Paid Programming: Investigating streaming ads during the election season

Paid Programming: Investigating streaming ads during the election season


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Hulu is an American subscription- and ad-supported video streaming service that is majority-owned by Disney. The service operates in the U.S. and will be rolling out internationally. Hulu had 35.5 million paid subscribers as of August 2020.


Overall grade


Our analysis

When it comes to political advertising and preventing abuse, Hulu is making some progress. However, questions about how policies are enforced remain and there are no ad transparency tools available.

Political Ads


Partial grade: B

Hulu seems to have some basic safeguards in place. However, Hulu doesn't seem to require ad disclosures, nor does it have an ad transparency library.

Does it allow political ads?

What are its rules for placing political ads?
Hulu has policies that limit the type of targeting tactics political advertisers can use. Political advertisers can't target individual viewers, nor can they use some of the more complex targeting tools Hulu offers, such as lookalike audience segments. Further, political ads can't be placed through Hulu's self-service Ad Manager platform, which is in beta.

Do political advertisers need to verify their identity in order to place ads?

Does it clearly mark political ads?

Does it require a "paid for" disclosure for political ads?

Does it fact-check or otherwise vet political ads?
Somewhat. Hulu requires political ad buyers to provide sources supporting the claims they make in their ads. However, it's unclear how thoroughly Hulu fact-checks such ads before they run.

Ad Transparency


Partial grade: F

Hulu provides no transparency tools to support monitoring or analysis. An ad library with complete, real-time data is critical to researchers ensuring the integrity of the platform.

Does it voluntarily report ad spend?

Does it have a public ad transparency library? (See our guidelines)

Does that library include ALL ads, not just political ads?

Ad Targeting


Partial grade: B

Hulu does have rules preventing micro-targeting, but its definition of political ads may not include other kinds of issue-based ads.

Does the platform allow political advertisers to target you based on:

(e.g. contextual ads)

Yes. Political advertisers can target by age range and gender.

Yes. Political advertisers can target specific states, zip codes, and media markets. They can also geo-target customers.

Interests & Behaviors (e.g. TV viewing data)
No, but non-political advertisers can use this targeting tactic.

Custom audiences (e.g. advertiser uploads 1st party data)
No, but non-political advertisers can use this targeting tactic.

Audience/Customer Matching (e.g. platform matches 3rd party data to existing customers)
No, but non-political advertisers can use this targeting tactic using third party data from data brokers such as LiveRamp (formerly Acxiom).

Lookalike/Similar audiences (e.g. platform finds new, "similar" audience segments)
No, but non-political advertisers can use this targeting tactic.

Behavioral segments (e.g. inferred characteristics)
No, but non-political advertisers can use this targeting tactic.

Potential Abuse


Partial grade: C

Hulu seems to be making some progress to curb abuse, but it's unclear how the platform enforces its policies.

Does it have a self-service platform?
Yes. Hulu has a self-service Ad Manager platform that is in beta, but it is not currently open to political advertisers.

Does the platform allow for negative targeting or blacklisting?
Yes, but is only permitted on a case-by-case basis.

What steps is the platform taking to prevent abuse?
Hulu does not permit political advertisers to use their self-service platform and they limit the kind of targeting such advertisers can do.

User Control


Partial grade: C

Users cannot opt out of political ads. The platform gives users little control over how they are targeted.

Can users opt out of political ads?
No, but they can opt out of interest-based ads and the collection of precise location data, according to Hulu's privacy policy. It's unclear what effect this would have on the political ads they see.

Can users get access to information about how they are being targeted?

Can users request deletion of their data?
Some users can. California residents can request deletion of their data, but they must delete their entire Hulu account to do so.