Paid Programming: Investigating streaming ads during the election season

Paid Programming: Investigating streaming ads during the election season


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Originally developed under Netflix, Roku is an American streaming TV device that offers access to streaming platforms from various online services. Roku currently operates globally. Roku had 43 million monthly active users as of August 2020.

Grade D

Overall grade

magnifying glass with grades sheet underneath

Our analysis

When it comes to transparent political advertising, Roku is not doing great. Roku does have rules in place that prohibit advertisers from using sensitive data or manipulating media, but it's unclear how these rules are enforced. Roku recently released an ad library, but it only includes basic information.

Political Ads

Letter grade C

Partial grade: C

In terms of political ads, Roku has rules banning specific kinds of targeting and the use of sensitive data. However, it's unclear how Roku enforces these policies.

Does it allow political ads?

What are its rules for placing political ads?
Roku has policies that limit the kinds of political ads that are run. Roku says that it can remove any political advertisers that are running manipulated content, misleading messaging, or targeting people using sensitive data. Only U.S.-based ad buyers can place political ads in the U.S.

Do political advertisers need to verify their identity in order to place ads?
Yes. Political advertisers must be verified prior to running any ads. However, this rule only applies to the video ad inventory that Roku runs, not ads managed by third party platforms.

Does it clearly mark political ads?

Does it require a "paid for" disclosure for political ads?
Somewhat. Roku says that all political ads must include a disclosure indicating who paid for an ad, subject to local laws. However, this rule only applies to the video ad inventory that Roku runs, not ads managed by third party platforms.

Does it fact-check or otherwise vet political ads?
Somewhat. Roku requires political ad buyers to provide sources supporting the claims they make in their ads. Roku says that it blocks and removes ads that "undermine participation or trust in the electoral or democratic processes" and will block ads that have been maliciously doctored or manipulated. However, it's unclear whether enforcement of such policies is proactive.

Ad Transparency

Letter grade D

Partial grade: D

Roku recently published a public ad archive, which is a step towards ad transparency. However, the archive only includes basic information about campaigns and researchers can't get bulk access to data.

Does it voluntarily report ad spend?

Does it have a public ad transparency library? (See our guidelines)
Yes. Roku recently launched a public-facing political ad archive in September 2020. The archive includes basic information such as the group who paid for the ad, campaign IDs, and the creative (videos). However, the archive does not include more detailed information about ad spend, targeting criteria, impressions, or other data, nor does it give researchers bulk access.

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

Ad Targeting

Letter grade C

Partial grade: C

Roku pulls in a lot of data about viewers from third party data sources. Roku does have rules prohibiting political advertisers from using certain types of sensitive data.

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

(e.g. contextual ads)


Yes. Political advertisers can target specific states, zip codes, and media markets.

Interests & Behaviors (e.g. TV viewing data)
Yes. Roku offers hundreds of viewing categories political advertisers can target.

Custom audiences (e.g. advertiser uploads 1st party data)

Audience/Customer Matching (e.g. platform matches 3rd party data to existing customers)
Yes. Roku pulls in a lot of third party data from data brokers such as LiveRamp (formerly Acxiom). For instance, people can be targeted based on household income, education level, number of children, or whether or not they are a veteran. However, Roku's policies bar political advertisers from using certain types of sensitive data, like data about users' medical conditions or sexual orientation.

Lookalike/Similar audiences (e.g. platform finds new, "similar" audience segments)

Behavioral segments (e.g. inferred characteristics)
Yes. Roku offers hundreds of unique audience segments political advertisers can target. For instance, political advertisers can target "Hispanic and multicultural viewers" or "religious" viewers.

Potential Abuse

Letter grade C

Partial grade: C

Roku's self-service ad platform could create opportunities for bad actors to exploit weaknesses on the platform. Despite policies that ban such behavior, it's unclear how such rules are enforced.

Does it have a self-service platform?
Yes. Roku has a self-service platform called OneView Ad Platform.

Does the platform allow for negative targeting or blacklisting?

What steps is the platform taking to prevent abuse?
Roku only allows U.S.- citizens and U.S.-based organizations to run U.S. political ads. In addition, they remove or block advertisers who are running misleading ads or manipulated content.

User Control

Letter grade D

Partial grade: D

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

Can users opt out of political ads?
No, but Roku allows users to “Limit ad tracking" in their settings.

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, according to Roku's privacy policy.