LiveRamp, provide data “onboarding” solutions, moving de-identified offline data into anonymous online cookies.
  3. Still others, such as PlaceIQ and xAd, provide cutting-edge geolocation-based targeting solutions.

In each of these cases, these companies are using AppChoices as an opportunity to utilize yet an additional channel to provide consumer education and choice — in most cases, in addition to other channels they already participate in, through the DAA, NAI and other industry programs.

Another common thread among the 18 is that several generally act as service providers, providing matching, aggregating and inferencing tools but not necessarily handling the ad creative. This means that it may be difficult for them, in certain cases, to implement or easily ensure that downstream or upstream partners implement the DAA’s “AdChoices” icon solutions. The AppChoices programs provides consumers with another channel (in addition to current industry websites and company-provided solutions) to engage directly with such companies.

A final commonality is that the 18 listed companies are generally well known as front-runners in implementing privacy by design – some because their own large brand clients insist on it, others because they have needed to spearhead privacy solutions to new data models, and still others simply as a matter of corporate philosophy.

The DAA has indicated that significant education and outreach will accompany the post-launch of AppChoices – including webinars and more direct engagement.  Inquiries to the DAA can be submitted at here or please feel free to reach out to us for more information and strategic guidance.

Photo by Sebastiaan ter Burg from Flickr

About The Author

Ken counsels clients on complex issues involving information privacy and data law, online liability, consumer regulatory and gaming law, including regulatory response, and adherence to self-regulatory guidelines for online advertising. Ken has had more than twenty years of experience in high-profile regulatory, in-house and private practice roles, including as Chief of the New York Attorney General’s Internet Bureau. He is one of the nation’s leading authorities on the relationship between emerging advertising technologies and online privacy.

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