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Two Truths and a Lie: The FTC Disclosure Guidelines

July 25, 2018 by Susan Getgood Leave a Comment

Tom Chernaik, the CEO of CMPLY, Inc. joined me as our guest on Two Truths and a Lie this week. Greg Narain was traveling and could not join the conversation. We dropped some truth about the FTC disclosure requirements and hopefully dispelled a few myths.

Please forgive some of the technical difficulties at the beginning of the episode. It was our first program “on location,” I got a little lost on my way to Tom’s office downtown (I ALWAYS GET LOST BELOW WALL STREET) and in my rush to start on time, I forgot to plug in the Blue Yeti mic. Hey, it’s live, right??

About Tom
For more than 20 years, Tom Chernaik has worked with leading brands focusing on innovation and insight in marketing, law, social media, privacy and big data.

With a vision for addressing marketer concerns regarding compliance, Tom launched CMP.LY in 2009. He grew the company – rebranded as CommandPost – into the world’s leading social media disclosure solution and expanded the offering to include cross-platform social media measurement of audience and engagement. CommandPost was named a Gartner “Cool Vendor in Social Marketing” for 2015.

Tom holds multiple patents for his work developing innovative solutions for monitoring social network content for compliance, measurement and activation of offline processes. His work in the areas of disclosure and privacy has bridged the gaps between policy and practice with practical technology solutions.

Prior to launching his company, Tom spent more than 15 years in leadership and marketing roles for leading entertainment and media brands including XM Satellite Radio, All Indie (which he co-founded) and Gotham Records. He holds a BA in Liberal Arts from NYU and a JD from Yeshiva University’s Cardozo School of Law. Tom was also the Co-Chair of the Ethics Committee at the Word of Mouth Marketing Association from 2011-2017.

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For more posts about the FTC Guidelines, please review the FTC Category and the Ethics Category in the archives.

So you want to be an influencer?

July 7, 2018 by Susan Getgood Leave a Comment

Last winter, I recorded two video workshops about best practices in influencer marketing for genconnectU, a course for Brands, Tapping into Social Trust, which was released in late May, and for influencers, Charting Your Path, which is available now.

A reality about making a course that includes tech is that anything too specific about platforms or tools will always be overtaken by changes in the marketplace. For example, when we recorded the courses, Klout was still in business and Google called its advertising products AdWords and AdSense.

This is why I focus on strategy, process and tactics rather than specific tools in my courses. Even though things have changed in the marketplace, the best practices have not.

In addition to the video lessons, there are additional materials in both courses, including a Scope of Work outline in the course for brands, and Guidance for Setting Rates in the course for influencers.

If you use the code Susan10, you can save 10% off the list prices of $119 for the Brand course and $29 for the new Influencer course.

From BOTS to BOUGHT: The “crisis” in influencer marketing

June 29, 2018 by Susan Getgood Leave a Comment

Today, Digiday published the confessions of a former influencer describing widespread fraud in the influencer marketing space, focusing largely on bought followers on Instagram, where influencers regularly amassed followers literally overnight in order to compete for coveted fashion and beauty deals. All to meet the demand of advertisers and their agencies for scale. Reach was the de facto result. This is absolutely 100% true, I have no doubt.

It’s also not influencer marketing. We have to be REALLY careful to not throw the baby out with this admittedly nasty AF bath water.

As I wrote last week, this fraud — and it is fraud — stems from the ad industry’s relentless pursuit of scale without a similar commitment to authenticity and performance metrics.

Influencer marketing works because it is human-centered, and humans beings don’t scale neatly with algorithmic and predictable precision.

In the 90s, anthropologist Robin Dunbar theorized that humans can only sustain a limited number of stable social relationships; 150 is commonly cited as the upper limit. While modern communication has changed how this dynamic works, as we are able to move more fluidly from group to group, online and off, and may participate in multiple networks of people with whom we share common interests, we should always keep Dunbar’s number in mind when thinking about how influence works. The ripple effect of a recommendation matters just as much as the initial impact. Much harder to measure of course, but just because something is hard doesn’t mean we should not strive to do it.

Influencer marketing done right is building relationships with customers over time, who serve as the advocates for your brand to their friends, fans and followers. You know and trust them. Their audience knows and trusts them. You work together to achieve a common goal. Kumbaya and all.

