Privacy Watchdog Brings Starz into Compliance with Digital Advertising Privacy Best Practices

McLean, VA – December 12, 2023 - BBB National Programs’ data privacy watchdog, the Digital Advertising Accountability Program (DAAP), is continuing efforts to bring the Starz Entertainment, LLC website, Starz.com, into compliance with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for online interest-based advertising.

Starz offers premium film and television content through cable television channels, the starz.com domain, and various streaming applications. As part of its ongoing monitoring activity, DAAP conducted a review of the Starz.com website for third-party targeted advertising practices.

As set in the DAA Principles for Online Behavioral Advertising (OBA), a first party that allows third parties to collect visitors’ web browsing data for Interest-Based Advertising (IBA) must provide visitors with notice, enhanced notice, and an opportunity to exercise choice regarding that data collection. 

Starz's privacy policy disclosed IBA information but lacked the required enhanced notice links. There was no separate link on Starz.com directly leading to an IBA disclosure. While each page had a privacy policy link in the footer, it did not meet the criteria for enhanced notice as it was not distinct from a general privacy policy link and did not direct users to IBA information. Additionally, the privacy policy acknowledged third-party IBA activity and provided opt-out links but these were not concatenated for easy viewing by and for the consumer.

In response to DAAP’s inquiry, Starz conducted a review of its compliance with the DAA Principles to identify areas in its compliance protocols that needed strengthening. After consulting with DAAP, Starz committed to the following actions to ensure consumers wishing to learn more about how their data is being collected and used by third parties would be directly delivered to relevant information about IBA practices and consumer choices affecting IBA collection: 

• Adding a "Cookies/Ad Settings" hyperlink in the footer of each webpage directing users to the sections in the privacy policy most relevant to IBA practices, such as "Advertising Cookies," "Embedded Scripts / Web Beacons," and "Third Party Ad Servers."
• Adding language to the IBA disclosure mentioning the option to opt-out via a jump link to the "Interest-Based Advertising" section.
• Adding jump links at the end of the paragraphs on "Advertising Cookies" and "Third Party Ad Servers" for easy access to user choices after reading about third-party technologies for collection.

In its statement, Starz Entertainment stated: 

Starz is committed to transparency and consumer choice. We commend the Accountability Program’s mission and its dedication to overseeing compliance with the industry, self-regulatory DAA Principles. Starz welcomed the opportunity to voluntarily participate in a collaborative process with the Accountability Program to identify ways to increase consumer awareness of interest-based advertising, in accordance with these industry principles. We are confident that the voluntary actions Starz took to implement enhanced notice and emphasize consumer choices demonstrate our ongoing commitment to privacy and our respect for the Principles.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of DAAP decisions, visit the DAAP Decisions and Guidance webpage.