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This document introduces the concept of website visitor profiling and describes the options the Frosmo Platform provides for addressing profiling issues.

Introduction to profiling

Website visitor profiling essentially means that you collect data about the behavior and potential interests of your website visitors, and then use that data to provide the visitors with relevant, targeted content. For example, on a sports equipment web store, you can track the visitors' location and the product categories and pages they most often visit (such as women's running shoes), and use that information to target them with recommendations relevant for them (such as women's running shoes appropriate for the season and climate of the visitor).

The advantage of profiling is that you can use it to segment markets and tailor services and products to align with individual needs. Other sectors than ecommerce, such as education and healthcare, can also benefit from profiling.

GDPR, profiling, and consent

The General Data Protection Regulation (GDPR), applicable in the EU/ETA area, is designed to make profiling and automated decision-making more transparent to individual persons ("data subjects"). The underlying concern, according to the Article 29 Data Protection Working Party guidelines, is that "profiling can enforce existing stereotypes and social segregation. It can also lock a person to a specific category and restrict them to their suggested preferences [...] or lead to denial of services and goods".

According to the GDPR, profiling is always:

  • Automated data processing
  • Carried out on personal data
  • Performed to evaluate the personal aspects (including economic situation, health, personal preferences and interests, reliability, behavior, and location or movement) of a natural person

This means that data tracking, for example for analytics purposes, is not considered profiling. It becomes profiling only when it involves personal data of a natural person that is used to evaluate and predict the performance, interests, or behavior of that person.

To profile website visitors, and, more broadly, to collect and process personal data about them, you need their consent. Consent means that your visitors freely opt in to data processing, have an ongoing control over how you process their data, and have an opportunity to withdraw their consent at any time. Providing the visitors with a clear opt-in/opt-out option with an explanation of how their data will be used is a good way to seek consent.

However, according to the GDPR, consent is not the only lawful basis to personal data processing. For more information about the other lawful bases, see, for example, the Guide to the General Data Protection Regulation (GDPR) by the UK Information Commissioner's Office (ICO).

Frosmo and profiling

In the Frosmo Platform, the following features are related to profiling:

  • Campaigns
  • Conversion definitions
  • Custom actions (for example, when using geolocation)
  • Modification display options that define whether to show the modification based on visitor history
  • Segmentation and segment groups
  • Target groups

The features can be considered profiling in that they use data about visitor behavior in targeting content to visitors. As mentioned above, segmenting visitors or collecting behavioral data is not profiling in and of itself.

In a relationship between Frosmo and a customer, the customer always represents the data controller, and Frosmo always acts as the data processor. This means that the legitimate and specific purpose for collecting personal data through the Frosmo Platform is always determined by the customer. In addition, the customer ensures that the data subjects have given their consent, one way or another, to data collection and profiling.

If the customer chooses to seek explicit consent by providing visitors with an opt-in/opt-out option, a visitor can refuse profiling. The Frosmo Platform provides the following options for ensuring that no profiling-based content is shown to visitors who opt out:

In addition to the features in the Frosmo Platform, Frosmo can implement customized profiling solutions that are not described in this document. To review the custom solutions on your site, contact your Frosmo representative.

Disabling the Frosmo Platform for a visitor

Disabling the Frosmo Platform for a visitor means that the visitor will not see any content delivered through the Frosmo Platform on the site. Your Frosmo team will implement this solution for you.

Disabling the Frosmo Platform for a visitor works as follows:

  1. The visitor enters the site.
  2. The site displays a consent pop-up or similar prompt to the visitor.
  3. The visitor either accepts (opts in to) or refuses (opts out of) profiling.
  4. Depending on the visitor's choice, the Frosmo Platform behaves in one of the following ways:
    • If the visitor opted in, the Frosmo Platform shows them personalized modifications based on their behavior on the site. For example, the visitor sees product recommendations for products they have viewed on the site.
    • If the visitor opted out, the Frosmo Platform sets the frosmo=off cookie in the visitor's browser. This cookie prevents the Frosmo scripts from loading on that specific browser. The visitor is shown generic content not delivered through the Frosmo Platform. Depending on your site configuration, this may have a significant impact on the usability and user experience of the site.

You can check your site layout with the Frosmo Platform disabled by adding the frosmo=off parameter to any page URL on your site. For example, if the page URL in your browser's address bar is https://frosmo.com/, you can check the layout by changing the URL to https://frosmo.com/?frosmo=off.

Implementing selective profiling

In selective profiling, you define for each content modification which visitors can see it. Before you can define the profiling setting for individual modifications, you must enable selective profiling for the site.

Selective profiling only affects modifications. If you use other profiling-related items, such as campaigns, conversion definitions, or custom actions on your site, you must disable them manually (unless you have consent from your site visitors, or another lawful basis for processing their personal data).

When selective profiling is enabled, the Frosmo JavaScript library still collects modification performance data, product data, and visitor data that can be used to monitor modification performance or to create other statistics about the traffic on your site. However, that data is not used to show targeted content to visitors who have refused profiling.

Selective profiling works as follows:

  1. The visitor enters the site.
  2. The site displays a consent pop-up or similar prompt to the visitor.
  3. The visitor either accepts (opts in to) or refuses (opts out of) profiling. The choice is registered and stored in the browser's local storage.
  4. Depending on the visitor's choice, the Frosmo Platform behaves in one of the following ways:
    • If the visitor opted in, the Frosmo Platform shows them personalized modifications based on their behavior on the site. For example, the visitor sees product recommendations for products they have viewed on the site.
    • If the visitor opted out, the Frosmo Platform shows them generic content modifications not based on their behavior. For example, the visitor sees product recommendations based on the most viewed or purchased products on the site.

