What’s More Important To CMO’s – Marketing Metrics or Strategy?

Several years back, I escaped to Sea Island, GA for a vacation.

Upon return, my boss came into my office, quietly closed the door, and asked if there was anything I wanted to tell him.

Puzzled, I said everything was fine.

He told me that when people go away on long vacations, momentous decisions were often made.

People would reflect during this time of pause, and make life-changing decisions–announcing divorce, big career shifts, etc.

He asked me again. Same response, I’m fine.

I was running advertising for a publicly traded company, with an agency known for its Cannes Award-Winning work.

Within six months, I left for the Internet.

In fact, I made plans for that dramatic career shift while on vacation.

As CMO’s leave for vacation this year, the seeds of shift will spawn.

It’s no secret the average tenure of a CMO is 43 months.

So the question every marketer will ponder from California to Cape Cod is how to reverse that trend.

As the Co-Founder & Chairman of C3 Metrics, you would think my answer would have something to do with media buying, such as multi-touch attribution (MTA) or marketing mix modeling (MMM), as this technology directly assists CMO’s in ‘moving the needle’ towards better ROI and this is what C3 Metrics is all about.

As a former CMO, I too will be on vacation on Cape Cod.

And if you join me for a few days of kayaking through the salt marsh, yoga, and evening walks on the tidal flats, my answer to that question will be this:

Dump the P’s, focus on the C’s. Bring your business strategy.

In today’s business environment, the reason why 90% of CMO’s get pushed out is because of revenue.

A CMO’s job in the eyes of the CEO and CFO is to drive revenue while leveraging cost.

Very simple.

Most CMO’s focus on the four P’s, and whether a target audience is watching this program or that program.

These are not unimportant, but for the CMO, you’re rearranging deck chairs on the Titanic.

Your fate is sealed if you focus on this, because you’ve got a limited amount of time.

It’s not the Four P’s that’ll keep your job, it’s the C’s + Business strategy.

C’s meaning: Customer, Competition, Cost

What does your customer want (or what can you create that they’ll want) which your competition isn’t delivering?

You can create or you can compete—competing is a slow road to failure.

And, marketing costs money (the third C).

Don’t marginalize your ad dollars with vanilla creative—demand every last ounce of effort from your agency to go places they’ve never gone before. Unchained.

Steve Jobs is perhaps the best product man and marketer known to mankind…but his best marketing didn’t happen with ‘1984’, his best marketing didn’t happen with ‘Think Different’.

His best marketing wasn’t the day that iTunes launched, propelling a record-breaking run on the stock to become the most valuable company in the world today.


His best marketing was the 1997 return when reviewing all the current and proposed products at Apple.

Apple had a slew of products. He said, “this is crazy,” grabbed a Magic Marker, went to a whiteboard, and drew a two-by-two grid. “Here’s what we need.” At the top of two columns, he wrote “Consumer” and “Pro.” At the side of two rows he wrote “Desktop” and “Portable.”

He proposed discontinuing 70% of all Apple products, focusing on making four great products, one for each quadrant. Consumer, professional, desktop, and portable.

That was his greatest marketing moment.

It was Business Marketing Strategy.

It set Apple in motion from disaster to outer space.

It more than moved the needle.

As a CMO, you won’t move the needle with this new ad campaign or that new campaign.

The way you move the needle is with Business Marketing Strategy.

Think your product is too small? Think again.

One of my marketing mentors, Don Price, got assigned brand manager to Rit Dye, a product with 10% market share, a competitor with 90% market share, and a category suffering negative growth every year.

With his newly minted Harvard degree he pitched a marketing plan to spend money on this and that, but was summarily shut down with nary a marketing dollar at his disposal.

He then focused on business marketing strategy.

He detached from the everyday cycle of the office. He helped reverse the gravitational trend and moved the needle to Steve Jobs proportions—by creating the tie-dye shirt.

He didn’t need better marketing, he needed business marketing strategy—and he delivered.

So while you detach from the office this summer vacation, think not about GRP’s. Today, incrementalism is for losers.

Think about business marketing strategy; business marketing that sets in motion inertia of revenue never seen before.

Don’t, and you’ll be the next CMO on permanent vacation.

Multi-Touch Attribution (MTA) & Baseball: Why Your Leadoff Hitter Is The Most Important

Multi-Touch Attribution (MTA) and Baseball are both a game of statistics.

Bill James (famous baseball statistician) found the strongest indicator of scoring runs in a game is whether the leadoff hitter gets on base. In Baseball, the leadoff hitter can start the best statistical predictor of success—originating opportunity to score.

Similar to Baseball statistics, when a smart marketer embraces a robust MTA platform, one aspect of what they measure is the first touchpoint, known as the “originator”.

This concept of attributing credit to media sources who originate revenue is quite new.

Even though marketers spend billions a year in advertising…the industry is stuck in antiquated measurement systems providing 100% credit to the last ad before the conversion event.

What this means, is that these outdated measurement systems give ZERO credit to media sources ‘originating’ revenue.

So if four ads contribute to a conversion, today’s outdated systems allocate the entire credit to the fourth, last ad–ignoring the first three, which actually seeded the revenue.

But multi-touch attribution (MTA) platforms like C3 Metrics work differently.

MTA recognizes credit should be assigned to a team of ads…and perhaps stronger credit should be given to the one who originated the conversion—because without originating revenue, how can you even have revenue?

So in the world of Baseball, and in the world of online media attribution—the leadoff hitter/originator is pretty darn important.

But what about the rest of the players…do they get credit with media attribution?

Just as in baseball where some players strike out, get RBI’s, or get two-run homers–some get credit and some don’t. In attribution systems like C3 Metrics, the revenue gets credited to three fundamental players: Originators, Assists, and Converters.

All online media sources are captured in C3 Metrics from the top of the funnel where sales are originated to the very bottom of the funnel. So for a $100 transaction, an Originator would get a fraction of that $100 attributed to them—and the Assist and Converter would get their respective fractional credit of $100 attributed to them. 100% of the revenue attributed into three parts.

We know that leadoff hitters getting on-base produces the largest impact on scoring runs (less runs are scored without them). And with media attribution, we know that Originators produce the largest impact on scoring revenue (no revenue without originators).

Baseball, Football and media attribution—one of these things is not like the other, and one of these things is like the other.

Batter up!

Taking The ‘Me’ Out Of Media

When you’re a marketer in today’s multi-channel media world, we can use all the help we can get.

Pierre Bouvard is an esteemed colleague and C3 Metrics client.

He’s the Chief Insights Officer for Cumulus Media and Westwood One leading advertiser marketing strategy for the media and entertainment company.

