Newsletter - Match Rate, Issue #5: "Neutral," in writing, and opt-out season

Identity, data and measurement from someone who runs it.

Two things happened this week that change who you're trusting with your data. The FTC told Publicis exactly what it must do to keep LiveRamp open to everyone else. And three platforms decided, on your behalf, that their AI can change your ads and count your conversions unless you say no. The first deadlines are this week.

The two that matter

1. The FTC writes down what "neutral" has to mean for LiveRamp

What happened

On Oct 19, the FTC voted 2-0 to accept a proposed consent order that lets Publicis complete its $2.2 billion purchase of LiveRamp. The order lasts five years from closing and requires Publicis and LiveRamp to:

• Give all customers non-discriminatory access to LiveRamp's standalone products, on fair and reasonable terms, and not deny, degrade or delay that access.
• Keep firewalls so Publicis can't access or use LiveRamp customer data or confidential business information.
• Not retaliate against customers who raise compliance concerns with the FTC.

An independent auditor will check compliance every six months for the first two years after closing, then once a year for three years. Customers can request an audit of how Publicis meets the data protection, privacy and security obligations that apply to them. Contract disputes not resolved within 30 days go to outside mediation.

The FTC's complaint explains why. Without conditions, it says, Publicis could steer customers of rival agencies toward Publicis, degrade LiveRamp services those rivals depend on, or see competitively sensitive data about clients it doesn't serve.

The order is open for public comment for 30 days and isn't final until then. No closing date has been announced. Publicis says LiveRamp will keep an "open ecosystem connected to third-party agencies and platforms."

The market hasn't waited. Omnicom moved its exit from LiveRamp forward and is reportedly building its own identity product through Acxiom. Campaign and Marketing Dive report that WPP is winding down its agencies' use of LiveRamp.

What it changes

For years, "neutral" was something identity and data companies said about themselves. This order is the first time a regulator has defined it in operational terms for a provider owned by a media buyer: equal access, separated data, outside audits, and a way to complain without being punished. That's useful well beyond LiveRamp. You can ask any data or identity partner with a media parent the same questions.

The order also has limits. It protects access to LiveRamp's products. It doesn't make Publicis's rivals want to keep using them, and two of its biggest rivals have already decided not to. If your agency is Omnicom or WPP, your RampID-based audiences, onboarding and measurement are going to move somewhere, and the switch is happening now, not after the deal closes.

There is a fair case on LiveRamp's side. The order binds Publicis in writing, with audits, which is more than most data companies offer their customers. LiveRamp's draft letter to customers says it won't let anyone, including Publicis, use customer confidential information without explicit permission. Whether that's enough is a judgment each buyer will make differently.

The Semcasting view (my company's perspective): Semcasting is an independent audience data company with no agency or media parent, so we benefit when buyers care about this. Ask us the same questions you'd ask anyone else.

What to do this week

1. If your agency is Omnicom or WPP, ask in writing what replaces LiveRamp in your setup, on what date, and how match rates and measurement will be compared before and after.
2. If you work with LiveRamp directly, read the order's audit provision. You can request an audit of the data protection obligations that apply to you. Decide whether you want to.
3. For any identity or data partner with a media parent, ask the order's questions: Is access equal across platforms? Who can see our data and campaign information? Who checks?
4. If you have a view on the order, the FTC comment period is open for 30 days from Oct 19.

Sources: FTC, Oct 19 · Marketing Dive, Oct 20 · PPC Land, Oct 21 · MediaPost · Campaign on WPP

2. Opt-out season: platforms switch on AI ad changes by default

What happened

Three changes, all on unless you turn them off:

• ChatGPT ads, from Oct 29 or 30. OpenAI will turn on "creative enhancements" for new and existing campaigns. It can rewrite headlines and descriptions, translate them, resize images, and send clicks to a different page on your site. Variations can be generated in real time based on the conversation the ad appears in, and they serve without human approval. OpenAI's email to advertisers says Oct 30; its help page has said Oct 29. You can opt out in Ads Manager under "Manage settings," and existing opt-outs are kept.
• Meta product browsing, from Oct 28. Meta said it would turn on product browsing in existing Facebook and Instagram ads on Oct 28 unless advertisers opt out. It cites an average 3% conversion gain from its own test.
• Meta Pixel, from Nov 12. According to reports, Meta has told advertisers that a Pixel setting called "Measure conversions on customer devices" is already switched on and will start measuring Nov 12. It matches some website purchases on the customer's device using the email the customer gave the business. Reported limits: no EU or UK users, the Pixel must be directly on the page, and the site must require an email or phone login. You can turn it off per dataset in Events Manager. Meta hasn't said whether the extra conversions feed bidding, or how consent is handled.

Behind all three is a contract change. Meta's revised Commercial Terms add an "AI Features" section that, according to Adweek, makes advertisers "solely responsible" for changes Meta's AI makes to their ads. Meta told Reuters on Oct 23 that it is moving the terms' effective date from Oct 30 to Nov 20. It has dropped the sentence about using crawled content for AI training, but the right to crawl advertisers' sites remains.

What it changes

The default used to be that an ad ran as approved. Now the default is that the platform can change it, and in Meta's terms, the risk stays with you.

