DEMO SUPPLY / THE PUBLISHER’S RESEARCH DESKPERMISSION · COVERAGE · DELIVERY
Demo SupplySourcing research for US-facing publishers
Scope a shortlist

06Expert Q&A

12. What does the embedded game collect, and can the publisher enforce visitors’ privacy choices?

Interview objective: Connect contractual data descriptions with observable browser behaviour.

Put this to: Michelle W. Cohen, the supplier’s privacy lead and the publisher’s engineer.

Why it matters to buyers: California’s privacy regulator explains that covered businesses must honour qualifying opt-out preference signals, such as Global Privacy Control, as requests to opt out of sale or sharing. This does not mean every publisher or every network request is covered; applicability and the nature of the processing require assessment. (cppa.ca.gov)

Draft framing — a good answer should cover:

  • A data-flow map identifying recipients, purposes, identifiers and retention.
  • Applicable roles and contractual restrictions for each party.
  • Behaviour before interaction, after launch and under relevant privacy choices.
  • Whether optional analytics and advertising can be disabled independently of gameplay.
  • How opt-out or consent choices are transmitted, tested and recorded.
  • What happens when the supplier changes a tracker, recipient or purpose.

Sharp follow-up: “Show us the difference in network behaviour with the relevant privacy choice active. Which remaining requests are necessary, and who has assessed that?”

Buyer output: A counsel-reviewed data inventory and an engineering test record.

Do not accept either “it is inside an iframe, so it is not our problem” or “a consent banner solves it” as a completed assessment. Request the specific responsibilities and technical controls for this implementation.

Expert quote — awaiting interview: [Approved quotation and attribution.]

Sources cited on this page

  1. cppa.ca.govwww.cppa.ca.gov