Navigating Affiliate Tracking & Consent Laws with Steven Brown

[00:00:11] Jake Fuller: All right, welcome back to the Profitable Performance Marketing Podcast. I am your host, Jake Fuller, CEO of JEBCommerce. Our topic today is one that I think is gaining a lot more attention and I’ve been really excited to cover this. So we’re going to talk today about affiliate tracking and some of the changes between not only consent laws, but different consent platforms that have popped up in the US and the different state by state laws that mandate that for consumer protection and how that has an effect on affiliate tracking and why merchants, publishers, and networks should definitely take notice.

[00:00:48] So I don’t think there could be a better guest for this, someone that I’ve seen tackling this head on in the space. We have Steven Brown from Moonpull on the podcast today. Welcome Steven.

[00:01:00] Steven Brown: It’s great to be here, Jake. Thank you for having me.

[00:01:02] JF: Oh, it’s a pleasure. I really enjoyed our chat at ASW just last week. I’ve been bothering Steven for a good portion of time now, so we can get him on. This has been a topic I’ve had interest in well over a year, and you guys have seemed to truly dive headfirst into the topic in covering, ways to get around these issues, how to better identify these issues, and why it’s important for our industry to take note of the changes of not only consumer behavior, but consumer consent online.

[00:01:34] So I appreciate you jumping in.

[00:01:36] SB: Yeah, no, it’s good to be here. And it’s a definitely an important topic. And it is definitely getting traction in the US. Obviously, I’m a European, and we’ve had our laws in Europe for longer. So we perhaps got a little bit more experience on what the direction of travel might be for user consent tracking issues that arise because of it.

[00:01:58] JF: And for our listeners, before we start diving into questions, do you mind doing a quick background on your industry knowledge and space that you’re in and where you’re at currently?

[00:02:07] SB: Yeah, so I’ve been in the affiliate industry since 2000, so I started off by founding a network that we sold in 2008 that was called BuyApp. We sold it to AOL then changed their strategy and sold it in about 2011 onto AWIN, and I broadly say about a third of the AWIN business today is the legacy of the business they bought in 2011, and I think we were technically innovative at the time, so we were doing things like served server tracking, we introduced click IDs into the industry, which people take for granted now. And working at a network, it teaches you even back those days that tracking is both an art and a science.

[00:02:57] A science because you can go and read the way they implement tracking, an art because advertisers have other complexities with their site that need to be taken into consideration when tracking is implemented.

[00:03:11] So I had the network background, I’ve then worked for a number of publishers, one of which was a cashback site here in the UK called Easy Fundraising, and when you work at a cashback site, you get a feeling for untracked sales. So the user queries and they then align with what I knew from my network days.

[00:03:36] And what that taught me is, whether it’s 5 percent of sales that go untracked or 10 percent of sales that go untracked, it’s actually perhaps 0.1 percent on some advertisers and 50 percent or more on other advertisers. So actually, understanding how to get back the revenue from tracking issues should be on an advertiser by advertiser basis and going after the low hanging fruit.

[00:04:05] So Moonpull was founded to help analyze tracking and solve tracking issues, initially on the low hanging fruit scenarios, but actually what we find is it gives insight into other scenarios as well, even if it can’t pinpoint the issue.

[00:04:23] JF: Fantastic. So this is why you are on the show for this topic. A lot of experience around tracking, how that’s implemented and the nuances for advertisers on how they implement some of those tracking metrics that we all know and love. So I want to start with the basics. Classically speaking, when a merchant jumps in to the affiliate channel and they set up a program, what has been the status quo for how we track those affiliate conversions through the channel for a merchant?

[00:04:52] SB: So the standard way of tracking is a publisher has a URL on their site that redirects through a network redirect path. It lands on the advertiser’s site and the advertiser’s site typically has a piece of javascript in it that then sets a cookie reading a parameter out of the URL that the network added. So that is what we call the handover of the part of the journey and then at the other end of the journey you have you’ve got the confirmation page, the checkout, that then talks back to the affiliate network.

