OBA Compliance

Crowd Science Position on OBA Compliance

Read more about OBA here.

The Crowd Science Position

Based on the clear definition of OBA practices, Crowd Science does not collect web viewing behaviors over time for the purposes of predicting user preferences and interests to deliver specific advertising to specific individuals. In particular, any data collected by Crowd Science, whether tracked or via survey, are not utilized at the any individual (cookie) level. Data are statistically projected to a larger portion of an audience and at no time is a direct survey response associated to a particular cookie for ad targeting purposes.

Nevertheless, since Crowd Science does play a role in ad targeting utilizing collected data, we must be sensitive to the association and be fully transparent (principal number 3).

It is currently unclear within which kind of entity Crowd Science operates and there may be some debate or clarification required around this. In summary, there are cases where we may be considered an agent of a First Party, or in other cases as a Third Party.

When collecting data on behalf of a publisher (First Party), data are owned by the publisher and we have limited rights and access to the data. As such, we may be considered as an agent to the First Party. An agent is defined as follows:

Agents and other entities that perform business operations of First Parties are treated as if they stand in the shoes of First Parties under these Principles and thus, their activities are not included in Online Behavioral Advertising. Similarly, this traditional legal construct of agents would apply to Third Parties and Service Providers and their agents and other entities that perform business operations of Third Parties and Service Providers. If the agent is taking on the responsibility for the Third Party or Service Provider, either the agent or that entity would have to satisfy the obligations under these Principles. Thus, an entity cannot escape its obligations by outsourcing its responsibilities to an agent.

In cases where we are working with an ad network, Crowd Science may be considered a Third Party or agents of a Third Party. This is also particularly a gray area depending on the exact agreement between the ad network and their affiliate sites and the definition of control.

How Crowd Science Complies

Based on the seven principles, Crowd Science supports compliance by:

  1. Education: Crowd Science supports the OBA initiative, and participates in active discussion regarding targeting, data collection, and advertising
  2. Transparency: Crowd Science's privacy statement clearly outlines data collection and use.
  3. Consumer Control:
    1. Participation in Crowd Science survey data collection is on an opt-in basis with full disclosure at survey intercept, introduction and privacy links.
    2. Crowd Science provides a mechanism for web site visitors to opt-out of data collection. Please visit http://app.crowdscience.com/optout/
  4. Data Security: Crowd Science employs data security practices as prescribed by numerous industry organizations (including MRIA, CASRO): these are outlined in Crowd Science's privacy policy
  5. Material Change: Material change in any policies is clearly communicated
  6. Sensitive Data: Crowd Science abides by industry standards dealing with sensitive data, included in but not limited to COPPA
  7. Accountability:
    1. Members of IAB, MRIA, and in process of becoming recognized by NAI and listing on http://www.AboutAds.info
    2. Crowd Science supports a complaints mechanism as outlined in its privacy policy

If you have any questions about Crowd Science's OBA compliance, please email us at privacy@crowdscience.com.

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