Previously Pierre was Senior Vice President of Sales for TiVo Research & Analytics where he led cross-media targeting and sales lift measurement engagements for Procter & Gamble, Comcast, Turner Broadcasting, and NBCU. As President of Sales for Arbitron Inc., Bouvard launched Arbitron’s Portable People Meter (PPM) and he created the out-of-home and custom research divisions.

Earlier, Bouvard was Executive Vice President at Coleman Insights, a leading market research and consulting firm to the radio industry in the U.S. and in Europe. At Coleman, he helped launch the nation’s first Hip Hop formats in Los Angeles and New York City and oversaw the programming and marketing strategies of dozens of successful major market radio stations.

Mr. Bouvard has served on the boards of Adify and TRA Inc. and currently serves on the boards of the IRTS, a leading media charity in New York City and the Library of American Broadcasting. Pierre has advised a number startups. Mr. Bouvard currently advises Affinity Answers, a social media audience targeting solution, and Vadio, a digital music video application.

When we saw Pierre Bouvard post his amazing analysis of P&G’s massive shift into radio, there were 3 gems way down at the bottom:

  1. Talk to people long before they come to buy.
  2. Remind the many. Don’t lecture the few.
  3. Take the “me” out of media.

Taking the “me” out of your mix is the hardest of all.

As a marketer, your media usage looks nothing like the average consumer.

The best example of this comes from Havas Media North America CEO, Colin A. Kinsella:

“The biggest risk for radio is the 26-year-old planner who lives in New York or Chicago and does not commute by car and does not listen to radio and thus does not think anyone else listens to radio.”

Heed Pierre’s advice … take yourself out of your mix!

Why CCPA Is In Desperate Need Of Some Marie Kondoing

California’s attorney general, Xavier Becerra, filed a petition in early November that marks an investigation by California into Facebook’s privacy practices. Meanwhile, privacy legislation is still in motion. There was yet another announcement about potential changes to CCPA per a statewide ballot measure submitted in September. The plan would give Californians new data rights, place new requirements on companies, create opt-out provisions and add restrictions on access to information about consumers below 16 years of age. Notably, the submitted plan includes the creation of a data protection agency for Californians with the power to enforce the law and issue new regulations.

I believe the decision to establish an enforcement agency will provide a much-needed infrastructure to ensure CCPA compliance. It is also a sign that lawmakers are grappling with the serious undertaking that CCPA enforcement will be.

Enforcement aside, these additional measures once again place businesses in somewhat of a state of limbo. The new ballot measures and the steady stream of regulatory changes could result in an unsteady ground upon which companies can prepare in the countdown to CCPA that is going into effect on January 1, 2020.

I believe CCPA is in need of Marie Kondoing, but the train is still rolling toward the station, and all of these rules will supposedly be finalized and in effect in less than two months. It’s clear to me that most are unprepared — including those who are establishing the rules. After speaking with my colleagues, it’s become evident to me that there is a significant amount of uncertainty and a lot of confusion among businesses, not only on the adtech data side of the house, but among agencies, advertisers and those analyzing others’ data.

Because we know that CCPA today may not be CCPA tomorrow, we’re hanging on the edge of a void. I personally cannot wait for national legislation to finally come into effect. But until then, here are some questions about CCPA that I have heard and what they mean for businesses.


Companies should make certain that they’re giving notice to consumers about their data and provide consumers with the opportunity to tell them four things: “Yes, you can use my data,” “Show me what you have on me,” “What you have on me is not correct; I want to change it or amend it,” and “Don’t sell my data.”

We know that these disclosures and options need to be on our websites — visible and in plain sight — but I have yet to see any guidance on how big the disclosures need to be or what precisely they need to say.

How To Validate That A Person Is Who They Say They Are

Because of GDPR, many companies have mechanisms in place that allow removal requests. But, I haven’t seen any guidance yet in terms of how consumers are supposed to get in touch with you or how companies are to correctly validate that the person (who is saying, “Destroy my data,” or “Don’t sell my data”) is who they say they are.

There’s no system set up for that just yet. So someone can hypothetically come and say, “I’m Jeff Greenfield, and I’m a California resident, and you have data on me. Show me what you have.” Yet, how is a mere website owner supposed to know that you actually are a California resident without asking you to provide additional information about yourself? Or, how can they even know that you in fact are who you say you are? Will consumers need to provide a driver’s license to validate they are who they say they are?

That has not yet been made clear to the community at large.

Provisions For Kids And Teens

We know that the new CCPA proposal would require marketers and companies to obtain opt-in permission before collecting data from consumers younger than 16. We also know that the new proposal would require a company to obtain parent or guardian permission to collect data from consumers who are younger than 13. But how are companies supposed to know who is the actual parent or guardian of a minor under 13? And how do we validate that the consumer is younger than 16?

Unclear Definitions

There’s a lot of meandering because — even assuming validation systems will be put in place — consumers should have the option to say, “Don’t sell my data.” However, definitions are unclear. For instance, what is the definition of “selling data”? For example, it may be unlikely, but does “selling data” include analytics providers who are paid to analyze that data?

National Legislation

Yes, it seems like quite a mess, but history tells us that being privacy-compliant will become less complex and more straightforward — eventually. Legislation often first emerges at the state level, is then adopted by several states, and is then followed by national regulation. For example, several local lawmakers have enacted or proposed regulations around the use of facial recognition technology by law enforcement. Earlier this year California passed the Body Camera Accountability Act, which bans law enforcement from using facial recognition software for the next three years, and only recently was a new federal bill announced to restrict federal police’s use of facial recognition across the United States.

I believe state-by-state legislation for privacy is a mere Band-Aid solution. The only approach that’s going to be viable for the advertising technology business is likely federally mandated protection at the national level akin to the broad-sweeping GDPR regulations. The technology economy is simply not set up at the state level. Until then, even Marie Kondo can’t help us make sense of this.


This article was originally published in Forbes.

Are The Hurdles For Outcomes-Based Measurement Surmountable?

Today, marketers are being held accountable for their organizational bottom line more than ever before. With transparency increasing across marketing departments and businesses, brand leaders are being asked to track every dollar spent and demonstrate to finance leads how they are impacting revenue.

This reality, in tandem with marketer concern about how many of their ads are actually being seen by human beings — and prominent researchers like Dr. Augustine Fou outlining a bleak outlook for dollars wasted due to digital ad fraud — has pushed both viewability standards and outcome-based attribution measurement to the forefront.

The Biggest Hurdle

True outcomes-based measurement means being able to look holistically at your marketing channels, while filtering fraud and viewability at the individual user level and accurately connecting devices across the user journey. The key challenge for agencies, sellers and brands seeking outcomes-based measurement, at scale, is the lack of an omnichannel measurement platform with reliable protections in place. Accurate outcomes-based measurement requires a gold-standard multitouch attribution (MTA) solution complete with the bells and whistles of filtering fraud and viewability across devices to determine true incrementality.

