About Display & Video 360 and bidding on personalized ads inventory in compliance with the GDPR

Please see the following information to understand when Display & Video 360 can bid on personalized and non-personalized ads inventory in accordance with the General Data Protection Regulation (GDPR).

Bid on personalized and non-personalized ads

Display & Video 360 will bid on personalized ads when all of the following criteria are met:

  • End user grants Google consent to:

    • Store and/or access information on a device (Purpose 1)

    • Create a personalized ads profile (Purposes 3) 

    • Select personalized ads (Purposes 4)

  • Legitimate interest is established for Google to:

    • Select basic ads (Purpose 2)

    • Measure ad performance (Purpose 7)

    • Apply market research to generate audience insights (Purpose 9)

    • Develop and improve products (Purpose 10)

  • The SSP or exchange needs to register for at least one purpose and have obtained a valid legal basis for that purpose.

  • The legal bases of the SSP or Exchange for purposes 3 and 4 conforms to the guidance published in this article.

  • The SSP or exchange does not register for "Actively scan device characteristics for identification" (Special Feature 2) or the SSP or exchange registers Special Feature 2 but the Transparency & Consent (TC) string indicates the user does not opt-in to Special Feature 2.

If the consent requirements for personalized ads purposes are not met, Display & Video 360 will bid on non-personalized ads when all of the following criteria are met:

  • Google has consent to:

    • Store and/or access information on a device (Purpose 1)

  • Legitimate interest is established for Google to:

    • Select basic ads (Purpose 2)

    • Measure ad performance (Purpose 7)

    • Apply market research to generate audience insights (Purpose 9)

    • Develop and improve products (Purpose 10)

  • The SSP or exchange needs to register for at least one purpose and have obtained a valid legal basis for that purpose.

  • The legal bases of the SSP or Exchange for purposes 3 and 4 conforms to the guidance published in this article.

  • The SSP or exchange does not register for "Actively scan device characteristics for identification" (Special Feature 2) or the SSP or exchange registers Special Feature 2 but the Transparency & Consent (TC) string indicates the user does not opt-in to Special Feature 2.

Serve third-party pixels

Display & Video 360 only serves ads with third-party pixels when all of the third-party pixels meet all of the following criteria:

  • Each vendor needs to register for at least one purpose and have obtained a valid legal basis for that purpose.

  • The legal bases of the vendor for purposes 3 and 4 conforms to the guidance published in this article.

  • Each vendor either does not register "Actively scan device characteristics for identification" (Special Feature 2) or registers Special Feature 2 but the Transparency & Consent (TC) string indicates the user does not opt-in to Special Feature 2.

Note that if a vendor is not registered on the IAB Europe Transparency & Consent Framework Global Vendor List (GVL), Display & Video 360 will honor the consent found in the CPS (Consented Provider Setting) signal.

 

Macros

Display & Video 360 supports the following macros for passing GDPR-related information via third-party pixels:

  • ${GDPR}: 0 or 1, 0 = traffic from a non-GDPR region, 1= traffic from a GDPR region

  • ${GDPR_CONSENT_xxxxx} where xxxxx is the numeric Vendor ID of the vendor receiving the TC string: TC string received in bid request. 

Consented Provider Solution (CPS)

Consent Provider Solution (CPS) support: Display & Video 360 will support both the CPS and TCF v2 simultaneously. If Display & Video 360 receives bid requests with both TCF and CPS consent information, Display & Video 360 will respect the TC string and append CPS vendors which are not registered with IAB GVL. 

Cookie sync

Google will support both &gdpr and &gdpr_consent parameters to pass TCF v2 consent information for both in-bound and out-bound cookie sync requests. These parameters are optional.

If the &gdpr and &gdpr_consent parameters are present in the cookie match request, Display & Video 360 will sync cookies with third-party vendors if all of the following criteria are met:

  • Google has consent to:

    • Store and/or access information on a device (Purpose 1)

    • Create a personalized ads profile (Purposes 3) 

    • Select personalized ads (Purposes 4)

  • Legitimate interest is established for Google to:

    • Select basic ads (Purpose 2)

    • Measure ad performance (Purpose 7)

    • Apply market research to generate audience insights (Purpose 9)

    • Develop and improve products (Purpose 10)​

  • The legal bases of the SSP or Exchange for purposes 3 and 4 conforms to the guidance published in this article.

  • Each vendor either does not register for "Actively scan device characteristics for identification" (Special Feature 2) or registers Special Feature 2 but the Transparency & Consent (TC) string indicates the user does not opt-in to Special Feature 2. 

