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Contextual-only advertising program

advertising-contextual-targetingDomain: advertisingType: mixed

Description

When a product serves ads to user segments that regulators have placed under heightened protection (minors, sensitive-category profiling targets) the lower-risk path is to serve contextual ads — selected by the content surface or query keyword rather than by inferred user attributes — and to NOT serve behavioral / profile-based ads to those segments. The control documents three pieces: a contextual-ad policy specifying which user segments are profile-ad-excluded, the technical configuration of the ad-serving integration that enforces contextual-only mode for those segments, and the audit log showing per-impression which mode was used. Vendors in the contextual-ad space ship targeting based on page content + computer-vision content classification rather than user profiles, which simplifies the compliance posture against DSA Art 26, GDPR Art 22, AADC, and KOSA's profile-ad restrictions on minors.

Required by (3 regulations)

  • DSA

    Article 28 — online platforms accessible to minors must not present profile-based advertising using personal data of users they know with reasonable certainty to be minors.

    DSA Art. 28

  • UK AADC

    Standard 13 (Profiling) — profiling off by default for likely-to-be-children users; behavioral-ad profiling specifically called out.

    ICO AADC Standard 13

  • CA AADC

    §1798.99.31(a)(4) — businesses may not profile a child by default; default-off profiling necessarily disables behavioral ads to children.

    Cal. Civ. Code §1798.99.31(a)(4)

Fulfilled by (3)

  • gumgum · full · medium effort · $$
    Contextual ad platform — computer-vision-based page-content targeting, no user-profile dependency.
  • seedtag · full · medium effort · $$
    Contextual ad network — AI-driven content matching; explicit cookieless / no-profile offering.
  • In-house build · high effort
    Configure ad-serving integrations (e.g. Google Ad Manager, custom DSP relationships) to disable profile-based targeting for minor / sensitive segments; audit per impression.

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

  • contextual-ad policy doc
  • ad-serving configuration screenshot / config-export
  • per-impression audit log (segment → mode)
  • minor / sensitive-segment exclusion-list

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions.

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Built by Neel Patel, in-house game counsel. Games touch more compliance domains at once than anything else in tech. That's what ClearLaunch was designed around.

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions. Operated by a Washington-licensed attorney. Not licensed in California or other US states. ClearLaunch provides legal information; consult a licensed attorney in your jurisdiction. Data reviewed through March 2026. Methodology

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