Marketers need a lot of information because they’re looking for proven cause and effect metrics and essentially putting their jobs on the line and telling finance, “When will you give me more money? I’m spending it on X. It’s going to drive Y more dollars, and it will generate Z more profit.” So, with those stakes in mind, it’s important to be absolutely certain that your predictive models will perform as promised.

Set Realistic Outcomes

Much of marketing today is predicated on key performance indicators (KPIs), such as views, engagement and clicks, that are not always directly tied to revenue. For example, an auto manufacturer like Ford or Toyota might be focused on driving leads for their dealers. But, technically, that lead is not worth anything in terms of revenue.

With MTA — identifying an individual and stitching together a consumer’s journey anonymously — marketers are able to accurately tie that lead to revenue. Those automakers are then also able to ascertain which individuals end up buying the most expensive cars and track their outcomes in terms of revenue to actual action.

And that’s really what the goal is here!

There is always a path to outcomes — even for notoriously difficult industries like pharmaceutical brands. With today’s advanced MTA technology, you can track almost any KPI back to real revenue with the right platform. And, at the end of the day, we have to remember that leads don’t mean anything to finance, but revenue certainly does.

Know What Can’t Be Measured And Create Workarounds

Some sectors, like consumer packaged goods (CPG) brands, may require sampling to get information that cannot be obtained at the user level, but outcomes-based measurement is possible. Additionally, in a scurry for user-level data, I have seen a lot of CPG companies now moving very aggressively to have direct relationships with consumers — take Unilever’s acquisition of Dollar Shave Club, for example. Other resourceful CPG brands, like Tide, have cleverly worked around their lack of user-level data by launching and acquiring dry cleaning businesses around the country, enabling a direct one-to-one consumer relationship.

Industry Standards Are Necessary

Right now, every company has its own standards, and there’s no consensus in place for marketers or their agencies. Until industry attribution standards are agreed upon, wide-scale adoption of outcomes-based advertising approaches will be slower than marketers desire.

It’s challenging for companies delivering metrics to agree on standards and change the way that they do business for the greater good. Some attribution and outcome-based measurement businesses will struggle to adapt to the standards mandated by the industry. To prepare yourself for those new standards and develop outcomes-based measurement in your own organization, start with the following:

Perform A Geo-Based Hold-Out Test: This is often considered the gold standard, where you test one media channel versus your baseline in similar regions to demonstrate the incremental value of running a specific media channel to your organization.

Determine Your Time To Financial Impact: Extend your hold-out test for up to 90 days (or longer) to calculate how long it takes for consumers who are engaging with your media to have a financial impact on your organization. Remember that some channels may impact higher in the consumer funnel and may take up to six months or longer to have an impact.

Eventually, my prediction is that we should anticipate a shakeup in the attribution space as the inevitable takes place. In the meantime, you and your business should do everything within your power to stay up to date on these changing expectations.

This article originally appeared in Forbes.

How Do You Inspire Technology Adoption In Your Org?

How do you inspire people to work with technology?

Far too often, we see technology get in the way (vs. help) — and we see that daily in our business.
You’re working, trying to do your job and all of a sudden, there’s a new ‘tool’ that is “supposed to” help you do your job better.

It may help in the long run…. but there’s a learning curve and it becomes a major hassle as you do your day job plus learn this new tech.

Here are 3 + 1 Tips that we use daily at C3 Metrics to help us transition clients and they may help you:

1. Focus on the Benefits
Help employees see past any short-term pain to get a glimpse of a long-term vision. If technology has not worked out in the past, share lessons learned and what has been implemented since then to build team trust in new technology.

2. Find a Champion
Gather champions of technology to help get them on board first and they can internally promote the technology.

3. Training and Support
Build trust by providing on-going training and support systems for anyone that has questions or is learning the technology at a difference pace.

For Reni Walker, its her job to find the story and figure out the best way to get people to stop and listen.

She leads the development of content strategy for campaigns and content experiences, including the creation of targeted narratives, content journeys, and deliverable plans that bring those narratives to life at TD Bank.

For Reni, technology adoption is all about timing:

Timing of communications is also crucial. A “just in time” strategy works because it provides employees with what they need to know exactly when they need to know. The challenge is resisting pressure (often from senior leadership) to inundate employees too soon before they have a chance to engage with the product.


Is Marketing Attribution’s (MTA) Father Bill Gates?

When MSN was in the media business, Bill Gates hosted its annual Brand Summit, where the likes of Dave Matthews and Chris Cornell performed for an intimate audience of the top 50 advertisers.

In that exclusive audience was Ted Moon, who was spending over $100 million/year in digital for Sprint-Nextel, making him one of the top five digital advertisers in the world.

In 2007, Bill Gates keynoted that Brand Summit and spoke about the foolishness of the measurement systems which gave credit to only one media touchpoint, when advertisers were spending millions of dollars on hundreds of keywords, and thousands of publisher display sites.

“He railed about its lack of logic,” said Ted Moon, now CEO of Pathfinder Interactive. “In fact, Gates bashed and dismantled last click measurement like the Golden State Warriors dismantled every team in the NBA playoffs. It was the first time I’d ever heard of attribution, and soon after, it shaped every media buy I made.”

So was Bill Gates the father of marketing attribution?

That same year, Microsoft acquired aQuantive which included Avenue A/Razorfish.

Brian McAndrews and Jeff Lanctot had been ramping up their dialog of conversion attribution which had been developed and used initially there and via acquisition, by Gates and Microsoft.

Brian McAndrews Jeff Lanctot

When Microsoft started exiting the media business in favor of search alone (Bing), the need to ‘parent’ and raise attribution…fell by the wayside.

“There’s a saying that Barbie has a thousand fathers” said C3 Metrics advertising attribution measurement Co-Founder & Chairman Mark Hughes. “but aQuantive and Microsoft were the real fathers of marketing attribution. I once spoke with a former senior exec from aQuantive who told me that: attribution was the jewel of the acquisition, but inside the Windows-dominated culture, the diamond got lost.”

In the words of Shakespeare: “It is a wise father that knows his own child.”

It’s our job to carry on.

The Impact of Losing Third-Party Cookies On the Advertising Ecosystem

Google’s announcement about the removal of third-party cookies sent shockwaves thru both the advertising world and Wall Street.

Is this an Attribution Apocalypse or a necessary cleanse to the advertising ecosystem?

The changes and potential impact was the topic of an industry conference call held with Shyam Patil, Internet Analyst, at Susquehanna Securities and C3 Metrics Co-Founder and Chief Attribution Officer, Jeff Greenfield.


