Google Analytics: Remarketing & Privacy Policy change in May 2017

On April 7, Google informed its users that it would update one of the features of its web analytics service – Google Analytics. Google would enable cross-device remarketing campaigns.

What is remarketing in Google Analytics?

Remarketing campaigns are used to „show ads to people who have visited your website or used your app“. It is a common method for online marketers or businesses to target people, who already showed an interest in a product or service and there is a higher chance that they might be interested to buy your product or service.

The biggest advertisers offer remarketing services, including Google or Facebook. In the majority of cases, you may target people, who visited certain section of your website. The advantage of Google Analytics is that it enables you to target people based on various user activities, such as a number of visited pages, click on specific buttons on your website, etc. If you integrate your Google Analytics account with your Google AdWords account, you may target these people by paid campaigns.

If you use Google Analytics for your website, there are several requirements you should already be using (see Google’s article about policy requirements).

What is the change?

At present, it is possible to target users only at the device (or more specifically, a browser) they used to visit your website. If someone visited the website using a mobile device, the person will be a part of a remarketing campaign, but the ads would show only when browsing using the mobile device (a specific browser). The ads would not show, if they used a desktop computer.

After May 15, 2017, Google would be able to target people across devices. The is the Google’s description of the method:

„Where users have chosen to enable Google to associate their web and app browsing history with their Google account, and to use information from their Google account to personalize ads, Google will use data from its signed-in users together with your Google Analytics data to build audience lists for cross-device remarketing.”

It means that in our example, if the user visited a website using a mobile device and became a part of a remarketing campaign, they would see ads at any type device associated with their Google account.

What is the impact of the change?

If you want to use a remarketing feature in Google Analytics after May 15, 2017, you have to modify your privacy policy. Otherwise, you cannot use remarketing feature via Google.

Therefore, it is necessary to update your privacy policy. Google provided us with a basic guideline on the update.

Basically, it will be necessary to add a description of new methods of data processing for the purpose of remarketing campaigns.

It should include these two things:

• First, for users on your site, Google Analytics will collect Google-authenticated identifiers associated with users’ Google Accounts (and therefore, personal information).
• Second, Google Analytics will temporarily join these identifiers to your Google Analytics data in order to support your audiences.

What about legacy campaigns?

It is not clear, to what extent it would be possible to target users that did not use your website with an updated privacy policy. From the data protection perspective, it is more likely that such users should be excluded from campaigns. That means that you might have to stop the campaigns running with these audiences.

However, it is possible that there would be different opinions on this issue. Google might also publish additional guidelines on the technical details of legacy remarketing campaigns.

Conclusion

Basically, there are two main obligations resulting from this change:

1. if you want to use remarketing campaigns in your online marketing campaigns, review and update your privacy policy to include new methods of data processing

2. do it quickly, so that you can start collecting users into your remarketing audiences pursuant to new rules as soon as possible

At dataitlaw.com, we will cover any new developments about the issue.