[00:05:31] And so the cookie that is set at the handover is forming the memory between the handover and the checkout, and one of the reasons to use a cookie or local storage at that point is it’s recorded on the user’s device, so if they turn their device off and open their browser one day, three days, ten days later, the cookie is still there to be read at the checkout.

[00:05:57] JF: And we see that pretty often and this is why there’s been quite a bit of buzz around third party cookie depreciation, which Google has delayed. They were supposed to go through that last year. What are some other ways that brands can set up? I know those that are worried about cookie depreciation don’t realize that for well over a decade, if I’m not mistaken, server to server tracking has also been a way to implement more clear and precise tracking between merchants and affiliate programs.

[00:06:29] SB: Yeah, so there’s a hierarchy of tracking, and if a network broadly might have three or even four methods of tracking at when you get to the checkout, and If the network gets three or four signals saying a sales happened, they’re delighted. They can get rid of the duplicates and one remains. And so the third party tracking is essentially how affiliate marketing started back in the day.

[00:06:59] And that is not a cookie being set by JavaScript on the landing page, but it’s actually a cookie being set in the redirect. So in the case of AWIN, they redirect through a domain, AWINone.Com, and the cookie is set on that domain. But that, that cookie then becomes a third party cookie, if you’re on the site of an advertiser, so advertiser.com, it’s a cross domain cookie and therefore, it’s viewed as a third party one.

[00:07:34] What’s important to remember is we talk a lot about Chrome deprecation of third party cookies, but Safari effectively did the same in 2017, 2018. So that old legacy method of tracking does not work in the Safari audience.

[00:07:53] And depending on what data you look at, Safari might be 30 percent of the traffic to, that a publisher sends to an advertiser. And therefore, deprecation has already happened on that 30 percent. So that means a good reliable first party method is needed for that traffic otherwise it won’t track today.

[00:08:19] JF: Got it. And that highlights the nuances of networks and we obviously represent quite a few brands, and depending on the network that we’re launching them in or managing their program through, we do explain to them, and a lot of the times they don’t realize that there’s multiple touch points on how that conversion or consumer is being tracked.

[00:08:36] And there’s fallbacks if one doesn’t deploy correctly. So that first party tracking is definitely the standard on how you want to set up your program.

[00:08:44] SB: Yeah and to that point that server to server is often talked about in a different phrase to first party tracking but server to server, in most cases sets a first party cookie or local storage just in the way that JavaScript does on the user’s site. And when you think about it, you still need the memory.

[00:09:08] So, whether the cookie is being set by a server based method or a JavaScript based method, it has to set that memory. So plenty of networks recommend to their clients to have both server to server tracking and JavaScript based tracking from a master tag, for instance.

[00:09:29] JF: And in either case, all of this can be greatly affected when it comes to new consumer protection laws, when it comes to personal information, the collection of that information, and how brands and partners work with individuals that are coming to their site and whether or not they want that collected. Now in the UK you guys have passed I would say more aggressively, consent laws that have affected this more drastically than we’ve seen in the US so far but that seems to be shifting in the US market.

[00:10:00] Can you talk about the different policies that have come out that have started to affect any of these different tracking methods when it comes to consumer consent and how consumers have a bit more power these days to stop any of that personal information being tracked or that cookie being placed on their device and what we’ve seen the impact in our channel is.

[00:10:20] SB: So with the caveat that I’m no lawyer, which everyone in my circumstance says, in Europe, we have two laws around the setting of cookies and the setting of tracking and the use of personal information. The most well known is GDPR that came in, I think, in about 2018. But we also have another law called PECR which is about the strict setting of a cookie.

[00:10:47] It doesn’t matter whether it has personal information in it. It doesn’t matter whether the information in it is innocuous. It is basically, if you are going to write something onto a user’s device, you need consent for it, unless it falls into one of the categories of exemptions. So that is a essentially a strict law on the setting of a cookie.