Shyam Patil:
I’m Shyam Patil, the Internet Analyst at Susquehanna. Welcome to our conference call with Jeff Greenfield, Co-Founder and Chief Attribution Officer at C3 Metrics. If anyone in the audience has any questions, please feel free to email them to me during the call. What we’re going to try to do with the structure of this call, we’re going to try to just go through what Google is doing, the time frame, the near term impact to companies. Then we’re going to talk about what happens in a couple of years, talk about some of the specific changes that are going to happen then. And then the impact to companies in the ecosystem at that point. Jeff, you also mentioned that there’s some new information that came out last night, so maybe we can weave that in as well. But to start out, can you talk about exactly what Google is doing and what the time frame is?

Jeff Greenfield:
The big announcement that Google made, is that they will be blocking third-party cookies. This is very similar to the change that’s been made both in Safari and Firefox previously. To really understand it, let’s step back a little bit and talk a little bit about the difference between a first-party cookie and a third-party cookie, because that’ll help put a frame of reference on things.

Cookies are part of computer code. They’re how computers and computer language talk to each other. It’s part of JavaScript, it’s part of PHP. This is part of how things operate. So, it’s fascinating that these browsers are actually getting involved in blocking stuff like this.

A first-party cookie is when you go to a website and there’s a certain level of personalization that’s there. You go to Amazon and you’re automatically logged in and they say, “Hi Jeff.” Or you go to the New York Times and you’re automatically logged in. So first-party cookies are cookies that are set by the page that you’re actually on. And those are what make the digital experience an ‘actual’ experience. It’s what makes it comfortable to you and it’s not like you’re starting from ground zero.

A third-party cookie is a cookie that’s set by someone that is not the owner of that website. So if you go to the New York Times and there happens to be an ad there for a shoe company, there may be a cookie that’s set by that shoe company or that is set by that ad server. That’s a third-party cookie, because it’s different than the site that you’re actually on.

The whole digital experience has been about this combination of first-party cookies and third-party cookies and the whole advertising ecosystem, including the ability to target, has been built on third-party cookies. That ecosystem is extended by what you would call a cookie sync. Where, somebody who has first-party cookies syncs with somebody else who has first-party cookies and then they come up with a ‘secondary’ cookie. This secondary cookie would allow them to find individuals based upon their preferences, what type of stuff they’ve bought, maybe their age, maybe some other demographic information. And that’s been the entire basis of the advertising ecosystem.

When Safari and Firefox did away with third-party cookies, it was a hit, but it wasn’t that big of a hit. Primarily because most people around the world tend to access the digital landscape using a Chrome browser. Most companies just shifted most of their targeting over to Chrome, advertisers accepted the fact that Safari was tough to target, but they didn’t worry about it because the vast majority of people were using Chrome.

So this announcement is a big deal.

It’s a real big deal to a lot of companies, and it’s also a huge deal to brands and advertisers. Because in their world, they don’t know what’s going to happen next. It’s forced a lot of questions, and it’s causing a lot of people to start to rethink strategies.

Shyam Patil:
Great. That’s a very helpful intro. I know this is a topic that all of us are trying to figure out. If anyone in the audience has questions, just please feel free to email them over to me and I can try to weave them in. Can you talk about, there’s kind of a near term and then there’s what they might do in two years. Can you just talk about right now or in February, what’s going to change?

Jeff Greenfield:
In February, they’re doing a way with non-secure cookies. Most internet traffic today, over the last couple of years, has shifted to what they call ‘SSL’ or a secure socket layer, so that any information that you send across the web, there’s a secure handshake that goes on. So that if you’re logging into your bank, everyone knows that little lock and key you want to see there. Sometimes you go to URLs, the URL name is in green, which means it’s really been validated. And you want to make sure that whenever you’re accessing webpages that the actual webpage itself is totally secure, so that somebody can’t get in the middle and get your information or take your credentials to log in.

For years, a lot of tracking technology and ad servers wouldn’t use SSL primarily because, especially in the early days, to send traffic over the web securely actually cost more money. You needed to get individual IP addresses, which were very costly. And so everybody just used the regular transmission settings.

So what’s happening in February primarily is that, if you have a cookie and it is setting in a non-secure manner, it’s going to be stopped. And so all that means is, is that anyone who’s part of this advertising ecosystem, they just have to make an update. Now, the issue is, is that you may have code that’s on a non-secure page. Most webpages today, if you try to go to the non-secure version, it’ll automatically redirect to the secure version.

But there’s a lot of older webpages that are still out there, that have a lot of older computer code, and you don’t want to be stopped from collecting data from there. What most in the advertising ecosystem are doing is that if their tag is called in a non-secure manner, they’re just going to redirect to the secure one. It’s just a quick update that folks have to do. More than anything else, it’s just a note from Google to the advertising ecosystem that says, “Hey, this is the first thing that’s going to happen.”

This happens in February where non-secure is not going to be allowed. You will have to make some updates to your code. After that, things are going to be the status quo until about two years from now, and that’s when the big change is going to come, and that’s when all third-party cookies are going to be blocked. It doesn’t sound like a lot of time, but it is a lot of time if you put the right minds behind it. And now there’s an incentive to start thinking differently because if you don’t, your business model is going to be completely gone in terms of how you target, how you track, and how you determine that what you’re doing is actually being effective.

Shyam Patil:
Is this a big deal? Does non-secure change, is that going to be a big deal you think? Is that going to be disruptive?

Jeff Greenfield:
It’s not disruptive. It’s a smart move that people should make. Truth be told, Google should have done this a long time ago. Because what it does is, by having stuff that’s non-secure out there, someone can think that they’re loading one thing and they’re actually loading something else, so there’s not that secure handshake. This quells for the moment some of the transmissions of potential malware and other issues. This is a cleaning house maneuver on behalf of Chrome. They should have done this a while ago. It’s not a big deal for most of the teams that need to do this at all.

Shyam Patil:
I think you already answered this question, but in terms of the near term impacts, so we’re talking changes that are coming into February. What, if any, do you see on the likes of Trade Desk, Criteo, LiveRamp, Facebook, Google, or even some of the advertisers like Booking, any impact to those guys with the changes coming in February?

Jeff Greenfield:
They’ll have zero changes to what’s going on in February. They’ve already adapted to these changes. All of those folks are very sophisticated teams. Most of this should have already been handled ahead of time.

Shyam Patil:
You talked about this a little bit, but maybe to go into more detail. What are the big things that happen in two years? Maybe the specifics there. Maybe you can weave this into your response is just how will user tracking and targeted advertising be done at that point?

Jeff Greenfield:
That’s where things get really interesting. So remember, the entire digital ecosystem has been based upon these third-party cookies. And the reason that they’ve done this is because, let’s say my company is jeff.com. And I’ve got ads that appear across all of these different websites. So if you see an ad on the New York Times and it’s from the jeff.com ad network, I’m going to set a jeff.com cookie that’s a third-party cookie. Now when you go to boston.com I’m going to be able to see that I just saw you on the New York Times because I’m going to be able to read and write that jeff.com cookie. I can’t see any New York Times cookie because I’m not on the New York Times page.

