concerning their use of Google’s advertising services, including price, remuneration, fee and
performance metrics. Google provided (and continues to provide) these reports through
various routes, including (i) user interfaces (
UIs
), (ii) DTFs, (iii) application programming interfaces
(
APIs
), and (iv) Google’s Ads Data Hub.
136
(a)
For advertisers, pre-existing reporting options are available in (i) Google Ads, (ii) DV360,
(iii) CM360, and (iv) SA360. These reports cover a variety of performance and
verification metrics (such as number of Clicks, number of Impressions, Click-Through
Rate,
etc
.) as well as pricing data across various metrics.
(b)
For publishers, pre-existing reporting options are available in (i) GAM, (ii) AdSense, and
(iii) AdMob. These reports provide performance data that can be filtered by various
metrics (such as Impressions, Revenue, Clicks
etc
.) and dimensions (such as Ad Unit,
Device Type, Country
etc
.). Pricing/fee data is also reported to publishers using metrics
appropriate to each product.
26.
To comply with Art. 5(9), Google provides an additional fee transparency solution for advertisers
which builds upon Google’s pre-existing extensive reporting tools.
Through this fee
transparency solution, Google discloses to advertisers using its advertising products, for billable
advertisements, the price and any fees paid by the advertiser (
one-sided transparency
), the
remuneration received by the publisher including any deductions and surcharges where the
relevant publisher is using Google’s advertising products (subject to certain conditions being
met, described further below, including publisher consent) (
two-sided transparency
), and the
measure on which these prices, fees, and remunerations were calculated.
Billable
advertisements
are events that customers are billed for that occur in relation to an
advertisement, such as a click, view, impression or conversion.
27.
Advertisers are presented with an option to request a file containing daily data from Google Ads,
DV360, and CM360. These files are updated on a daily basis. For SA360, where pricing involves
a flat rate that does not change between events, customers already receive full transparency
into their fees (which was available prior to the DMA). Google Analytics accounts are provided
free of charge, and so Art. 5(9) fee disclosures are not applicable. For Google Analytics 360, the
relevant fee does not change “per event”; as with SA360, customers already received fee
transparency prior to the DMA.
28.
The daily files include the following fields for billable advertisements:
(a)
A unique event ID,
(b)
The amount paid by the advertiser to Google and the measure for this payment, and
(c)
For ads displayed on third-party properties:
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See
Section X.B.1 in the Google Ads Chapter of Google’s first Compliance Report for further
information on each of these methods of reporting, as well as further detail on the pre-existing
reporting options available to advertisers and publishers using Google’s advertising services.
EU DMA Compliance Report - 91
