This topic explains the concept of Concept or Pay and how publishers can honor end-user consent preferences by giving them a free opt-out option to limit data tracking.
What is Consent or Pay?
“Consent or Pay" is a concept where users are given a choice to either provide consent for data collection or pay to access content without consenting to data tracking or advertising. The three main options are:
- Consent: This is the option for users to allow the collection, processing, and sharing of their personal data in exchange for free access to a website or service. CMPs typically collect and store users' consent choices for compliance with privacy regulations, such as GDPR or CCPA. By providing consent, users allow consent for different data processing purposes as selected by the publisher on their and their vendor’s behalf.
- Pay: This option is an alternative for users who prefer to completely opt out of any data processing. Instead of consenting to data collection, users can choose to pay a fee for an ad-free experience or access to premium content without any data tracking. This allows users more control over their privacy.
- Free Partial Accept: The European Data Protection Board (EDPB) has released an opinion citing that publishers must provide a “Free alternative to opt-out of personalized advertising”. Under this, InMobi CMP enables a Free partial accept option which allows end-users to opt out of personalized ads if they so choose. This way, InMobi’s solution remains compliant with EDPB's opinion on this topic.
Developments so far
In November 2023, Meta introduced a paid subscription for Instagram and Facebook users who don't want to be tracked. This was referred to as the 'Pay or okay' model.
In response to this, the European Data Protection Board (EDPB) has published an opinion stating the following:
“In most cases, it will not be possible for large online platforms to confront users only with a binary choice”.
A free alternative should be given without behavioral advertising, e.g. involving the processing of less or no personal data.
The scope of this opinion is for “large online platforms“ (evaluated on a case-by-case basis).
Consent or Pay 2.0
Consent or Pay 2.0 emerged after the EDPB's guidance to offer users a free opt-out of personalized ads.
Consent or Pay 2.0 Checklist
- Partial Accept is mandatory (Reject all will be behind pay-wall). Users will be able to opt out of personalised ads. This is the main differentiator from the 1.0 version of Consent or Pay which only had a binary choice.
- At least one non-personalized purpose should be available to empower users to opt out of personalized ads. This is also a check maintained by InMobi CMP on behalf of publishers.
- Multiple implementation options for publishers:
- Option 1: Publishers can use CMP’s consent call-backs to re-direct the user themselves based on the consent state (Accept All, Reject All, etc).
- Option 2: Publishers can simply provide the re-direction URLs (web) in the CMP which does the re-direction
- Balance publisher control vs. standardization for button copy (button labels), consent screen text, and language translations.
- Provide publishers control to implement consent or pay in only certain countries but not in other countries.
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