Guidelines 08/2020 on the targeting of social media users – version for public consultation

Section 5.3  Targeting on the basis of observed data

61 There are several ways in which social media providers may be able to observe the behaviour of its users. For example, observation is possible through the social media service itself or may also be possible on external websites by virtue of social plug-ins or pixels.

• Example 4: Pixel-based targeting

• Mr. Schmidt is browsing online in order to purchase a backpack. He visits the website “BestBags.com”, views a number of items, but decides not to make a purchase. The operator of “BestBags.com” wishes to target social media users who have visited their website without making a purchase. To this end, it integrates a so-called “tracking pixel” on its website, which is made available by the social media provider. After leaving the website of BestBags.com and logging into his social media account, Mr.Schmidt begins to see advertisement for the backpacks he was considering when browsing BestBags.com.

• Example 5: Geo-targeting

• Mrs. Michu has installed the application of a social media provider on her smartphone. She is walking around Paris during her holidays. The social media provider collects information regarding Mrs. Michu’s whereabouts via the GPS functionalities of her smartphone on an ongoing basis, using the permissions that have been granted to the social media provider when the application was installed. Mrs. Michu is staying at a hotel that is located next to a pizzeria. The pizzeria uses the geo-targeting functionality offered by the social media provider to target individuals who are within 1km of its premises for the first time in the last 6 months. When opening the social media provider’s application on her smartphone, Mrs. Michu sees an advertisement from the pizzeria, decides that she is hungry and buys a pizza via its website.

• Example 6:

• Mrs. Ghorbani creates an account on a social media platform. During the process of registration she is asked if she consents to the processing of her personal data to see targeted advertisement on her social media page, on the basis of data she directly provides to the social media provider (such as herage, sex and location), as well as on the basis of her activity on other websites outside of the socialmedia platform using cookies. She is informed that this data will be collected via social media plug-insor tracking pixels, the processes are clearly described to her, as well as the fact that targeting involves other entities who are jointly responsible for ensuring compliance with the GDPR. It is also explained to her that she can withdraw her consent at any time, and she is provided with a link to the privacy policy. Because Mrs. Ghorbani is interested in seeing targeted advertisement on her social media page, she gives her consent. No advertising cookies are placed or collected until Mrs. Ghorbani expresses here consent. Later on, she visits the website “Thelatesthotnews.com” that has a social media button integrated on it. A small but clearly visible banner appears on the right edge of the screen, asking Mrs. Ghorbani to consent to the transmission of her personal data to the social media provider using cookies and social media plug-ins. The website operator undertook technical measures so that no personal data is transferred to the social media platform until she gives her consent.