• by Wendy Davis , Staff Writer @wendyndavis, May 14, 2012

With its initial public offering looming, Facebook is again floating a new privacy policy. The company's latest round of revisions were apparently prompted by the Irish Data Protection Commissioner’s Office, which Facebook says encouraged it "to be even more detailed about how we use information."

Among other changes, the company now offers some specific examples showing how it draws on users' data to target ads. "Sometimes we allow advertisers to target a category of user, like a "moviegoer" or a "sci-fi fan," the company explains. "If a person 'likes' the 'Star Trek' Page and mentions 'Star Wars' when they check into a movie theater, we may conclude that this person is likely to be a sci-fi fan. Advertisers of sci-fi movies, for example, could ask us to target “sci-fi fans” and we would target that group, which may include you."

Including that scenario in a privacy policy probably goes a long way toward explaining targeting to people who aren't in the industry.

But the new policy doesn't just attempt to clarify ad practices. Facebook also indicates it's contemplating serving ads to users when they're on other publishers' sites. That is, it appears that Facebook will use the information it collects from consumers (such as whether they're sci-fi fans) to serve them with targeted ads even when they're not on Facebook.

Facebook chief privacy officer Erin Egan reportedly confirmed that the company's policy now says "that we can advertise services to you off of Facebook based on data we have on Facebook."

While doing so probably wouldn't raise new privacy issues, it might nonetheless result in pushback for the company. Ads that are based on the kind of detailed knowledge that Facebook has about its users might feel -- for lack of a better word -- creepy to consumers.

Justin Brookman, director of the consumer privacy project at the Center for Democracy & Technology, points out that Facebook's potential move into off-site advertising -- based on data it has collected -- would hardly be groundbreaking. "With all the scrutiny on behavioral advertising based on third-party data, you're seeing more and more companies offering advertising based on data they collected as a first party," he tells MediaPost, adding that Amazon and LinkedIn currently are starting to make use of their first-party data on other sites.

But, he adds, "Facebook must be aware of the potential for backlash from consumers who don't want the company following them around the web using their communications to inform ads, so Facebook will have to make sure to message this to consumers if that's the road they're going down."

Brookman also points out that the privacy implications could change dramatically if Facebook was to combine its data about users with other information gleaned from their Web-surfing activity off-site. "That would raise significant privacy concerns," he says.