Influencer marketing works because we do move in and out of different groups online, and when we share a recommendation from one into another, we form a ripple on the pond. What’s been missing is way to independently assess the audience of influencers to verify that they do have the right audience. Independent of and across the platforms, independent of the agencies. It’s challenging, and even more so if you respect individual privacy rights. I’m working on some things in this space. More to come.

In the meantime, the best approach is to understand that the best results from influencer marketing don’t come from scale. They come from trusted relationships over time.

The other issue exposed in the Digiday Confession is poor measurement practices.

Reach is a delivery metric. It tells us whether we executed our social tactic successfully. It is not a performance metric. Performance is engagement with content, and your objectives dictate whether you are working toward likes, shares and comments, or driving all the way down the funnel to conversion. Reach is not a result.

The Digiday piece also shared that boosting posts, at least in this confessor’s situation, was just as fraudulent, reaching folks not even remotely in the audience target purely to shore up the numbers. This is just straight up bad practice. Boosting posts simply to increase the reach is a waste of money. You should ONLY boost your best-performing content, the content that is getting verified engagement, to expose it to a larger or different audience. Do not boost your turkeys. Let them fade away.

What about the BOTS?
The other article that caught my attention this morning was a piece on CNN about Lil Miquela, an influential CGI (computer generated image) that amassed quite a following before it was revealed that she was a CGI.

My opinion? If CGIs advocate for brands and someone is compensated for the endorsement, it is advertising, straight up, and should be disclosed. Ethically, I think it should be disclosed even if they are not doing brand or cause related work, because they are a construct, and consumers should know.

Personally, I’m not sure I love the idea of people modeling themselves after, being influenced by, robots, but as long as it is fully disclosed as CGI advertising, I don’t see why brands shouldn’t have the option to use CGI tools to deliver their message. They can dictate the message and don’t have to worry about the opinion of the CGI. Likewise if they use BOT accounts to manage message flow or respond for the brand in place of human CSRs. It’s okay as long as you tell people they are engaging with a BOT.

But CGIs and BOTs are not influencer marketing. They are simply innovations in advertising.

Digital media predictions for a post-GDPR world

May 14, 2018 by Susan Getgood Leave a Comment

Last week, a business acquaintance made a ballsy prediction on LinkedIn for which he took a fair amount of flak. Posting a comment, I noted that his essential point was not that much of a stretch. Of course, there were nuances to the argument, but a long statement with a bunch of caveats wouldn’t be nearly as interesting or thought-provoking. Predictions have to push at the edges or people won’t pay attention. So, I figured it was time to step onto the ledge and make some predictions about the future of digital advertising. I’d love to hear what you think, agree or disagree.

1. In a post-GDPR world, targeted advertising is going to become more expensive. Not immediately. There is still a lot of confusion (some real, some manufactured) about what is required. In the end, though, the increased costs of delivering compliant targeted audiences combined with a decrease in available inventory as consumers retract or refuse permission, will increase ad rates to premium, not programmatic, rates. I’ve been arguing this for a while and the pundits are finally admitting it.

2. Context will be queen again. In order to reach the right audience, we will turn to content-centric, community-centric marketing tactics. In part because they ARE more effective in converting customers, but mostly because the cost differential between them and targeted/programmatic advertising won’t be so great. It will be just that much easier to take the leap of faith to try these tactics, which are still working out their success metrics (more about that in a bit.)

This is the opportunity for niche publishers and brands to create content for their micro-audiences that both provides the necessary context for ads and sponsored content and creates a relationship and value exchange in which the consumer is more likely to give permission for the specific use of personal data. As an example, Pepper & Wits, a new content site for women 45+ who are navigating menopause is owned by P&G; we certainly should expect sponsored content and other brand outreach but the primary purpose is to offer value to the consumer and targeted context, not targeted ads.

3. “If you aren’t paying, you’re the product” is a cliché whose days are numbered. Consumers will start to care about privacy. It has been a LONG time coming, but I truly believe that consumers are finally understanding the true cost of free digital services/platforms, and are going to want real value in exchange for the right to use their personal data. “Legitimate business interest” is not going to be sufficient to use a person’s data without permission. Publishers and brands who are offering great content and building relationships with consumers will have a far better chance of obtaining (and retaining) permission.