So right there is the importance of that third-party cookie – it allows me to see you across all of these different sites. You may read about it where it’s called ‘cross-site tracking’, but it’s part of the nature of third-party cookies. That aspect is going to go away. Companies have all tested and tried different things. Going back in the early days, people were using flash cookies because everybody in the world had Adobe Flash on their systems. And the greatest thing about Flash is that you can put information in Flash and it would always be there. You could always find it. And it was cookie-less, which was great.

Of course Flash is not supported anymore and it stopped working and automatically getting called in the browsers. So that was gone. So then what companies did, is they did what a lot of the fraud companies do, which is digital fingerprinting. And a digital fingerprint looks at a combination of different aspects. So your operating system, your browser and versions, all of that data, all the way up to how many different fonts you have installed on your system.

And what they found is that if they could pull like eight or nine of these different aspects out, they could do a very good job at identifying you on a statistical basis. They wouldn’t know it was absolutely you but could do a good job of identifying a unique computer. Safari and Firefox in particular have done a really good job at stopping that practice and Chrome is also doing that as well, so digital fingerprinting is gone too.

There’s other methods that companies utilize. One of the big building blocks of the internet is the addressable aspect, so that every computer has to be coming from some sort of address, what they would call an IP or an internet protocol address. All IP Addresses are unique and you can link these back to specific households and to specific companies as well. Where it gets difficult is that, if you’re part of a company, everyone at the company appears to becoming from the same IP address. So that makes targeting a little bit difficult.

A lot of companies in the advertising ecosystem are going to start utilizing some sort of proprietary identification, which will be based upon location with some aspects of early digital fingerprinting – such as operating system, browser, etc. In addition, many companies have direct relationships with the sites in which the ads are being served. Criteo is a great example. Criteo works with almost 20,000 publishers. One of the unique selling prospects of Criteo is their direct relationships.

If you go back to the birth of this whole digital ecosystem, it was all about the publishers, the Yahoos of the world. They controlled the ad buying experience for marketers. All of a sudden we got into the programmatic world where it didn’t matter who you were, because everybody was providing inventory for programmatic and we moved away from direct relationships. Back in the early days, every publisher had their own sales force to sell directly to advertisers. As programmatic grew, direct sales (also know as IO sales) started to shrink.

We’re going to see a change back to where publishers are saying, the inventory I have is unique. And the reason for that is because, I know who my readers are, I know what they read, I know where they live, I have all this demographic information on them. And it’s more valuable to me to have a direct relationship with people with advertisers and a direct sales force, versus selling everything via a programmatic exchange.

It doesn’t mean the exchanges are going away, but we’re going to see a move more towards more private exchanges and a move back to direct relationships. With a direct relationship, Criteo can get data from a tracking perspective pushed back to them that will bypass Chrome. And it does that through an API where the publisher themselves will send information back directly to Criteo servers and that’s what’s going to happen.

And what that allows both the publisher and someone like a Criteo to do is to say, “Hey, we’re going to live in our own kind of world, in our own existence.” Because this is the first of many changes to come from these walled gardens. Chrome is not the way that we access the internet. Chrome is an extension of the Google and the Alphabet business strategy. Changes to Chrome at the end of the day, they are always going to be Google’s their best interests. Right now it’s being said that it has to do with privacy, but the reality is, is that this is part of a larger business strategy for Google. And so the key way for tracking for these companies is going to have direct relationships. That’s going to be their best method. Companies that don’t have direct relationship and don’t have scale, they’re going to struggle. They’re definitely going to have some problems.

Shyam Patil:
Cross-site cookie tracking. Can you just talk about why that’s important now, and then what impact this will have in two years, and who do you think is going to be impacted the most?

Jeff Greenfield:
Cross-site cookie tracking is the purpose of these third-party cookies. It allows me to track you across as many different sites as you go. As long as my ad is there and my code is there, I can track you all the way across the entire ecosystem, wherever you go. And what that allows me to do, is it allows me to make sure that I’m giving you the right frequency, that I’m not showing you 80 ads a day. It allows me to write a better experience from a brand perspective, which I know most of you on the call are probably laughing about, because that’s been one of the complaints the longest time about the web is that the experience should be incredible. With all of this technology, I should have such a positive experience with brands.

But typically what ends up happening, is a crappy experience.

I go to a place and I make a purchase – so they know that I made the purchase and their partners should know that I make the purchase, but now I get bombarded with ads for the next two weeks. And somebody is wasting somebody else’s money.

In the early days of the internet, efficiency was really, really important. And whenever someone would make a purchase, they used to call it an ‘unpixel’. It was a special piece of code that got fired to let all the partners know that this person made a purchase, stop showing them ads at least for 30 days. It depended upon the frequency of purchases. But don’t show them anymore ads because they just bought today. They’re not going to come back and buy again, but that doesn’t even happen these days.

So it’s funny because, this is going to impact the ad experience, which I think actually needs an overhaul and that’s what consumers really feel about it. That’s going to be the biggest impact is the ability to deliver ads in a targeted manner. And what’s happened is, is that you can get really micro targeted. And a lot of advertisers in a lot of brands, they get really turned on by this. Because I can actually go right now in the world of cross-site cookies, and I can go and I can find individuals who have purchased with the competitor within the last three months, and put it on a major credit card. Now none of that stuff is online, but what’s happened is companies like MasterCard and Visa, they are taking their data they have on consumers. They are matching it into a cookie pool to sync up. When you go and buy ads, you can buy segments of individuals.

And that sounds like wow, the more targeting you do. So you can find people whose lease is about to expire on their truck and this is the third truck that they’ve owned. You would think, “Wow, I’m going to target these people. My sales are going to go through the roof.” And yes, these people do buy. But the problem is this – not only do you have the cost of the ad itself, but now you have the cost of the data on top of it. Now all of this operates in this world of third-party cookies. And the cost of that data sometimes triples the cost of the actual advertising.

And what a lot of advertisers have found is that, this is a really cool thing to talk about. People get very, very excited about it, but the cost is so obscene that it makes profits kind of disappear. So yes, I can acquire customers, but it’s at a cost that is too costly for me to continue to do that strategy. And that’s part of the problem.

So that process is going to disappear. Those companies that are out there that have this data, they’re now going to have to find another way, in order to link that data up. It’s going to impact the ability to target. It’s going to be gone unless they find other ways and it’s going to impact the ability to deliver on the frequency. So all of a sudden, if these companies didn’t figure things out, you would start to see tons more ads or you wouldn’t see any ads at all. Obviously you’re going to see ads, so chances are you’re going to see a lot more ads.