[00:11:10] There’s no ifs, no buts, no sort of wriggle room, unless it is a defined exemption. And actually what that does in Europe for affiliate marketing is rather negates the consideration of whether affiliate tracking involves personal information, because the first law captures affiliate marketing in most circumstances, so you don’t need to go to the second test.

[00:11:37] Whereas if I use CCPA as the sort of flagship law in the US and obviously not every state has a law at the moment, but CCPA is very much around personal information. So it actually is the analog to the law that doesn’t really bite in Europe. So actually the way that personal information is appraised with regards to affiliate tracking, that conversation is really starting more for the US than it ever did in Europe. And the, the question of whether something is personal information depends more on the circumstances. And we discussed this at ASW, as you mentioned earlier, and Santi from CJ came out with the very nice phrase that you never become a legal counsel because you love risk. And so it then leads to what is personal information?

[00:12:38] Often there’s a risk adverse approach to determining what is personal information.

[00:12:44] JF: As these different laws and restrictions, continue to pass… now, you had mentioned in the US not all states have these laws, but it has grown the past few years. It’s gone from, maybe five states that have implemented stricter laws on personal information and how that data is collected. I think it’s up to maybe 20 now.

[00:13:02] SB: Yep, 20 is my understanding.

[00:13:04] JF: So it is growing. So what impact do you see for advertisers who sell in the US, or maybe they sell globally, but let’s focus on the US for now. You’ve got 20 states that they have to pay attention to what consumer consent laws have to be followed compared to states that maybe don’t have or have more leniency.

[00:13:21] But overall, from an e com perspective, there’s going to be an impact on the website and how consumers are transacting. Where in that lies the issue with breaking a tracking code and missing out on affiliate sales.

[00:13:35] SB: Okay, so broadly the laws say if you’re going to deal in personal information, you need consent to do so, and the way that I look at CCPA is, it’s not a law about affiliate marketing. It’s not even a law about online marketing. If you have 50 stores, let’s say in California, and you take people’s email addresses at the checkout, you need to be complying with CCPA to give those people the right to be forgotten.

[00:14:08] The right to have their data deleted, the right for their data not to be used, and you need, therefore, if you’ve got hundreds of thousands or millions of customers, you need a consent infrastructure to be able to manage the information you gather and your obligations under the law. And in my mind the consent prompts, the pop ups, the consent management platforms that you see on websites are just the front window on that consent infrastructure.

[00:14:38] So a legal counsel has to have some sort of consent infrastructure, whether they devise it themselves internally, or whether they go to one of the providers, and the leading one is OneTrust. So that then leads to a consent management platform being at the start of an online user’s experience of a website.

[00:15:00] And that then leads to the questions that we’re familiar with. Do you consent to using my data? Do not sell my data. Manage preferences, etc. The how the advertiser chooses to ask their questions is part of their approach to interpreting the law and managing risk.

[00:15:18] JF: I would say over the past, honestly, the past two years, if I go back further, I thought it was a lot less common, but the past two years, as I browse brand websites, pretty consistently, not only for the clients that we manage, but looking at prospects or competitors, et cetera, it’s become more and more common where I almost expect to have that front end pop up or that footer that doesn’t allow you to fully interact with the site until you give it permission or not permission to do X, Y, Z.

[00:15:45] It’s represented in different ways, depending on the site.

[00:15:48] SB: Call that is the consent management platform forcing engagement with it. Back in the day, you could almost go through to the checkout and just ignore the cookie banner at the bottom of the screen without engaging with it. Whereas now, what we see, more anecdotally, as you were saying, is we see more instances of forced engagement.

[00:16:12] And what we also saw in the UK is after the laws were passed, the first stage was the consent management platforms were bolstered. So they went from the small bar you could ignore to the ones that you can’t ignore, but they didn’t control the first party affiliate tracking for a year or two years or three years after the law came into force.

[00:16:36] And then we got the regulators biting a little bit more and saying, you know what, it’s great that you’ve got the consent management platform, but we’d actually like you to be controlling the cookies according to the law. And so from 2021, 2022, three or four years after the law, we see more advertisers controlling the affiliate first party tracking such that it only initiates if the user gives consent.