When a returning visitor (who was profiled before selective profiling was implemented) enters the site, they may see personalized content until they make the choice to opt in to or opt out of profiling. However, the consent prompt should be disruptive, preventing the visitor from using the site until they have made the choice.

Enabling and disabling selective profiling for a site

You may not have the necessary access rights to enable and disable the Selective profiling module for your site. If this is the case, contact your Frosmo representative for instructions.

To enable selective profiling for a site:

  1. In the Frosmo Control Panel, click your user name, and select Company Settings.

    Enabling selective profiling for a site

  2. Click the quick menu button for the site, and select Set modules.

    Enabling selective profiling for a site

  3. Click Add for Selective profiling.

    Enabling selective profiling for a site

  4. Click Close.

You have enabled selective profiling for the site.

To disable selective profiling for the site, follow the above steps, but click Active for Selective profiling.

Disabling selective profiling for a site

Registering a visitor's choice on the site

After enabling selective profiling for your site in the Control Panel, you have to update the site itself with a feature that seeks visitor consent and sends the visitor's profiling choice to the Frosmo Platform. If you like, your Frosmo team can create the feature and set up the registration call for you.

To register the visitor's choice:

  1. Add the frosmo.easy.profile module to your site's custom script.
  2. Create a UI for the visitor to give their consent or refuse profiling. Depending on your site, this can be a simple pop-up, a banner, or an option on a registered visitor's profile settings.
  3. When the visitor makes a choice to accept or refuse profiling, call the appropriate Frosmo Core function:
    • frosmo.easy.profile.enable(): Enable profiling for the visitor.
    • frosmo.easy.profile.disable(): Disable profiling for the visitor.

The Frosmo Platform does not recognize a visitor as such (unless they are logged in). Instead, the platform recognizes the visitor's browser. Based on the browser data, each visitor is assigned a unique visitor ID that allows the platform to identify the browser on the site, or across domains and sites. The information about the profiling choice registered for a specific visitor ID is stored in the browser's local storage.

The web page must be reloaded after the visitor makes the choice to accept or refuse profiling. Selective profiling does not automatically refresh the page, so you may want to force the page to refresh after the visitor has made their choice.

Managing selective profiling for modifications

The Frosmo Control Panel provides the following profiling settings for a modification:

  • Opt in: The modification is shown to the segments and target groups defined in the modification display options. Use this setting to implement targeted content based on visitor profiling.
  • Opt out: The modification is shown to visitors who have refused profiling. You cannot use any profiling features in the modification, such as segmentation or target groups. Use this setting to implement dedicated or alternative content for visitors who have refused profiling.
  • All: The modification is shown to both segmented visitors and visitors who have refused profiling. You cannot use any profiling features in the modification, such as segmentation or target groups. Use this setting to implement generic UI improvements and bug fixes.

When you define the profiling setting of a modification as Opt out or All, you can only have one variation for the modification, and you cannot use comparison groups with the modification.

The following table shows the relationship between the visitor's profiling choice on the site and the modification profiling settings.

Table: Showing modifications to a visitor according to their profiling selection

Visitor selectionAllOpt inOpt out
Not selectedShowShowShow
Opt inShowShowHide
Opt outShowHideShow

Defining the profiling setting for a modification

To define the profiling setting for a modification:

  1. In the Control Panel, select Modifications > Overview.
  2. In the modifications list, find the modification whose profiling setting you want to define.
  3. Click the modification name to open the modification settings.
  4. Select Display Options.
  5. In the Profiling section, select the profiling setting you want.

  6. Click Save.

Viewing the modification profiling settings

When selective profiling is enabled for a site, all the modifications on the site are labelled based on the profiling settings defined for them.

To view the profiling setting of a modification, in the Frosmo Control Panel, select Modifications > Overview. You can see a status label for each modification.

Figure: Modification profiling settings

Example: Displaying a modification to visitors who have refused profiling

To display a modification to visitors who have refused profiling:

  1. In the Control Panel, select Modifications > Overview.
  2. In the modifications list, find the modification whose profiling setting you want to define.
  3. Click the modification name to open the modification settings.
  4. Select Display Options.
  5. In the Profiling section, select Opt out.

    As a result, the following display options are disabled:

    • Segments
    • Segment combination
    • Target groups
    • Target group combination
    • Max. displays per visitor
    • Visitor session sources

    In addition, if you're using states (custom actions to determine whether the modification is shown to visitors), you must be careful not to use them in a way that can be considered profiling.

    If you have segments, target groups, or other profiling-related display options defined for the modification, and you define the profiling setting as Opt out or All, the profiling-related display options are hidden. You can revert back to the original display options by changing the profiling setting back to Opt in. However, once you save the modification with the profiling setting defined as Opt out or All, the profiling-related display options are permanently removed.

    Similarly, if there is a comparison group created for the modification, and you define the profiling setting as Opt out or All, the comparison group is hidden. You can revert back by changing the profiling setting back to Opt in. However, once you save the modification with the profiling setting defined as Opt out or All, the comparison group is permanently removed.

  6. Click Save.

    A modification with the profiling setting defined as Opt out or All can only have one variation. Upon saving, if your modification has more than one variation, you are prompted to select which one to keep.

You have configured the modification so that it's only displayed to visitors who have refused profiling.

Make sure that the modification content is suitable for all visitors.

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