When does targeting apply?
In Step 1 of the wizard, you are asked whether your advertisement used personal data to select who sees it. If you answer "yes", the Targeting Details step (Step 2) appears in your wizard.
"Targeting" in this context means any use of personal data to determine which individuals or groups are shown the advertisement. This includes:
- Selecting an audience on a social media platform based on age, location, interests, or behaviour.
- Using a mailing list to send campaign emails to specific people.
- Running programmatic ads that use cookies or device identifiers to select viewers.
- Using voter file data to target specific households or demographics.
If your ad is a print poster on a public billboard, a newspaper ad visible to all readers, or a flyer distributed without any data-driven selection, you typically answer "no" and the targeting step is skipped entirely.
Step 2: Targeting details
When targeting applies, the wizard asks you to describe two things in free-text fields.
Analytical techniques
This field asks you to describe the analytical techniques used to select your audience. Art. 9(1)(e) PAR requires this disclosure. Write in plain language so that a layperson can understand what you did.
Examples of what to describe:
- "Interest-based targeting on Meta Ads Manager: selected users who have expressed interest in climate policy and renewable energy."
- "Geolocation targeting on Google Ads: limited display to users located in the state of Bavaria."
- "Lookalike audience on Meta: created an audience similar to existing newsletter subscribers."
- "Demographic targeting on a programmatic ad platform: selected adults aged 25-55 in urban areas."
You do not need to describe the platform's internal algorithms in technical detail. Focus on what criteria you chose and what tools you used.
Goals, mechanisms, and logic
This field asks you to explain the goals, mechanisms, and logic behind your targeting approach. Why did you target this way? What were you trying to achieve? How does the targeting mechanism work at a high level?
Examples:
- "Goal: reach voters in the constituency of Munich North who are likely interested in local transport policy. Mechanism: Meta's interest targeting selects users based on page likes and engagement with transport-related content. Logic: we want to ensure our policy proposals reach the voters they are most relevant to."
- "Goal: inform party members about the upcoming general assembly. Mechanism: email sent to our membership list. Logic: only members need this information, so we use our existing database rather than public advertising."
The key requirement is that your description must be understandable by a layperson. Avoid jargon and technical shorthand. If a citizen reads your transparency notice, they should be able to understand why they were shown this ad and how the selection worked.
The methodology description (Step 6)
Separate from the targeting details, Step 6 of the wizard asks for a plain-language methodology description under Art. 9(1)(h) PAR. This field appears for all notices, not only those with targeting.
The methodology description covers how the costs and financial arrangements of the advertisement were calculated. While this is not about targeting per se, it is related: the methodology should explain the financial logic behind the ad placement.
The wizard can auto-generate a starting point for this field based on your cost line data. For example, if you entered cost lines with 19% VAT and a benefit in kind, the wizard might suggest: "All amounts are stated inclusive of VAT. VAT rate: 19%. The difference between the market value and the price actually paid constitutes a benefit in kind."
You can accept this pre-fill and edit it, or write your own methodology description from scratch. The description should be clear enough that a regulator or citizen can understand how you arrived at the stated costs.
Common questions
What if I use a platform's built-in audience tools?
If you select audience criteria on a platform like Meta, Google, or a programmatic ad network, that counts as targeting with personal data. Describe the criteria you selected and the platform you used.
What if the platform does the targeting without my input?
If a platform optimises delivery automatically (for example, showing your ad to users most likely to engage), but you did not select any audience criteria yourself, the answer depends on whether personal data was used in that optimisation. In most cases with modern ad platforms, the answer is yes. When in doubt, answer "yes" and disclose what you know about the platform's optimisation.
What if I only target by geography?
Geographic targeting (for example, showing an ad only in a specific city or region) uses location data, which is personal data. If you used geotargeting on a digital platform, answer "yes" to the targeting question.
Do I need to list every data category?
The regulation asks for the targeting criteria and methods, not an exhaustive list of every data point. Describe the categories you selected (age, location, interests) rather than individual data fields. If you used AI-based optimisation, mention that explicitly.
What about AI and automated decision-making?
If your targeting uses artificial intelligence, machine learning, or automated decision-making, mention this in the "goals, mechanisms, and logic" field. You do not need to explain the algorithm in technical detail, but you should disclose that AI was involved and describe its role at a high level. For example: "Ad delivery is optimised by Meta's machine learning algorithm, which selects users predicted to be most likely to engage based on their past behaviour on the platform."
Writing for clarity
The overarching principle for both the targeting details and the methodology description is plain language. The regulation explicitly requires that these explanations be understandable by citizens who are not experts in advertising technology or data protection law.
A good test: read your description to someone who does not work in marketing or politics. If they can understand what you did, why, and how, your description meets the standard.