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How to Make a Killer Privacy Policy, for Online Advertisers

By Nathan Pabich

These days, web privacy is a hot topic. As the internet continues to change, privacy policies will need to be revisited. This year it seems as if everybody is updating their privacy policy; from Google and Microsoft to Facebook and Pinterest. 

In order to build trust between a brand and customers, companies must be clear about privacy and offer even clearer guidance along with its privacy options.

Leveraging Paid Media Channels to Support Customers’ Advertising Needs

Below, we’ll detail the paid media channels DTC leverages to support our customer’s advertising needs. You’ll find some of the links and resources to each channel’s privacy policy documentation, as well as some additional context for your team to consider.

None of this is meant as legal advice. These are merely resources for your company and legal team to review in crafting a privacy policy that is right for your organization.

The goal of your privacy policy will likely contain the following:

·         Clearly announce the name of the company that is collecting the personal information.

·         Thoroughly describe the purpose of the information being collected.

·         Provide opt-out instructions, if applicable.

·         Any other information, as required by applicable laws and regulations.

Google Ads Privacy Policy

What should you include in your privacy policy for Google Ads? The search engine giant has some recommendations for privacy policy best practices on its platform, including:

Remarketing – Remarketing is a great way to re-target audiences who have already visited your site and engaged with your brand. While many people understand that websites collect user information it’s best practice to spell out, in your Google Ads privacy policy, what information you are using and gathering.

Google says it best…“you should inform these people that you gather information for remarketing, re-engagement, or similar audiences on your website or in your app.”

General – On this page you can see exactly what information Google Ads collects about your customers, why it collects that information and how you can keep your information secure.

LinkedIn Ads Privacy Policy

What terms are you agreeing to when you advertise on LinkedIn? Let’s dive into LinkedIn’s updated privacy policy in 2021. 

General – When companies start using LinkedIn Ads Services, they’re agreeing to the company’s terms and conditions. While LinkedIn agrees to optimize your campaigns and offer businesses or third-party advertisers (like DTC) must comply with applicable law, according to LinkedIn’s privacy policy. LinkedIn reserves the right to reject, modify or terminate your Ad Services. 

Lead form ads – When creating Lead Gen Forms on LinkedIn, companies and advertisers are required to include a privacy policy URL. Essentially, businesses need to describe how they’re going to use the collected leads.

Facebook Ads Privacy Policy

When we talk about Facebook’s privacy policy, we’re also talking about the privacy policies for Instagram and Messenger. 

Facebook’s General Privacy Policy – This resource, straight from Facebook, explains what information Facebook collects from its users regarding:

  • Information and content provided, including posts, pictures, and location tags
  • Networks and connections
  • Usage and engagement
  • Information about transactions made via Facebook products
  • Information about those who users interact with on Facebook, that tells Facebook more about them.

This privacy policy resource also dives into how Facebook uses and shares its user information and data gathered on the platform.

Facebook Lead Form Ads Privacy Policy – Facebook’s “Lead Ads” allows companies to run ads that give Facebook users the ability to provide their email address or other information. In turn, Facebook asks that advertisers comply with their terms and conditions.

Microsoft Ads (Bing Ads) Privacy Policy

More and more companies continue to update their privacy policies to better explain how they’re using consumer data. Microsoft’s Bing Ads platform is no different. 

Bing Ads General Privacy Policy – Bing does not allow websites to advertise whose sole purpose is to collect data. According to Bing Ads’ privacy policy, that includes advertises for pages that link to, or redirect to such organizations:

  • Sites may not collect personal data without user consent
  • Sensitive information like financial, health, or government-related must be performed on a site hosted on a secure server.
  • Advertisers must comply with all applicable data-collection laws and regulations surrounding personal data collection.

Pinterest Privacy Policy

Many B2C companies advertise on Pinterest, a social media platform with a wide and diverse user base. We wanted to include a link to Pinterest’s updated privacy policy. Pinterest does a great job outlining how they use the data they collect, what data they collect, and what choices users have. Their privacy policy language makes it easy to understand and user-friendly.