4. Things are about to get more competitive. Facebook and Google are vulnerable in this new advertising economy. They aren’t in danger by any means, but their models are based on scale, not relationships. They have no friends, just users. This opens up a sliver of opportunity for niche content publishers to create better experiences for consumers and pick off a little wedge of the pie. The duopoly will still get (more than) its fair share, but they will be handicapped in delivering their biggest strength, targeted audiences at scale, so the little guys can dart in and nab their share in areas where Facebook and Google cannot play effectively, content and community. Niche publishers, bloggers, even brands who can make the long haul investment. And Amazon. Amazon already does a better job of community than either Facebook or Google, is nipping at their heels and has a distinct e-commerce advantage. I also predict Reddit will make a strong play for the “community ad dollar.”

5. All of this will drive innovation. Certainly, in ad tech to manage consent, but that’s just the tip of the iceberg. Folks are already working on challenges like better measurement and attribution models that assign value properly and proportionally to all the players in the value chain, not just the last click. This is crucial for branded content, video, social media and influencer marketing.

Community is also getting some attention. Two start-ups doing interesting things to connect brands with consumers: Social Data Collective and Suzy. Suzy (AskSuzy.com) is the evolution of social media and influencer business Crowdtap. It helps advertisers make and manage meaningful connections with customers by offering them access to its super panel of consumers. Social Data Collective has a slightly different approach; it asks consumers to share personal data with the brands they love in exchange for products/services.

But I think even more interesting things are on the horizon. For example, aggregators of consumer information that validate consumer audiences and can compare them across properties, including blogs and YouTube and all the other places that community will form, not just sites big enough to register on comScore. Audience data all the way down the long tail to validate that the context IS delivering the right audience. This “data hole” has been the bête noire of the influencer marketing business, but there wasn’t a strong enough incentive to solve it, when advertisers could just buy targeted audiences cheaply. To sell content and community as the right context, you need the metrics to prove that you’ve got the goods. It’s coming. I am certain. And it won’t need PII (personally identifiable information) to do it.

We also need tools to give consumers control over their privacy across platforms and processors. Right now, if you think someone has compromised your private data or is using it without permission, good luck tracking it down. Blockchain is the best bet for creating this privacy audit trail. Someone is certainly working on this already. In fact, if you know who, I’d love to chat with them!!!

So there you have it. My predictions for the digital media industry. If you need me, I’ll just be out here teetering on the ledge.

P.S. If you want to check out the prediction of my business acquaintance, you can find it on LinkedIn.

Customer-Centric Marketing. An idea whose time has FINALLY come?

May 9, 2018 by Susan Getgood Leave a Comment

Activating the passion that consumers have for the brands they love and turning them into your advocates is the secret sauce to identifying and converting new customers as well as increasing the loyalty of retained customers.

This simple concept, customer-centric marketing, has been the basis of my work for more than 20 years. It’s why I embraced blogs and then social media so wholeheartedly. It’s why I advocate so strongly for transparency, authenticity and disclosure, because they foster trust, the currency of social interaction. Online and off. It’s why I have embraced GDPR and other privacy initiatives for the promise they offer to build strong relationships with customers based on a balanced, informed value exchange for personal data.

Customer-centric marketing is also an idea that is often given lip-service, but not nearly as often embedded in our corporate DNA. We talk a good game about building relationships with customers, incorporating consumer feedback, building products and services that delight them. But when it comes time to implement the marketing plan, we use the language of war. We target audiences. We deploy tactics. We execute plans. We profile the customers into personas who are expected to follow prescribed patterns of behavior.

Which is fine, to a point. It would be foolish not to aim your marketing efforts at the audience most likely to buy. But our language and our tactics both tend to dehumanize our customer, to the point that we forget they are people and not just impressions or clicks or conversions or profiles. Taken to the extreme, and make no mistake modern digital marketing exists on the very edge of this extreme, our marketing isn’t just automated, it’s robotic, and not in a good way.

More human tactics like social marketing, influencer engagement, event marketing and even branded content restore the balance and remind us that customers aren’t simply segmented groups of purchasing behaviors, they are people. Living, breathing people who love our products and services, and are simply waiting to be asked. While these tactics are very often more effective, they are nearly always more expensive than digital advertising which uses programmatic buying and consumer targeting to reach the right audiences cheaply, at scale.