Shyam Patil:
I’ve got a bunch of questions from the audience, but before I get to those, I wanted to just talk one more change just conversion measurement. You talked about this a little bit earlier. There’s also a change that Google made recently. Can you just talk about what’s happening with conversion measurement in two years, and what’s going to be the impact?

Jeff Greenfield:
Conversion measurement means the actual outcome. Advertisers buy ads because they want to lead to some sort of conversion. In the world of e-commerce, it’s an actual purchase, in the world of B2B and branding, it may be some other KPI (key performance indicator).

Most companies that have operated in this space, when they sell ads, they typically provide two tags. They provide a tag to put on every single page on the site, which is a retargeting tag. So I know that when people have been to the page, I can go and find them and I can find them on a cross-site cookie basis, so that’s going to kind of go away. And the other piece is a tag that goes on the conversion page or the action page where whatever your KPI is and I provide a tag to go there. That also historically has been a third-party cookie as well too, so I can identify these people that have actually purchased.

A lot of companies have switched to first-party cookies.

Facebook has done that.

They primarily did that to get around the whole Safari change so they could still get conversion information. This is definitely going to impact the smaller companies out there – they are going to have to update to first-party cookies so they can actually get that information. I see them definitely doing that. Part of the larger picture of conversion tracking, is this movement of the digital landscape impacting sales and the retail world off of the digital world.

Because remember, most of commerce still happens in the brick and mortar. And we’re starting to see more and more brands move into brick and mortar. We saw Amazon move and purchase Whole Foods. We’ve seen a lot of strictly a digital brands do the same – Warby Parker is one of them. They keep opening retail shops. Indochino, a suit brand for men, they have retail shops as well. You don’t actually buy anything in the shop, but you try things on and then you make your order digitally.

So the ability to link those two together for outside third parties, that is typically been a link that’s been done by syncing a series of third-party cookies together, that’s going to be impacted. That’s incredibly important, because more and more you have companies like Facebook and Google that are wanting to demonstrate that buying ads in the digital world, the virtual world where they live can impact sales in store. You buy ads on Facebook, people are going to go buy furniture at the Ashley Store. Or if you advertise, we can send people into Home Depot. So being able to connect those two together historically has been done through third-party a lot of times utilizing LiveRamp or using some sort of proprietary tool without those third-party cookies, they’re going to have to try other ways to link together.

Jeff Greenfield:
The other impact it was just reported on, is this blockage into the app world. Think about it, if I’m a brand and I buy an ad on Google on page search, I’m usually driving people to my website. So when somebody clicks and they come from Google, I can see that they came from Google, so I know my clicks are working. When somebody goes and they click and I’m sending them to download my app to the app store and when they’re there, how do I know that click actually happened? And then how do I get information out of the app store?

Jeff Greenfield:
So there’s certain app providers, one of the largest is AppsFlyer. Traditionally what they do with someone like a Google or an Apple is they say, “Hey, when that user clicks, send me a click at the same time. Either redirect through me. So when someone clicks, send them to AppsFlyer real quick and then we’ll redirect to where they’re supposed to go. Or send me a click at the same time.” And so what Google is now said is, “Hey, we’re not going to do that anymore. We’re not going to send you information on every single click. We’ll send you information for people who actually downloaded something. When somebody converts and they download an app, you send us the data you have on them and we’ll tell you what they clicked.”

Jeff Greenfield:
So it’s moving to this model where these walls are getting higher and higher, and they’re saying, trust us. It’s important in business to trust, but you also have to verify and you have to validate. And when those walls are up, it’s impossible to verify and validate. And that’s the problem.

Jeff Greenfield:
And the app world is not going away. The app world is getting much, much bigger. It’s billions of dollars a year and lots and lots of money is being spent in the app world, to not only to get people to download the app but get people to utilize the app. And so this is another way for the walls to come up from Google.

Shyam Patil:
Can you talk about companies going from being third-party to being first-party cookies? Can you just talk how companies are able to do that? And then I have a few follow ups on that.

Jeff Greenfield:
It’s just a matter of how the computer code work. The key is, is that in order to write a first-party cookie, it can only happen through JavaScript that sits on the side as a piece of computer code, so you have to have JavaScript.

Jeff Greenfield:
A lot of companies historically when they traffic out their code to go onsite, it’s typically what they call a one by one image tag. Image tags can only write third-party cookies. An image tag gets called, it doesn’t interact with the browser and it’ll call my jeff.com information and that’s it. But if I put a jeff.com piece of JavaScript code on the site, jeff.com can also, if I’m in New York Times, jeff.com can read and write New York Times cookies, and I can also read and write jeff.com cookies. So it lets me do both first-party and third-party cookies.

Jeff Greenfield:
For years, Google analytics was third-party cookies, because that’s how the whole advertising ecosystem worked was on third-party cookies. They moved to first-party cookies a number of years ago. Facebook, when Safari did away with third-party cookies, Facebook quickly moved to first-party cookies. They still have the option from a privacy aspect I believe, where your pixel that you put on the page can be third-party cookies. I’m sure that’s going to be go away and it’s going to be all first-party.

Jeff Greenfield:
So it’s just a matter of moving from a one by one image tag to a piece of JavaScript. and so it’s just a matter of re trafficking, which is a little bit of a workflow. But over the next two years, that’s not going to be an issue for a lot of folk. But they’re going to want all of the members of this ecosystem, will at least be wanting to get that first- party data themselves when they’re on a publisher site. So they’ll mostly be writing first-party cookies.

Shyam Patil:
Another question. So sites like Facebook, Snap and others use pixel for targeting remarketing attribution, however those guys impacted by the Facebook as a pixel on Zappos and they can use that today to remarket on their app or tell whether there was a conversion, will that still be possible in a couple of years? What will happen there?

Jeff Greenfield:
And that example with Facebook having a tag on Zappos, that tag will be a first-party cookie, which will send information back to Facebook on that user. So they’ll still be able to target people using first-party cookies because remember, they have that relationship with that site. Because remember, it’s Zappos that went and said, “Hey, I want to enable this behavior so that I want to retarget within my Facebook feed.” So they’ll be able to send that information back and forth.

Jeff Greenfield:
Even if Google came along and decided to do away with that, then Facebook would set up an API, where Zappos would send information server to server. So that when someone landed on the Zappos site, there would be a little piece of computer code that would send information directly back in the background from Zappos to Facebook, essentially would bypass the whole Chrome and Google environment.

Shyam Patil:
Another question is, you talked about the direct relationship structure. You’ve talked about it quite a bit just now and then you talked about it earlier with Criteo. What’s the mechanics of that? Do you have to go one by one to the publishers? How many direct ties will retailers and publishers just generally have?

