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

Section 5.4  Targeting on the basis of inferred data

73 Inferred data refers to data which is created by the controller on the basis of the data provided by the data subject (regardless of whether these data were observed or actively provided by the data subject, or a combination thereof). Inferences about data subjects can be made both by the social mediaprovider and the targeter.

74 For example, by virtue of monitoring the behaviour of its users over a long period of time, both on and off the social media (e.g. pages visited, time spent on each page, number of reconnections to that page, words searched, hyperlinks followed, “likes” given), the social media provider may be able to infer information regarding the interests and other characteristics of the user of the social media. In the same vein, a targeter might also be able to infer data about specific individuals and use that knowledge when targeting him or her to display ads on his or her social media page.

• Example 7:

• Mrs. Delucca often “likes” photos posted by the Art Gallery “Beautifulart” by impressionist painter Pataolito on its social media page. Museum Z is looking to attract individuals who are interested in impressionist paintings in light of its upcoming exhibition. Museum Z uses the following targeting criteria offered by the social mediaprovider: “interested in impressionism”, gender, age and place of residence. Ms. Delucca subsequently receives targeted advertisement by Museum Z related to the upcoming exhibition of Museum Z on her social media page.

• Example 8:

• Mr. Leon has indicated on his social media page that he is interested in sports. He has downloaded an application on his mobile phone to follow the latest results of his favorite sport games, has set on his browser the page www.livesportsresults.com as his homepage on his laptop, often uses his desktop computer at work to search for the latest sports results on the internet. He also visits a number of online gambling websites. The social media provider tracks Mr Leon’ online activity across his multiple devices, i.e. his laptop, his cell mobile phone, and his desktop computer. Based on this activity and all the information provided by Mr. Leon, the social media provider infers that he will be interested in online betting. In addition, the social media platform has developed targeting criteria enabling companies to target people who are likely to be impulsive and have a lower income.The online betting company “bestpaydayloans” wishes to target users that are interested in betting and that are likely to be betting heavily. It therefore selects the criteria offered by the social media provider to target the audience to whom its advertisement should be displayed.