  • Each vendor needs to register for at least one purpose and have obtained a valid legal basis for that purpose.

  • End user grants the vendor consent for Store and/or access information on a device (Purpose 1).

    For Display & Video 360-initiated cookie match requests, &gdpr and &gdpr_consent parameters will be appended to exchange-provided cookie match URLs, and the parameter values must be forwarded on redirect, in accordance with the IAB TCF spec.

Frequently asked questions 

How does Display & Video 360 handle bid requests containing both TCF string and CPS field? 

If a bid request includes both CPS and TCF v1 fields, Display & Video 360 does not bid for this request as Display & Video 360 does not support TCF v1.

If a bid request includes both CPS and TCF v2 string, Display & Video 360 respects the consent in the TCF v2 and CPS consent to vendors which are not registered with IAB GVL.

Example:

Assume there are 3 vendors: Vendor A, Vendor B, and Vendor C

  • Vendor A and vendor B register with the IAB GVL
  • Vendor C does not register with the IAB GVL

If Display & Video 360 receives a bid request containing both TCF v2 string and CPS, the TCF v2 string includes vendor A, but not vendor B and C. The CPS includes the consent of vendor B and C. In this case, Display & Video 360:

  • Respects the legal basis of vendor A in the TCF string
  • Ignores the consent to vendor B in the CPS string
  • Respects the consent to vendor C in the CPS string.

Does Display & Video 360 support Global scope & Out-of-band scope?

Per our existing EU User Consent policy, publishers must clearly identify each party that may collect, receive, or use end user’s personal data as a consequence of using a Google product. Therefore Display & Video 360 does not bid on requests which indicate Global scope or Out-of-band scope.

Can you give some examples to explain Google’s requirement of purpose 3 and 4?

Legal basis of Google:
Does the user grant consent of purpose 3 and 4 to Google? Eligible for personalized ads? Display & Video 360 behavior
Yes Yes Display & Video 360 may bid for personalized ads, depending on other legal basis.
No No Display & Video 360 may bid for non-personalized ads, depending on other legal basis.

 

Legal basis of SSP or Exchange vendor:

SSP or Exchange purpose 3 and 4 registration in GVL Publisher restriction for purpose 3 and/or 4 Eligible for personalized ads? Display & Video 360 behavior
Legitimate interest only Requires legitimate interest or Undefined No If the user does not object to legitimate interest for purposes 3 and 4. Display & Video 360 does not bid. If the TC string indicates that ad personalization is not permitted, depending on the other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid.
Legitimate interest only Not allowed or Requires consent No Display & Video 360 does not bid for personalized ads. Depending on other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid.
Consent only Requires consent or Undefined Depends on user consent Depending on user consent to purpose 3, 4, and other legal basis, Display & Video 360 may bid for personalized ads, non-personalized ads, or does not bid
Consent only Not allowed or Requires legitimate interest No Display & Video 360 does not bid for personalized ads. Depending on other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid
Flexible (consent by default) Requires consent or Undefined Depends on user consent Depending on user consent to purpose 3, 4, and other legal basis, Display & Video 360 may bid for personalized ads, non-personalized ads, or does not bid
Flexible (consent by default) Requires legitimate interest No If the user does not object to legitimate interest for purposes 3 and 4. Display & Video 360 does not bid. If the TC string indicates that ad personalization is not permitted, depending on the other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid.
Flexible (consent by default)  Not allowed No Display & Video 360 does not bid for personalized ads. Depending on other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid
Flexible (legitimate interest by default) Requires consent Depends on user consent Depending on user consent to purpose 3, 4, and other legal basis, Display & Video 360 may bid for personalized ads, non-personalized ads, or does not bid
Flexible (legitimate interest by default) Requires legitimate interest or Undefined No If the user does not object to legitimate interest for purpose 3 and 4. Display & Video 360 does not bid. If the TC string indicates that no ad personalization is permitted, depending on the other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid.
Flexible (legitimate interest by default) Not allowed No Display & Video 360 does not bid for personalized ads. Depending on other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid
Not used Not allowed or Requires legitimate interest No Display & Video 360 does not bid for personalized ads. Depending on other legal basis, Display & Video 360 may bid for non-personalized ads or does not bid
Not used Requires consent or Undefined Depends on user consent to Google Depending on user consent to purpose 3, 4, and other legal basis, Display & Video 360 may bid for personalized ads, non-personalized ads, or does not bid

 

 

 

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