Jeff Greenfield:
Someone like a Criteo, when you start to see the shifting landscape of what’s happened, remember years ago I was a publisher and I would write great content that would get spidered and people would find me. And I would typically get found in the yahoos of the world and now the Googles of the world because that’s where people went to go find stuff. And Google because they’re constantly changing their business strategy over the years, when you now go to that Google page, 80 to 90% of what shows up on your screen at any one time is ads.

Jeff Greenfield:
In fact, it was just a shift that was made with how now the ad display, the little picture next to the ad where it says ad is now smaller than it ever was. The ads aren’t a different color. It’s almost impossible to tell the difference between the ad and the organic content. And so now if I’m a publisher, the chances of me getting found in Google and counting on that strategy is nonexistent.

Jeff Greenfield:
In fact, we just read about a local Boston company, TripAdvisor, because of a Google update they’ve been now moved to the second page. Publishers can’t rely upon a strategy anymore and they’re starting to realize that folks like Facebook, where five years ago publishers built up a whole Facebook strategy, they started working with them and then Facebook’s business strategy changed as well too. They’re realizing that they’re an island on their own. And they need to build content and make content that is right for their readers. They need to understand who the people are that are coming to visit them. That’s the whole purpose behind the paywall besides getting revenue from it, the real purpose is, that the more I can learn about you, the more I can create content for you and deliver the data that you want.

Jeff Greenfield:
And then an extension of that is having a direct relationship, not only with the brands that I work with, but also the partners and having a sharing relationship so that we can both thrive in this world of wall gardens. Essentially creating my own little sort of walled garden, if you will, because I can’t count on the ever evolving business strategy of Google and Facebook to deliver the traffic that they used to. I need to find ways to create my own audience and curate it.

Jeff Greenfield:
Yes. To answer your question, you have to go one by one to each one of these. The larger ones is just like an advertising relationship. They’re meeting with them on a regular basis. There’s two sides to the house there at Criteo, there’s the side that’s selling the ad, and then there’s the side that’s developing these longterm relationships. I’ve long said for many years that Criteo has thought it was a one trick pony, because all they’re doing is they’re delivering these dads to advertisers. But as their strategy continues to grow and evolve and the strategies of Google and Facebook evolve, and these relationships that they have with publishers where they’re actually delivering revenue to these folks, I could see where they could expand even more so, and provide even better tools for publishers that help improve their revenue.

Jeff Greenfield:
And I think that could be an interesting growth area for them, because that’s something that these publishers desperately need and they need a partner and Criteo’s proven to be a partner for them. So that’s a separate side of the house that most people on the marketing side don’t see, but they definitely have it in order to keep those relationships as strong as they are.

Shyam Patil:
It sounds like in the new framework with privacy sandbox on the Google [inaudible 00:31:31] that you don’t expect much impact to one-to-one retargeting. You don’t think guys like Booking.com or Criteo are going to be impacted, because the likes of Criteo will be able to get their first-party cookies embedded in publisher sites. Is that a fair summary?

Jeff Greenfield:
Yeah, and their ability to create their own unique proprietary identifier. They’re also sitting on top of massive amounts of data. They’ve got the smartest and the brightest minds in the world. And not only that, it’s not like Google is pulling the rug out from under them and saying, “Hey, this is happening on Monday, guys. Good luck.” Yeah. If that were to happen, that would definitely be a problem. But two years, two years in the world of digital, that’s like 25 years in the world of brick and mortar. That’s a lot of time. A huge amount of time.

Shyam Patil:
Maybe more specifically on Trade Desk, had another question come in. It doesn’t sound like you expect much impact at Trade Desk, because of the talent they have as well as their unified ID, their own identifiers. Specifically on Trade Desk, is that going to be their solution, the unified ID that they have? Is there something else? And do you think they could lose share to Google’s DSP? Could Google’s DSP be advantaged by in any way by this? Or do you think they could lose share to Amazon’s DSP? Can you just talk about what Trade Desk solution is going to be or what you think it might be? And then, if they could lose share in the landscape to either Google or Amazon?

Jeff Greenfield:
The biggest issue that Trade Desk is going to have is, is not in two years, but it’s right now. And it’s the confusion this has created across brands and across advertisers. It’s forcing a lot of them to start rethinking their strategies.

Jeff Greenfield:
The problem is for a lot of them, they’re utilizing the Google ad server and they’re part of that stack, so it’s always a question of do I go all in on this? Or is it better to use different components? Trade Desk over time could actually gain share, as long as they handle the PR aspect, which is to instill confidence in advertisers that, “Hey, we’ve got our unified ID. This is going to work.” You want to be independent. That’s the biggest thing is that you don’t want to be dependent on Google to deliver everything.

Jeff Greenfield:
In terms of Amazon, Amazon has done a really good job of enabling that search. People tend to forget how powerful search is and why Google became the pipe that it is. It’s because their search functionality was so much better than Yahoo’s. So now start to think, when you go to search for a product on Google and the results that you get versus when you go to search on Amazon and the results that you get, what is more visual? What provides you better information? You only have to do it a couple times and then all of a sudden your behavior starts to change. Most people probably start to search first now and Amazon. And so as a result, that’s a pipe that Amazon hasn’t really started to monetize just yet. They’re just starting to do a little bit. It’s like the early days of Google when they started a first putting up their ads.

Jeff Greenfield:
The difference that Amazon has and the value that Amazon has over Google is not only can they put up little ads and start to monetize it just a little bit, but once you’re using that pipe, anything you buy from there, they get a piece of it. And not only that, but sometimes they can move you towards, after you’ve clicked on some ads where they’ve made money, you may end up buying a product that they own where they even make a bigger share. And that’s the big piece that the Facebooks of the world and the Google are missing, which is that end piece of commerce. That’s a huge piece that they’re missing that one or more acquisitions that they can make, that would really be a game changer here for them.

Shyam Patil:
So we’ve talked about Trade Desk, we talked about Criteo. LiveRamp, what do you think is going to be the impact to them from this change?

Jeff Greenfield:
LiveRamp right now, they’ve got this identity graph which is pretty incredible. It’s incredible in the sense it’s kind of like Criteo in the aspect that Criteo has 20,000 publishers that are part of their network that believe in Criteo. And LiveRamp has every single member of the digital ecosystem contributing data. You can now take our identity that we establish for our clients and link it up with a million other things. It’s absolutely incredible. And the value that they’ve created is that they’ve gotten everybody together.

Jeff Greenfield:
LiveRamp historically is operated based upon third-party cookies and there will be no impact to them over the next two years, but they’re going to have to evolve that strategy. And again, you’re talking some of the brightest minds there. I don’t doubt them at all. Primarily because every single member of the ecosystem from every single advertising technology company, to every single major brand is contributing data into this.