[00:17:08] So what the flip of that is, the first party tracking is not being initiated if the user declines to give their consent.

[00:17:16] JF: And that in lie is where the problem. So when those users give, do not give consent, that master tag or the deployment of that first party data tracking is not implemented on site. So then that consumer continues to shop, converts, and it’s no longer tracked through the affiliate network in most cases.

[00:17:35] And so through the data you guys have combed through, do you have a good idea of just generally speaking, what percentage of users don’t allow consent where that tag never gets to be deployed?

[00:17:47] SB: Okay, so there’s three things I should remember to talk about in the next few minutes. One of which is the percentages that you’ve just mentioned. Second is how the hierarchy of tracking that we spoke about earlier interacts and the third is, actually, it doesn’t really matter what the law is, it’s what the implementation is that is important.

[00:18:14] Coming back to the first, what percentage do we see being inhibited? It relates to the second, which is the hierarchy of tracking. And, in Safari, there is no third party tracking fallback. There might be other methods that kick in. So it might be the advertiser is using a voucher code at the checkout to do the tracking.

[00:18:38] So all is not lost. But the primary method of setting a first party cookie is lost if the advertiser requires consent and the user declines to give consent. So if Safari is 30 percent of an affiliate’s traffic and half of the that traffic has advertisers that require consent, that’s 15 percent of the traffic, and then if half of those people say no, that’s 7.5 percent of the traffic that publisher is sending is not going to track for consent reasons at this moment. But that, that is, is over a portfolio of clients. If you’re interested in just the one advertiser that has consent controlled tracking, the loss in that 30 percent is obviously 15 percent of someone’s whole traffic base.

[00:19:34] Then you say what happens in the other 70 percent and to make life simple, let’s say that over the 70 percent is Chrome and so Google controlled. At the moment, Google allow the third party backup. And the way the third party tracking works is it’s set on the redirect path. So before a user sees anything on their screen.

[00:20:00] So it’s outside the scope of consent platforms at the moment. So on Chrome, if someone says no, then the third party backup method at the moment kicks in. And we know that Google has said that they’ve put the third party deprecation on hold, but we look at that and say, actually, that’s not good news because they’re not telling us precisely what they’re going to do, and they’ve no longer given the timescale and you link that to Vouchergeddon, which in, I think, March last year, Google said they were going to do something and then they did something in May. Now who knows how quickly Google are going to come up with their approach to third party deprecation and how quickly they’re going to do it. So I think, from my mind, the whole affiliate industry should be on watch and be fearing what Google does.

[00:20:55] Not what I feel a little bit more, which is where there’s been a slight sigh of relief.

[00:21:00] JF: I agree. And it’s funny because one of the keynotes at Affiliate Summit, this is a sidebar, was whether Google was an affiliate friend or foe, and it was a discussion with some PMA members. And I love the conversation and just this idea because whenever Google makes a big policy change or an update to, what they’ll allow or disallow or an update to their algorithm it makes very big waves across many industries, but especially in the e com world when it comes to digital marketing.

[00:21:25] It is something that to keep sight of Google holds a lot of power. And if they did depreciate like Safari already has, now you’re implementing, upwards of a hundred percent of the traffic source coming through a merchant program or a merchant site can have that same effect where.

[00:21:41] You’ve got this large percentage that might be saying no to deploying that master tag and then there’s not a fallback to that third party cookie any longer. Is there other actions in which merchants can take to ensure that tracking exists?

[00:21:56] SB: It’s difficult because the determination of whether affiliate tracking involves personal information. It then comes down to different networks do different things different do tracking slightly differently. And, different advertisers do different things with the data that they receive. So some might be very heavy on mining their data.

[00:22:20] Some might be in the medical industry where they’ve got to be really concerned about personal information. And I don’t know whether this is impactful or not, but some publishers will have a logged in audience. Some will be doing email retargeting. So they know something about the user before they send the user through to the advertiser.

