Facebook’s response to CCPA, Limited Data Use (LDU), was late and continues to be confusing and challenging for advertisers. You might not even know if your Facebook marketing is CCPA compliant right now. And, if your Facebook results in July looked wonky, Limited Data Use might be to blame.
To recap, for all of July, Facebook suddenly and automatically enabled  Limited Data Use in advertisers’ accounts. That effectively flagged all users in California as having submitted “Do not sell my information” requests via your website, limiting your ability to market to them or measure the actions they took from your ads.
“Which is quite damning,” said Simon Poulton, VP of digital intelligence at Wpromote on our Live with Search Engine Land discussion on LDU  . “It’s quite honestly the greatest amount of overreach I think I’ve ever seen from a platform in terms of what they’re doing — actively hurting themselves in terms of revenue — but really what’s happening is a lot of advertisers are seeing a huge dip because of this. They essentially killed off all remarketing within California.”
Further, Poulton notes, LDU eliminates the passback signal, “so you’re losing the signal at the point of conversion, so even if you can market to people in California in terms of prospecting, the signals you get back will be next to zero conversions.”
If you’re not sure if CCPA applies to your business, read this first  . If it doesn’t, you don’t have to worry about LDU. If it does, keep reading.
LDU transition period confusion: Check your settings
The default setting for LDU in Events Manager is currently still “Keep transition period.” But, that is still the initial transition period that ended July 31 — yes, more than a month ago!
It’s essentially the same thing as checking “end transition period now,” meaning, if you’ve taken no action to implement the LDU flag on your site and have that checked, your Facebook marketing is currently not CCPA compliant. You’ll need to check the option to extend the transition period to October 20 and then get to work implementing the flag.
Where should you implement the LDU flag on your site?
If you implement Facebook’s limited data use flag on every single page within the Pixel by default, that’s no different than having the “extend transition period” toggle on in Events Manager.
What you need to do is enable that LDU flag only when a user has taken action on the Do Not Sell My Information banner on your website, says Poulton. But, that gets complicated. What does an opt-out look like?
Say a user opts-out from your site. That’s a value you want to store in the cookie so you can be persistent across sites, explains Poulton.
“The challenge here comes when a user also disables cookies. It means I can’t store that value. There is a way to do this by storing the LDU flag in localStorage and persist that with the user,” Poulton says, “that’s kind of a sacred place for on-site functions more than anything, which I think this is in the spirit of CCPA.”
The problem? “That’s incredibly technically complicated. We have some really smart developers working on this and they’ve found that complicated with clients,” says Poulton.
“A happy middle ground.” Poulton suggests (with the caveat that he is not a lawyer) that a “happy middle ground is just to simply enable LDU to fire whenever someone opts-into ‘Do not sell my information’.”
“It’s slightly overkill but it is a great way to do it and persist that value for individuals. You really do want to make sure you can respect the user’s choice.”
Another suggestion: store the IP address in a hidden field when a user opts out on your site for consistent treatment. LDU does this as well.
Facebook has also updated the Facebook Pixel Helper Chrome extension  to show when and what data processing options are sent, Poulton noted on Twitter Thursday.
How should advertisers deal with California now?
“We’ve been breaking California out into separate campaigns,” says Akvile DeFazio of social media advertising agency AKvertise. “We find it easier to get better visibility, ease of management and optimization to see what’s really happening with these new campaigns since all these changes are very new…. That way it’s not going to impact your campaigns as a whole and maybe cause performance to go down.”
In her polling of other Facebook marketers, DeFazio found about 60% said they are also breaking out California into separate campaigns.
Engagements with ads and posts. DeFazio pointed out a workaround that might still work for pixel-based retargeting audiences if you’ve got LDU enabled.
“We’ve noticed that if we just target California and people that have previously engaged with a Facebook or Instagram ad or post, we’re still seeing performance in those audiences because clicks are technically considered a form of engagement, so chances are you’ll still hit maybe a large percentage of people that engaged with prior ads or posts and you can retarget to them,” she said.
DeFazio is also continuing to build lookalike audiences based on those engagement lists. “They’re still performing to an extent, not as powerfully as they were at the end of 2019, but it’s something in the interim as we continue strategizing with clients.”
“If you want to create other custom audiences, one thing we’ve seen work well in the past in other scenarios is creating dummy UTMs and append that to your ads,” added DeFazio. “So we’ll know who we’re targeting in particular ad sets. Anyone who clicks that ad, we’ll use that dummy UTM to create a lookalike audience that can be used to reach California users — who haven’t opted-out, of course.”
Low opt-out rates. Because CCPA is opt out — as opposed to GDPR’s opt-in — DeFazio expects that friction will lessen the impact for marketers. For context, Poulton noted a nationwide client that had roughly 2 million sessions in June and saw 800 people opt out.
You can still glean California performance insights by looking at your analytics, your CRM and/or your orders data.
“There’s still reason to market in California,” says Poulton. “Just because you can’t report on them doesn’t actually mean that you’re not converting and engaging them.”
- ^ suddenly and automatically enabled (searchengineland.com)
- ^ Live with Search Engine Land discussion on LDU (searchengineland.com)
- ^ if CCPA applies to your business, read this first (martechtoday.com)
- ^ extension (business.facebook.com)
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