For most retail advertisers, that may be a reasonable trade for better performance. For healthcare, pharma and financial services, it's a compliance problem. Headlines, claims and landing pages in those categories are reviewed for a reason, and a rewritten headline or a different landing page is a different ad.

It also affects measurement. If the platform changes the destination URL, landing-page conversion rates and UTM-based attribution change with it. And if Meta starts counting more conversions on Nov 12, your Meta-reported results will rise on that date for reasons unrelated to your campaigns. A jump that coincides with a measurement change shouldn't be read as performance.

What to do this week

1. Now: decide on ChatGPT creative enhancements. If you're in a regulated category or haven't reviewed it, opt out at the account level and turn it back on campaign by campaign if you want it.
2. Check whether Meta product browsing is now on in your existing campaigns, and decide whether to keep it.
3. Before Nov 12, record your Meta-reported conversions and your own order or lead counts for the same period, so you can tell how much of any change comes from the new measurement.
4. Have legal read Meta's AI Features section before Nov 20.

Sources: OpenAI Help: Creative enhancements · Search Engine Land · PPC Land on the ChatGPT dates, Oct 21 · PPC Land on Meta's terms and product browsing, Oct 22 · PPC Land on the Nov 20 delay, Oct 23 · PPC Land on the Meta Pixel, Oct 27

Quick hits

iOS 27.2 is out. The Trade Desk fix is expected, not confirmed. Apple released iOS 27.2 on Oct 26. The 27.2 betas removed The Trade Desk's ad domain from Safari's blocklist, but neither Apple's release notes nor WebKit's Safari 27.2 post mentions the blocklist, so treat the fix as likely until someone confirms it. Nothing has changed for the identity vendors Apple described in its Oct 19 post, including UID2, LiveRamp, ID5, Permutive and Audigent. Adoption will take weeks, so keep reporting Safari separately. MacRumors · PPC Land

Netflix wants your conversion data. On Oct 20, Netflix launched the Netflix Pixel and upgraded its Conversion API to take more than 20 standard lower-funnel events, for lift studies, attribution, A/B tests and building audiences. The Trade Desk audiences arrive on Netflix in November. The same day, Netflix cut its 2026 ad revenue target from $3 billion to $2.7 billion. Before you send conversions, decide which events Netflix needs and whether it can use them to build audiences. Netflix · AdExchanger

Google is moving all customer-file uploads into one pipe. The new DV360 API v5 beta, released Oct 22, removes the ability to create and update Customer Match lists through the DV360 API. Google points developers to its Data Manager API, the same system that, per last week's issue, will stop requiring hashed data on Nov 16. No v4 shutdown date yet. If you have a custom DV360 onboarding integration, plan to rebuild it. Google Ads Developer Blog · PPC Land

EU governments agree on cookie exemptions for measurement. After the Oct 11 stall, EU ambassadors agreed the Council's Digital Omnibus position on Oct 21. It would let sites skip consent for six purposes, including first-party and media audience measurement and measuring contextual ads (no profiling, pseudonymised data, no reuse). Sites would wait four months before asking again after a refusal. It isn't law: Parliament hasn't set its position, and member states would have 24 months to apply the cookie rules. IAPP · PPC Land

LinkedIn's B2B targeting comes to CTV. Since Oct 22, advertisers can target CTV in DV360 by LinkedIn job title, industry, company size and company. LinkedIn hasn't said how a profile is matched to a streaming household. AdExchanger

The explainer: opt-out season

Platforms are switching on features by default this fall. Here is what's on, from when, and where to turn it off.

Three rules of thumb:

1. Decide at the account level first. Turn a feature off by default, then turn it on campaign by campaign where you've reviewed it. The reverse is harder to audit.
2. Record a baseline before any measurement change. Write down platform-reported conversions and your own counts for the weeks before a change. Otherwise you can't tell a measurement change from a performance change.
3. Regulated categories review everything that touches claims or landing pages. If a feature can change either, it goes through the same review as a new ad.

A question worth asking this week

"Our agency is moving off LiveRamp. What happens to our audiences and our measurement?"

Start with an inventory. List every place RampID touches your setup: CRM onboarding, audiences in each DSP, clean room work, and measurement or attribution that matches exposure to outcomes. Each one needs a replacement, and they may not all move to the same place.

Then ask about continuity. A new identity provider will match your file differently, so match rates, audience sizes and measured results will shift. Run old and new side by side for at least one campaign cycle if you can, so you know which changes came from the switch.

Finally, ask who owns what. If your agency builds its own identity product, find out whether your audiences and match data are portable if you change agencies later.

My bias: Semcasting is one of the companies you might move to. The questions apply to us too.

That's Issue #5. If your agency has already told you what replaces LiveRamp, send me a message on LinkedIn. I'd like to know how much notice you got.

If this was useful, subscribe to the blog to get the next issue by email.

Geetha

Match Rate is written by Geetha Neelakantiah, SVP Business Development, Marketing & Operations at Semcasting. The views are my own. Sections labeled "The Semcasting view" or "My bias" reflect my company's perspective. Nothing here is legal advice.