[00:22:43] So the considerations that the legal counsel has to go through are quite far and wide. But nevertheless, the e com department still wants tracking to work. And these laws are not just affiliate laws. They impact on other industries as well. So if you want to use Adobe, you’ve got to have considerations for, is there first party tracking enabled?

[00:23:07] And the third part of the one, two, three, I said earlier is what we see is even if an advertiser wants to implement a consent platform such that the cookie should be immediate, we still see poorly implemented consent platforms that stop the first party tracking. So even if the intention is for it to be there the tech team have not quite understood the brief, let’s say, and they’ve got the implementation rolled out poorly.

[00:23:39] It’s very important to, to check the quality of the implementation. And often what happens is you can’t apply 20 laws realistically in a technical implementation. So many advertisers will say, we’ll apply the most stringent view that we have to all 50 States, or we’ll apply, and we see only a handful of times, differentiating states on one group to another group.

[00:24:07] JF: Anything that nuanced can obviously be implemented poorly and cause additional issues when you’re trying state by state implementation of that you had just mentioned where some of those platforms may roll out and consumers can give consent, but it still doesn’t launch that master tag as if they didn’t. So boil this down we obviously represent a lot of merchants. We work with a lot of publishers. How much are publishers taking notice and what kind of effect is it having on the trust between a publisher and an advertiser if there’s disparity between what the publisher thinks that they’re converting at versus what the network’s actually tracking with the advertiser.

[00:24:47] SB: I think we’ve spoken a lot about user consent. There’s also tracking issues for other reasons that are nothing to do with user consent and have affected affiliate marketing through the years. And it’s you know, the tag doesn’t appear or the pixels be removed from the confirmation page.

[00:25:08] So there’s two, two sets of issues that impact affiliate tracking. Those that relate to the imposition of user consent and those that relate to the advertisers putting in place just the tracking normally. And, to a degree, because everything is a slow drift, publishers in Europe were relatively sanguine for saying we’re earning money. We’re all right. We know what’s going on. We know that tracking is not perfect, but we know that this is the profit we’re making.

[00:25:40] And I think over the time that we’ve been working with publishers… so I estimate about 40 percent of UK affiliate revenue is through Moonpull’s clients. So we have a very good conversation with the larger publishers and they’re starting to view how they choose advertisers differently.

[00:26:03] Earlier this month, sorry, earlier this year, we had a mini conference in London on publishers talking about how they’re selecting advertisers. And we’ve seen our clients through the course of their first year being a Moonpull client actually go out and think we’ve got to look at BI differently.

[00:26:24] Perhaps we’ve got to hire somebody in to look at actually how we’re maximizing revenue. And then they realized that maximizing revenue advertiser by advertiser, isn’t necessarily the right thing to do.

[00:26:38] Perhaps it’s more about optimizing revenue across the whole portfolio of advertisers they use. And then I think that leads to the very mature decision that sometimes publishers need to make the decision not to work with an advertiser if they’re not happy with the commercial relationship.

[00:26:58] When I talk to many networks, they suggest that publishers have more clout than they believe they have with getting things fixed. And again, Santi and David said that in the ASW keynote. And I think that’s true. And therefore publishers, if they can articulate why tracking is not working so well, they’ve got a better opportunity to get it fixed.

[00:27:23] And this is what we start to see with our Moonpull clients. So our Moonpull publishers, understand tracking better. They, through using Moonpull, they can really articulate the tracking scenario of an advertiser and then they can actually end up with a very high quality conversation with the advertiser about why it’s not tracking properly or why they feel the sales are not being rewarded fairly.

[00:27:51] And then they can develop the relationship from there. As an example, before Black Friday, a publisher of ours said, we’ve seen a commission drop with an advertiser, and by using Moonpull, they realised that the advertiser was sending their traffic to advertiser.com and then half the traffic to uk.advertiser.com. One half was tracking and the other half wasn’t. And the advertiser said first time it’s probably a low conversion because it’s an offer that’s enticing people in to have a look at the offer and they’re not buying. And the publisher didn’t buy it. So they pushed a bit harder. Then they got another reason for the drop.