Jeff Greenfield:
What’s interesting is who’s not contributing data? It’s the other wall garden. Google will not allow even our tags, which are independent to be on any Google property if we’re carrying a LiveRamp tag. So the walls have been up against LiveRamp for a very, very long time. So most people see the ecosystem where LiveRamp is its own separate walled garden. But the difference is, is that they are a walled garden in that aspect that they’ve gotten everybody to buy into it and contribute data. So incredibly powerful.

Shyam Patil:
Sounds like you think that two years, nothing major’s happening in February that’s going to show up the ecosystem. Two years is a long time for the scale of public companies to adapt. So you don’t really see much impact to Trade Desk, Criteo, Ramp, and Facebook, Google from the changes that could happen in two years. Is that a fair summary of your assessment of what’s likely to happen in a couple of years from this change?

Jeff Greenfield:
Yes. I’ll add in one piece. One aspect that is going to be impacted has to do with, brands do a lot of what they call brand tracking, which has brands like to know based upon their large global advertising, how do you feel about us? What’s the likelihood that you would refer someone? What’s the likelihood that you would buy? Brands do this and they spend multi-millions of dollars each year. These brand trackers are typically done via surveys. You may see them where the survey pops up on a website. And the way that they do this is that they know whether you got exposed to an ad or you didn’t get exposed to the ad, because they’re tracking technology is there.

Jeff Greenfield:
There’s going to be an impact in the ability of brands to track. And where are they going to be able to do that really well, is that there are companies out there that have people that have opted in where they’re allowing the survey company to look at everything that they’re doing on the web. Every bit of browsing behavior is being passed to them. Even though they may be using Chrome. That’s a separate thing that gets on and Chrome can’t have anything to do with it. And these individuals, they also have it on their TV sets, so you know what they’re watching and they’d have it on their phones too.

Jeff Greenfield:
The company out there that has one of the trackers if you will, of people that have opted in for that has been Comscore. That’s going to become very valuable and there may be a lot of survey companies that are going to start utilizing their group of people, because that’s going to be incredibly important is to have a group of folks that have opted in that allow everything to be looked at so that they can check on what their impact to the brand has been if they were exposed versus that they were not.

Shyam Patil:
Awesome. If anyone in the audience has any further questions, send them over to me and I’ll make sure I get answers back to you and thank you Jeff so much for taking the time to join us today and share your thoughts. This is the very interesting topic that we all have a lot of questions on, and we’re all trying to figure out. And with that, Paul, I will turn it over to you to conclude.

Paul: Certainly. Thank you. Ladies and gentlemen, this does conclude today’s conference call. If you have any questions, please reach out to your Susquehanna representative. You may disconnect your phone lines at this time and have a wonderful day. Thank you for your participation.

In-Home Delivery: Welcome To The Brave New World Of Store-To-Home

Did you ever think we’d reach a tech-enabled retail revolution where groceries would be delivered not only to our front doors, but inside our refrigerators? Starting this fall, Walmart is doing just that with its InHome grocery delivery service. The new service heats up the in-home delivery market, and follows first mover Amazon, which offers in-home delivery inside customers’ front doors, as well as in-car delivery and in-garage delivery.

While these two retailers have high expectations for moving beyond the mailbox — believing that consumers will be willing to sacrifice their privacy in the name of convenience — store-to-fridge represents a new frontier of delivery, breaching the barrier of privacy to our butter, bread and berries. In-home delivery presents an opportunity for retailers to set themselves apart from their competitors and increase market share. But, given the privacy and security risks, in-home delivery services must be cleverly executed.

Amazon pioneered in-home delivery with its Key by Amazon service. Key by Amazon is a connected door lock and security system that allows package carriers into the home via the Amazon app to drop packages inside of a homeowner’s front door. The app alerts consumers of pending deliveries with a series of status notifications and provides users with the option to live-watch the delivery in progress and/or view a video clip of the delivery post-event. Amazon’s drivers are instructed to knock before requesting to unlock customers’ doors via their Amazon handheld scanner. As home access is provided via Amazon’s smart lock and app, the e-commerce giant does not need to share sensitive codes or keys with its drivers. Once the delivery is complete, the homeowner’s door is relocked, and security is contacted if lock issues arise.

While Amazon seeks permission to access customer entryways, Walmart wants permission to walk beyond that threshold to consumer kitchens and fridges. Allowing delivery workers so much farther into American homes could breach the last barrier of privacy.

Walmart understands that consumer privacy and safety is paramount to its success. Similar to Amazon’s home access model, the retail giant announced that it will use smart door lock and smart garage door kits and equip workers with body cameras to ease consumer concerns about strangers entering their homes. In addition, Walmart says it will ensure that employees have at least 12 months on the job before being allowed to enter consumers’ homes. Walmart will also include short bios of each worker within its delivery app to personalize the experience and begin to create loyal customers who will trust this service for all of their shopping needs.

But, as Uber and Lyft have painfully learned, extensive background checks and training for those in contact with customers is rarely enough. The ride-hailing companies have experienced a string of disturbing ride app incidents involving drivers. Uber has since launched an investigational unit devoted solely to driver misconduct, and it says it enforces a “three strikes and you’re out” policy. Meanwhile, ride-hailing company Lyft is under fire in a new lawsuit for reportedly mishandling what is being called a “sexual predator crisis” involving its drivers.

And there are widespread issues that arise from retailers’ use of smart home and video technologies too. Just last month a California father’s Nest camera was allegedly hijacked by woman threatening to steal his 18-month-old son. Last month a criminal reportedly used compromised passwords to hack a family’s camera security system to turn up their thermostat and play obscene music. Igniting further concern, security experts confirmed that no smart lock is perfect and demonstrated the ease of hacking various smart lock brands back in 2016 and shared a slew of smart home security flaws in recent months. Amazon’s Key by Amazon Smart Lock Kit has been the subject of numerous hacking news stories, and I believe that Walmart’s Level Lock could potentially have a similar fate.

Another quandary yet to even be considered by brands, the advertising community and regulators alike is how do retailers venturing into in-home delivery address in-home privacy in a GDPR and CCPA compliant world? The laws are not yet written, yet retailers entering homes will have access to highly personal information that can help them to further personalize interactions and communications with their consumers.

For example, if the bodycam footage of an Amazon or Walmart delivery worker notices, through artificial video recognition intelligence, that a customer is running low on Sir Kensington’s ketchup, should the retailers offer the highest paying bidder the opportunity to deliver a coupon for Hunt’s or Heinz ketchup? Does this action create a privacy concern? Does it violate the trust a customer has built with the company? Or is it simply something that consumers could find creepy? This remains to be seen. In the meanwhile, as a best practice, I recommend that all data should be frequently deleted, and brands should tread very carefully around using consumer data gained in-home until lawmakers play catch-up.

This article was originally published in Forbes.