Guidelines 08/2020 on the targeting of social media users – version for public consultation
Paragraph 5.2.2 Data provided by the user of the social media platform to the targeter
54 Targeting can also involve data provided by the data subject to the targeter, who then uses the data collected in order to target the data subject on social media. For example, “list-based” targeting occurs where a targeter uploads pre-existing lists of personal data (such as e-mail addresses or phonenumbers) for the social media provider to match against the information on the platform. In this case, the social media provider compares the data uploaded by the targeter with user data that it already possesses, and any users that match are added to or excluded from the target audience (that is, the ‘cluster’ of persons to which the advertisement will be displayed on the social media platform). The social media provider may also allow the targeter to ‘check’ the list prior to finalising it, meaning that some processing takes place even before the audience has been created.
Ms. Jones contacts Bank X to set up an appointment regarding a possible mortgage because she is buying a house. She contacts the bank via e-mail to set up the appointment. Following the appointment, Ms. Jones decides not to become a customer of the bank. The bank has nevertheless added the e-mail address of Ms. Jones to its customer e-mail database. Then, the bank uses its e-mail database, by allowing the social media provider to ‘matching’ the list of e-mail addresses it holds with those held by the social media platform, in order to target the individuals concerned with the full range of financial services on the social media platform.
Mr. Lopez has been a customer at Bank X for almost a year. When he became a customer, he provided an e-mail address and was informed by Bank X, at the moment of collection, that: (a) his e-mail address would be used for advertising of offers linked to the bank services that he is already using; and (b) he may object to this processing at any time. The bank has added his e-mail address to its customer e-mail database. Afterwards, the bank uses its e-mail database to target its customers on the social media platform with the full range of financial services it has on offer.