[00:28:34] And consistently the publisher was saying, look, we’ve got this report from Moonpull that says you’re sending the traffic to two different URLs. And eventually it got escalated within the advertiser correctly, and the fix was implemented very quickly. And so that’s an illustration of how publishers are getting a bit more determined to look into tracking matters and have the conversation with the advertiser and the clout they have if they’re right.

[00:29:02] JF: I 100 percent agree. I think you could boil this down. Just some takeaways from that simply put our channels always been built, the base, the foundation of our channel is a partnership channel that runs on a commission level or CPA basis where it’s performance were known as a performance channel.

[00:29:20] So these brands come in. They want to work with these top publishers. They have a list of folks that they might want to work with and who they want to recruit and partner with so that those publishers can then promote them. Those publishers are putting a lot of skin in the game by promoting to their audience when they only get paid out if a conversion happens.

[00:29:38] And so if tracking is not implemented correctly, that publisher is not getting the payments that they’re due. And by all means, they should be upset about that. And I think what to pull from that is for brands, merchants, retailers, as they look at how to diversify and expand an affiliate program, one of the first things you should look at is whether or not you’re implementing tracking properly.

[00:30:01] And if there are issues or anything that’s brought to your attention, it should be addressed quickly. And I agree with you where I think advertisers have always felt they had the pull and so they may ignore that for some time and disregard that. But I think we’re coming to a place now where as an agency, we’ve seen this.

[00:30:19] Where publishers, if they don’t feel like conversion rates are where they need to be, or they’re not properly tracking the conversions that should be tracked, they’ll pull away and go to competitor B, C, or D. And brands have to realize that those publishers are hard to rope back in if you’ve broken that trust.

[00:30:36] You made an agreement to pay them for conversions that they’re driving, and if you are almost knowingly not tracking those properly because you refuse to implement updates, that’ll end up impacting your program pretty considerably.

[00:30:49] SB: Yeah, I think to defend many advertisers, I don’t think, I think it’s very rare that an advertiser is deliberately not paying out what they want. I think there may be challenges that they struggle to get the code updated. They may actually end up paying a fair amount, but it’s via a commission rate that’s higher than they would like, or they’re paying a tenancy associated with it.

[00:31:15] And that has the knock on effect that actually you may be paying the right amount of money, but you’re not measuring it properly. And so if you run a campaign and 50 sales result, but actually it should have been a hundred recorded if the tracking was reliable, you’ll have a different view on whether that campaign was successful.

[00:31:38] And I think that’s one of the reasons why it’s really important for everybody to care about getting tracking right.

[00:31:44] JF: And where do the networks play a role? When I bring this topic up in our circles, a lot of folks like to jump right to this is the network’s responsibility, which I think they have some responsibility in that regard. I don’t think it falls solely on the networks, but I’d like to hear your opinion on where they play a role and what they can do to help ensure that transition to the publisher to advertise your relations and tracking capabilities.

[00:32:10] SB: I think it’s a difficult one because yes, networks sit in the middle, but the example I use often is if you’re about to send 10,000 clicks to a specific deep link product, you have a responsibility to check that for yourself and not complain one day later that it didn’t track. So that immediately says there’s a shared responsibility for getting tracking to work.

[00:32:35] And publishers will see things that networks will never see in their data because, however hard a network delves into its statistical analysis, publishers will see things differently. So that publisher that sends 10,000 clicks, they’re looking on a product by product level basis of whether something’s tracking, which the network probably isn’t.

[00:32:58] They’ll be looking at brand new referrals, whereas a network be looking at referrals where the cookie may have been set one day, five days, ten days earlier. So publishers will naturally have a different data set to networks and the network ultimately is sitting there between the publisher and the advertiser.

[00:33:20] And then the publisher has the option whether or not to promote an advertiser. An advertiser has an option whether or not to show great love to specific publishers and therefore I think it’s really important the network sits in the middle and actually tries to encourage best practice. But, I think like any industry, if your supply chain isn’t as good as you like, then you probably vote with your feet and look for a different supply chain.

[00:33:48] But equally, you often look to improve your supply chain, so you can make sure your factory is running 24/7. And I think as a publisher, I would be looking to make sure I’ve got rid of all the friction in my supply chain, so that actually I know that if I do this, I’m going to get that. And so I think publishers do have a responsibility.

[00:34:12] I think agencies are the ones that absolutely also share that responsibility, and agencies often have a good line into the right people at the brand to, to get things fixed faster. So I really like to see agencies take more responsibility over tracking as well.

[00:34:32] JF: So again, it goes back to being a shared process and I don’t disagree with anything you just said. I think as an agency, I can vouch for probably many others that are in my shoes it can be very frustrating when you knowingly have a tracking issue with a merchant program that needs to be fixed and you struggle whether it’s on the advertiser side or the network side or whatever support you need to help do that, it can be quite frustrating.

[00:34:57] So I do agree that having that source that can go and play advocate for each side is important to make sure things get done.

[00:35:04] SB: I was going to say one thing that I think is really important is it’s not that one network is worse or better than the other. It’s not that one agency really is better or worse than the other. It’s, to a degree, it’s just bad luck whether an advertiser has inadvertently got a tracking problem or not.

[00:35:22] And therefore, if you view it as just bad luck and random, then there’s an opportunity for everyone to be a bit more honest, and have confidence about being a bit more honest, about when there’s an issue or not. And I definitely feel the networks are realizing that actually part of running a network is not having 100 percent of their clients tracking 100 percent reliably every moment.

[00:35:52] Yes, let’s talk about when there’s an issue. Let’s let publishers know when there’s an issue and publishers can dial down the promotions they’re doing with that advertiser and it takes some of the angst out of the issue and allows the advertiser to get on and fix it.

[00:36:09] JF: I noticed I think this past year AWIN launched CPI their conversion protection initiative and it’s top of mind because any of our clients on AWIN I think in April is when that goes into effect fully, but essentially what that does is they’re putting the pressure back on advertisers to ensure that they’re updated with the latest tracking that they check through that, confirm it, test it and that it’s properly working so that, again, it helps put some of that back onto this shared responsibility idea where the networks have the power to say, hey, as an advertiser, if your program, you want it to run successfully, here’s this new initiative.

[00:36:46] Here’s how it operates. It accounts for, a potential loss and track sales. So the publisher gets their fair credit and you have to make sure you’re implementing the proper tracking guidance that we give you so that your program operates as it should. Do you feel like that’s a step in the right direction from a network perspective?

[00:37:03] SB: I do. I think it’s a very honest thing because what will happen is the publisher will get an additional line in their interface saying you’ve got an extra $100 this month and even if they don’t know the maths behind it, they can say I’ve got an extra $100 compared to the $300 I already received.

[00:37:26] That’s AWIN’s estimate of what’s going wrong with the tracking, cJ also, certainly for their larger clients, have very much looked at things on a one by one basis as well. There are, within the industry, those, AWIN’s CPIs is a much more open calculation. But I think it’s the right thing to do to look at encouraging advertisers to have the right tracking.

[00:37:54] Because ultimately, most large publishers need reporting back to the click and by making a payment that is a lump sum, it still doesn’t allow a cashback site to operate very efficiently. If you’re a CSS partner, you need to know which clicks are driving the sales. So encouraging any tracking that comes back to the click and allows the click ID to be present, I think is very important.

[00:38:24] JF: Agreed. I think it’s refreshing to see the collaboration picking up. I feel like you have facilitated much of that from what I’ve seen. There’s anytime I look up anything regarding tracking errors, consent platforms, Moonpull seems to be kind of on the forefront with conversations and public educational pieces, webinars, sit downs at shows when they have keynotes, you guys are diving head in.

[00:38:47] I love seeing the collaboration build. I think more publishers, brands, agencies, networks are taking notice to this and realizing that, as we move forward as an industry to continue growing as an industry, this has to be tackled and paid attention to.

