Prebid Server supports a mechanism for Publisher control for overriding privacy-sensitive activities. See the Activity Controls for more information.
Note that Activity Controls are currently not well integrated with other privacy features, but that will change as these features mature.
If PBS receives ‘device.lmt’ flag in the OpenRTB request, it does the following anonymization:
Prebid Server host companies and publishers have the ability to control the enforcement activities that take place.
The enforcement strategy changed significantly between TCF 1.1 and TCF 2.0. TCF2 is a more nuanced and stricter policy.
If a Prebid Server host company wants to support GDPR, they should register for the IAB Global Vendor List. This is because
end users must provide legal basis for the host company to read/write cookies or /cookie_sync
will return an empty response with no syncs and /setuid
will fail.
If Prebid server determines the user is in GDPR scope, then consent is independently tested for each ‘Purpose’ with different consequences for each:
Activity | Legal Basis Required |
---|---|
Responding to /cookie-sync requests | Purpose 1 (Device Access) |
Setting a cookie on /setuid requests | Purpose 1 (Device Access) |
Conducting auctions | Purpose 2 (Basic Ads) |
Passing User IDs into an auction | Any Purpose 2-10. User IDs are important for more than personalizing ads - they can be used in frequency capping, building profiles, counting unique users, etc. So Prebid Server should pass User IDs through the auction if any of Purposes 2-10 pass the legal basis test. In PBS-Java 2.12 and later, accounts can set configuration which requires user P4 consent before extended IDs can be passed. |
Invoke an analytics adapter | Purpose 7 |
Pass the user’s precise geographic information into auctions | Special Feature 1 |
More details are available in the Prebid Support for TCF2 reference and in the Prebid Server GDPR Reference.
Note: TCF 2.2 strings are processed exactly the same as TCF 2.0 strings. The only difference from a Prebid perspective is that the Global Vendor List is stored on a slightly different path. This new path is supported by PBS-Go 0.260 and PBS-Java 1.123.
There are a number of GDPR configuration settings that PBS Host Companies must consider:
gdpr
flag. (Note: this config is currently called gdpr.default_value
in PBS-Go and gdpr.default-value
in PBS-Java.)uids
cookie in GDPR scope will fail.uids
cookie set in the host company domain should be defined to match what’s in the TCF 2.1 maxCookieAgeSeconds
GVL field. (This is the host-cookie.ttl-days setting in both Go and Java.)The specific details vary between PBS-Go and PBS-Java, so check the version-specific documentation for more information.
The Digital Services Act (DSA) in the EU requires that end users of “very large online platforms” be able to understand whether any of their personal data was used in targeting a particular ad. At a high level, it’s similar to the ancient “Ad Choices” program where users were supposed to be able to understand why they were seeing the particular ads.
See the IAB’s DSA document for background.
Basically, the OpenRTB request and response have new objects defined in the ORTB extension.
Request: $.regs.ext.dsa
Response: $.seatbid.bid.ext.dsa
Prebid Server supports passing these fields through the bidstream and it does validations on the bid responses to make sure they contain publisher-required values.
In general, publishers are responsible for creating the DSA object in Prebid.js, but in some use cases, they can’t, including App and AMP. In addition, some Publishers might find it difficult to update their Prebid.js configuration across a broad network of sites in a short period.
Prebid Server host companies can help resolve this by updating stored requests, but making a broad update across potentially thousands of DB entries can be difficult or undesirable. So PBS-Java also supports account-level configuration to have Prebid Server inject a default DSA object. e.g.
privacy:
dsa:
default: >
{
"required": 1,
"pubrender": 1,
"datatopub": 1,
"transparency": [{
"domain": "example.com",
"params":[1]
}]
}
gdpr-only: true
The IAB’s Global Privacy Platform is container for privacy regulations aimed at helping the ad tech ecosystem bring disparate reguations under one communication path.
Prebid Server support for this protocol:
gpp
and gpp_sid
.See Prebid US Compliance Support for more info.
There are two modules offered by Prebid Server to process GPP string sections 7-12:
Also note that publishers can consider utilizing Activity Controls. For PBS-Java, the gppSid
, geo
, and gpc
conditions may be useful tools within a compliance strategy.
The Children’s Online Privacy Protection Act (COPPA) is a law in the US which imposes certain requirements on operators of websites or online services directed to children under 13 years of age, and on operators of other websites or online services that have actual knowledge that they are collecting personal information online from a child under 13 years of age.
If regs.coppa
is set to ‘1’ on the OpenRTB request, the following anonymization actions take place before going to the adapters:
The California Consumer Privacy Act (CCPA) is a law in the US. which covers consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses.
The IAB has generalized
this state-specific rule into a US Privacy compliance framework.
If regs.ext.us_privacy
is parsed to find that the user has opted-out of a “sale”,
the following anonymization steps are taken:
In support of the Global Privacy Control, Prebid Server passes the Sec-GPC
HTTP header through to bid adapters. It
does not currently take action on this header by default.
A publisher can utilize Activity Controls to link anonymization actions
to the precence of the GPC flag. See the gpc
rule condition in the
Activity Controls for
more information.
Prebid Server does not recognize the Do-Not-Track header. The committee determined that it’s obsolete in general and not supported on Safari specifically. We prefer not to implement, test, and document unsupported privacy flags. Prebid Server is not going to make a dent in the overall problems with DNT.
We may reconsider this position if community members provide evidence that the flag is meaningful to their customers or lawyers.
IPv6 addresses may be anonymized differently for Prebid Server host companies depending on how they’ve configured the server: