A caveat made to Gmail’s ad system is only small, but could raise questions around how investors’ data is stored and used by funds.
TL;DR: explain how you collect LP data.
On October 16, an updated privacy policy at Google took effect, changing the wording of a promise that it had made for years: that the content of a user’s Gmail inbox is not used to personalise ads.
While the policy still says it does not personalise ads based on Gmail, Drive or Photos content, it adds the condition that this holds “unless you choose to make data from these services available to other Google services that support personalized ads.”
This small change is tied to Google’s “Personal Intelligence” features that connect data across many of its services, including those listed above. The company has also stated that ads will not be based directly on a user’s inbox despite AI tools connecting these services, and that advertisers do not get access to content.
Protections around sensitive categories also remain – including health, religion and race – while users can opt-out by switching off “Smart feature in other Google products” in their Gmail settings.
This is purely about Gmail’s ad system, and does not change how it filters or delivers your email. The practical effect of this rule shift is also dependent on the number of people that opt-out (which nobody outside Google can currently measure!).
So, what does this mean for fund marketers?
With Gmail a popular choice of ESP, and email a favoured form of content distribution, any fineprint edits can affect a fund’s email marketing management, as follows.
Expect privacy questions from allocators
Institutional clients will be sensitive to any headline suggesting “Google reads your inbox”. Whether or not it is accurate, recipients may well tighten their settings. This means funds should clearly explain what data they collect, and why, in their own privacy notices and email footers.
Build strategies on first-party data
Inbox-level signals that you cannot control are not the surest forms of engagement or investor intent. Opens and clicks are directional, secondary in importance compared to event registrations, form fills, meeting requests and direct messages with IRs.
Review what your email contains
Like most compliance rules for sending sensitive materials like performance letters, consider hosting this information in a secure portal and linking to it, rather than including it in the main body of emails.
Brief compliance
Check and double-check that your existing disclosures and LP-facing language still reads accurately in light of Google’s change.
Source
Forbes, “Google Changed Gmail On October 16—Check Your Account Now”
TechPP, “How to Stop Google From Using Your Gmail, Drive, and Photos Data for Personalized Ads”