[00:39:02] SB: Yeah, and I think that’s right. And I’m pleased you’re seeing that. I’m delighted that we’re viewed that way. And it goes back to the name of Moonpull as a business, which is the pull of the moon, a rising tide floats all boats. And I am a great believer in the strength of the affiliate channel that, during Affiliate Summit recently I received what an email newsletter from the programmatic paid search industry.

[00:39:30] And it was all doom and gloom about their industries and what’s happening with cookie deprecation and the ability to track and personal information. And affiliate does have a really strong strength, which it has a first party solution that has been operated for over a decade. It needs to be implemented reliably, and yes, consent laws are inhibiting it, but it’s a damn good first party solution, and I think most other channels, most other models would love to actually have a first party solution that just needs to be implemented well.

[00:40:08] JF: I agree, and I think the buzz at ASW, while there is more consideration and concern to issues like this there has been no lack of optimism around how we tackle it as an industry. And again, I think one things I love about our affiliate channel industry, the folks who operate within the affiliate landscape, it’s almost painfully optimistic and collaborative.

[00:40:29] So when these issues arise and they truly start to have an impact on, programs, revenue, publishers, perception, everybody comes together and figures out what is the problem? How do we innovate? How do we move things forward?

[00:40:41] Sometimes maybe slower than others would like, but it happens and it creates this atmosphere where in five years from now it might be a passing concern that is no longer an issue and is figured out, which I think it’s great in our industry.

[00:40:55] SB: Yeah, and I would echo that. I mean, one thing that we’ve had to do at Moonpull is think about the language that we talk about tracking, and we’ve realized that for someone who uses affiliate marketing to appraise whether the tracking is operating or not is actually very simple. It almost boils down to the question of is the memory cookie present or not, which is not a hard question to answer.

[00:41:20] And Moonpull makes it very easy for someone to answer that question. The harder thing is if you’re working at a multinational advertiser and your responsibility is to keep a website with millions of customers going 24/7 with lots of different channels thinking about your load balancing making sure the master tag there is there every time.

[00:41:44] That’s difficult, but we’re not asking affiliate marketers to implement the code. We’re after them spotting if it’s not right, Moonpull gives some clues as to why it’s not right. And often, if you take the Moonpull clues like the master tag is there on this page, but not this page, a developer goes that was a bit stupid of me, wasn’t it?

[00:42:07] But if you go to a developer and say, I think the tracking is not working, asking anyone to find a needle in a haystack is going to challenge them. So, everyone having a few steps forward, but not being an internationally reliant developer. I think will greatly move the industry forward.

[00:42:26] And David Lloyd from AWIN said, his view is that every publisher, advertiser, and agency should have someone who understands tracking in it. And I think that’s absolutely true because that will allow higher quality conversations to develop issues to be spotted more quickly and things nipped in the bud.

[00:42:48] JF: I agree. I’m excited to see what Moonpull is doing and how that’s helped shaping the conversation. And we always want to be a part of that. Any final thoughts from you or as folks are listening, if they’re interested in what Moonpull is doing and how they’re moving the ball forward when it comes to identifying possible tracking breakdowns for publishers, agencies, advertisers, how would they go about, looking at Moonpull, getting a hold of you or your team, what would be the best way for them to do that?

[00:43:13] SB: Google the word Moonpull. We chose a brand that was good for SEO for the word off. So Google Moonpull, you’ll find our website. You’ll find our contact form. We’re on LinkedIn. I’m Steven Brown, steven.brown@MoonpullPartners.com. Find us at any way and we’re delighted to talk to people. Our blog’s got great content on it as well about tracking and how to make tracking reliable how to think about consent platforms, etc.

[00:43:40] So please do visit our blog as well.

[00:43:43] JF: I can second that, I’ve read many articles on your blog and is a go-to when a tracking error occurs. Yeah, Steven, I want to thank you again for joining us for an episode. I appreciate the conversation and look forward to seeing you again at the next event.

[00:43:57] SB: Very much so I’ve enjoyed the conversation too. Thank you.