Contextual-only advertising program

Description

Contextual-only advertising is the strategy of selecting which ad to show based on what the user is looking at (page content, query keyword, channel) rather than based on who the regulator-protected algorithm has decided the user is. The strategy exists because the family of statutes regulating ads to minors and ads using sensitive-category profiling has converged on the same operational answer: if profile-based targeting is forbidden for a segment, contextual targeting is the residual mode that still works. DSA Article 28 forbids profile-based ads to users a platform has reasonable certainty are minors. The UK AADC Standard 13 defaults profiling off for likely-children. California's AADC §1798.99.31(a)(4) defaults profiling off for children, which closes off the behavioral-ad path by construction. KOSA layers an additional federal restriction on profile-driven ads to minors. A working contextual-only program has three operational pieces. The first is the policy document that names which user segments are profile-ad-excluded and which ad surfaces serve them; the line that catches operators is not the policy itself but the second piece, which is the ad-serving configuration that actually enforces the rule. Most ad networks have a flag for contextual-only mode, but the flag has to be set at the integration layer for the specific segment, and the integration layer is usually a Google Ad Manager configuration or a custom DSP relationship that is owned by a different team than the one drafting the policy. The third piece is the per-impression audit log showing which mode actually fired for which segment, which regulators have begun asking for in lieu of policy-only attestations. The vendor landscape has matured around this constraint. Contextual ad platforms (GumGum, Seedtag, and a growing list of cookieless / no-profile networks) ship targeting based on page-content analysis and computer-vision classification, which means a product can hand off the entire compliance surface to a vendor whose business model already aligns with profile-ad restrictions. The trade-off is yield: contextual ads typically monetize below behavioral ads, and the gap is the price of the safer compliance posture for the affected segments.

Required by (3 regulations)

• DSA

  Article 28 — online platforms accessible to minors must not present profile-based advertising using personal data of users they know with reasonable certainty to be minors.

  DSA Art. 28

• UK AADC

  Standard 13 (Profiling) — profiling off by default for likely-to-be-children users; behavioral-ad profiling specifically called out.

  ICO AADC Standard 13

• CA AADC

  §1798.99.31(a)(4) — businesses may not profile a child by default; default-off profiling necessarily disables behavioral ads to children.

  Cal. Civ. Code §1798.99.31(a)(4)

Fulfilled by (3)

• gumgum · full · medium effort · $$
  Contextual ad platform — computer-vision-based page-content targeting, no user-profile dependency.
• seedtag · full · medium effort · $$
  Contextual ad network — AI-driven content matching; explicit cookieless / no-profile offering.
• In-house build · high effort
  Configure ad-serving integrations (e.g. Google Ad Manager, custom DSP relationships) to disable profile-based targeting for minor / sensitive segments; audit per impression.

Magist does not accept payment from vendors. Methodology.

Evidence formats

• contextual-ad policy doc
• ad-serving configuration screenshot / config-export
• per-impression audit log (segment → mode)
• minor / sensitive-segment exclusion-list