Pinterest General Privacy Policy – The biggest update for Pinterest’s privacy policy was greater transparency. The site recently “added more details about data we collect and how it’s used, along with a new way to control whether it is used to report on ads performance.” 

Pinterest also started offering greater data collection disclosures to its users from California, in lieu of the state’s additional privacy regulations.

We think Pinterest’s privacy policy is a good example of the effectiveness of clarity. There is no need to be vague in your stated privacy policy. If you bury your privacy standards with “legalese” you’re only making your brand appear less trustworthy.

Tools to Track & Capture Customer Information

There are many other tools and platforms that use code to track or capture information about your users & customers. If you are using a HubSpot or Pardot or anything similar, you will want to seek out their guidance as well to help craft an exhaustive privacy policy for your company.

Examples of privacy pages we love:

We wanted to point out a few examples of some top-notch Privacy Policy pages for inspiration. 

Starbucks – Starbucks’ policy is very clean, easy to navigate and covers a lot of ground. Starbucks specifically calls out their use of digital ads and gives its users easy ways to opt-out of unwanted tracking or use of personal information.

From a user experience standpoint, there are a lot of ways to get in touch with the Starbucks team if you have any further concerns.  

Best Buy – While Best Buy has a clean and easy to follow privacy policy, we really like that they have an entire page dedicated to their use of digital ads and their impact on privacy. 

Best Buy provides access to a tool which scans your browser and allows you opt-out of all sorts of cookies you probably didn’t even know you had. Best Buy uses browser history and personal information to show off interest-based ads that it deems relevant to customers. It goes on to say…

The browsing history we use is collected by us and by third parties on our website, as well as other sites. We may also share your anonymous browsing history from our website and personal information with third parties to provide relevant ads. They may combine this information with assumptions based on the other websites you have visited in order to tailor ads to you. If you would like to know more about how we use and share your information, please see our Privacy Policy.”

This type of language and transparency with an external link to a privacy tool like About Ads, is an impressive disclosure. It also goes above and beyond most brands’ by spelling out consumers’ options to opt out of interest-based advertising from third party providers.

Privacy & Google Analytics (GA)

As a digital marketing agency, we love Google Analytics (GA). It’s an extremely helpful tool to track somewhat anonymized information about website visitors and their behaviors. 

The Google Analytics Terms of Service agreement requires that those who use GA must have a privacy policy in place. It goes on to spell out that those websites using GA must disclose, in that privacy policy, how data is collected, processed, and provide notice of cookies. 

We, like countless other websites, use Google Analytics. Here’s a look at our privacy policy. You can click through to read more, but the big takeaway reads as follows: “This website complies to all US national laws and requirements for user privacy.”

How GA tracks user data on websites

Google Analytics collects information about site visitor behavior. It collects this information through JavaScript code placed on each and every page on a site. As users travel from page to page, GA can pull data about sources of traffic, monthly sessions, number of unique visitors, and much more. 

[Click here to read our full blog post: “How Does Google Analytics Actually Work?”]

While that may sound like super specific information, this data is somewhat anonymized. The information GA gathers about users is more vague. When we check our GA data, we can’t see that “John Smith from Yorktown, PA visited our website three times.” We can see that a user, using a specific keyword or phrase from a particular browser, located in a certain geographic region, visited our website three times. 

How Should You Feel About Privacy Policies?

The internet evolved rapidly, and for a long time, users were blissfully unaware about their data. But that’s not the case anymore. 

The trend now is for websites to be more forthcoming with their privacy policies. Which means full disclosures about what data they’re collecting, how they’re using it, and their use of cookies. For those suspicious about what data about them is available, we recommend trying tools like About Ads, but for others, the personalized ad experience is a welcome one.

You just need to decide for yourself!

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