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

Section 4.4  Other relevant actors

26 Targeters may directly use targeting mechanisms offered by social media providers or enlist the services of other actors, such as marketing service providers, ad networks, ad exchanges, demand-side and supply-side platforms, data management providers (DMPs) and data analytics companies. These actors are part of the complex and evolving online advertising ecosystem (which is sometimes knownas “adtech”) that collects and processes data relating to individuals (including social media users) by, for example, tracking their activities across websites and apps.

27 Data brokers and data management providers are also relevant actors playing an important role in the targeting of social media users. Data brokers and DMPs differentiate themselves from other adtechcompanies to the extent that they not only process data collected by means of tracking technologies, but also by means of data collected from other sources, that can include both online and offline sources. In other words, data brokers and DMPs aggregate data collected from a wide variety of sources, which they then might sell to other stakeholders involved in the targeting process.

28 While each of the other actors mentioned above can play an important role in targeting of social media users, the focus of the current guidelines is on the distribution of roles and data protection obligations of social media providers and targeters. Analogous considerations may apply, however, to the other actors involved in the online advertising ecosystem, depending on the role of each actor in the targeting process.