01 February 2020
Twitter Remarketing allows businesses to use Twitter to reach a larger audience of potential customers and gain more followers for Twitter account of a business.
Twitter has its own requirements for what policies advertisers must provide, and what information must be included. Both website and mobile apps are covered.
In the FAQ section for the website tag for remarketing, the very first FAQ informs businesses that there are specific policies that must be used when using website tags:
This FAQ is linked to a Twitter Support article about "Policies for Conversion Tracking and Tailored Audiences".
Whether a business uses Twitter Remarketing on a mobile app or on a website (or, most commonly, both), Twitter states that you must provide legally sufficient notice that:
Twitter also provides an extensive list of what types of tailored audiences are prohibited, such as targeting ads based on religious affiliation or beliefs, negative financial status or condition, or race.
Twitter provides a simple way for Twitter users to opt out of tailored ads and provides this information to visitors in a "Privacy Controls" section. Logged-in users can go to their "Account Settings" and uncheck the box next to "Promoted Content."
Additional information is provided for how tracking can be limited or disabled on both a web browser and mobile device including both iOS and Android-specific information:
Here are some examples of companies and their Privacy Policies that are using the remarketing with Twitter and how each of the following required components has been met.
Girl Scouts of the United States of America
Their agreements include all of the required information in one short paragraph, seen below.
Note how there is no specific mention of using Twitter Remarketing service, just a mention of third-party advertising companies.
Visitors are informed that non-personally identifiable information may be collected by third-party advertising companies, which can include Twitter and others, in order to show advertisements.
This is a completely fine and acceptable way of covering all required pieces of information.
Goldie Blox's policy has a separate section titled "Third Party Tracking and Online Advertising" where all relevant information is included. Visitors are informed that data about their browsing behavior and use of the Goldie Blox website may be collected via cookies or similar tracking technologies and that the information is collected so that relevant ads may be displayed both on the Goldie Blox website and other websites.
Opt-out links are provided, as well:
While all of the required information is included here, and visitors looking for information about cookies will be able to find everything in one thorough section, breaking down the third-party advertising information into its own section can help visitors realize that cookies and their personal information are used in different ways, both by your website and by third parties.
Visitors are informed that collected information "will also be provided to our third party providers, advertisers, advertising networks and platforms, agencies and partners."
The next section in their agreement deals with "Online Behavioral Advertising" and continues to inform visitors how cookies are used by "third party service providers, advertisers, advertising networks and platforms, agencies, and partners...for online behavioral advertising."
The consumer opt-out information and links are provided for convenience and compliance:
Note how TripCase separated the "Online Behavioral Advertising" section from the general "Cookies" section.
The section that deals with remarketing states in part that:
AdRoll is then linked, as well as a general informative website about interest-based advertising.
While this article is focused on remarketing through Twitter and Rock Creek uses AdRoll, this example is included to highlight how it doesn't matter if you use Twitter Ads and then AdRoll or another third party advertising platform.
This section is written in very user-friendly language that states how:
"As you browse Aceable, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with [company website]."
Aceable lets visitors know that personal information such as names, addresses and telephone numbers aren't collected. An opt-out page link is provided:
While AdRoll is specifically mentioned, Aceable could have left that out and just said that their "display advertising partner" enables them to present retargeting ads. This could then work for Twitter, or any other retargeting platform such as AdWords, AppNexus or Perfect Audience.
"Targeted Advertising" has its own section. This section is very short but includes enough general information to be adequate. What information is collected, by whom, and what it is used for is all outlined, as well as why this is done, and how a visitor can opt out.
Notice how no specific mention of a third party advertising network is mentioned. This could be AdRoll, Twitter, and any combination of multiple third-party partners:
However, some businesses choose to include this information within more broad sections of their Privacy Policies agreements, such as within the general "Cookies Usage" section instead of a separate section or a separate agreement.
This article is not a substitute for professional legal advice. This article does not create an attorney-client relationship, nor is it a solicitation to offer legal advice.