Webwise "Customer Choice Process"

[Dan Beale-Cocks]

Nicholas Bohm wrote:

>  Section 11(3): In this section “direct marketing” means the
>  communication (by whatever means) of any advertising or marketing
>  material which is directed to particular individuals.
>
>  Phorm's services clearly fall within this; indeed, it is their boast.

I'd think Phorm are clear.  Phorm would say that the ads are not 
directed to a particular individual ("Fred Bloggs") but to an 
'anonymised' set of people who's browsing history included certain 
trigger words.