The good news, for advocates of more human centered approaches (like me), is that GDPR promises to reduce that financial gap. The SUPPLY for targeted ads will be diminished when (inevitably) publishers can’t document permission or consumers withdraw permission. It also will be more expensive to deliver an audience targeted PROPERLY with personal data. Both scenarios will increase CPMs for the remaining inventory. More on these and other scenarios in Marketing Week.

Certainly, contextual targeting will pick up the slack for digital advertising. There also will still be a market for premium permission-targeted audiences. Niche publishers in particular have tremendous incentive to develop a strong value proposition, both for their content and in exchange for the use of personal data for targeting. I wrote about this last fall.

As the cost gap closes between digital advertising at scale and more engaging tactics like influencer marketing and branded content, marketers will have incentive to shift budget to customer-centric marketing, where relevance can be proven by our interest and engagement with content and brands, not simply implied by our browsing history or past purchasing behavior.

It’s then up to us as marketers to create the compelling, customer-centric campaigns that engage consumers and convert prospects to buyers.

I’m game!

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Additional Reading on GDPR. Tick Tock. Less than 3 weeks to go.

A column from the UK’s Marketing Week that shares a similar perspective on the opportunity to my own: Ben Davis: GDPR is the bible of customer-centricity
Overview from Ad Exchanger on Google’s Policy: Google’s GDPR Consent Tool Will Limit Publishers To 12 Ad Tech Vendors
Nice piece from AdAge: Publishing Trade Groups Criticize Google over GDPR Policy Sidebar: I find Google’s position that it is a data controller particularly interesting in light of its usual claim that it is a tech company, not a publisher or media company. It seems inconsistent that it would have first-party rights, as a controller, over data related to a content audience if it is not providing service to the audience directly (ie the content ) but only indirectly, via the services it provides to the publisher.
Sweet piece from TechCrunch on Facebook’s response

Yes, my friends, influencers do have influence. Here’s why we’ve gotten confused.

March 3, 2018 by Susan Getgood

Earlier this week, my friend Toby Bloomberg tagged me into a conversation on LinkedIn about evaluating influencers for branded content programs, spurred by a Medium post that argued influencers don’t really have influence.

My comment got too long. What a surprise! Not. So I am posting it on the blog in its entirety. For context:

Influencers have influence. Ultimately, influencers are your customers. They buy (or don’t) your products and services, and they talk to each other. Some influence a few, some influence many. But there is always value in customer -centric marketing.

The issue here is that we collectively have done a few things that contribute to the perception that influencers don’t have influence. I could write a book on this, and perhaps I should, in between trying to re-establish my consulting practice once again after 7 years inside.

First, we talk about one group, influencers, which is misleading. There are really multiple subgroups, each of which has different characteristics, and should be folded into the marketing plan with different strategies and tactics. Microinfluencers are your customers who individually do not have tons of followers, but in aggregate can create a volume of earned media. Mid-tier content creators/bloggers are also your customers, but they have built a larger following on a blog or social platform, and can be tapped into as content producers for both the endorsement value and their distribution channels. Celebrity influencers are much more about their scale, and somewhat less about their role as your actual customer.

Second, we need to activate these different types of influencers in ways that match their reach, influence and status as your customer. The same strategies don’t work across the board. We should start with our business objective, tap into the influencer population that will best help achieve that objective and the define a measurement strategy matched to the program. We also need to communicate those objectives and expectations clearly to the influencers we work with. It is OKAY to ask someone you are compensating to deliver a certain result. Our clients ask it of us. We should ask it of the people we work with. Not necessarily with crowdsourced strategies tapping into hundreds of microinfluencers, but certainly for content programs with mid-tier folks and celebrities. You cannot get mad at non-delivery if you don’t set an expectation.

Third, we need to ground our content programs in relationships with our influencers. After all, they are our customers. There are no shortcuts to relationships. There is no tool, no database, no algorithm that can substitute for the relationship. Use automated tools to get started, to manage content production, to monitor and measure results, to understand the performance of your influencers. But don’t expect that you can define a target audience, search a database for influencers that match the target, or whose audience does, or both, hire them to do something without the due diligence of getting to know them, and then hope for the best. If you know the influencers, you’ll know whether and where they have influence.

Finally, the original article was interesting in that it conflated two related but different marketing strategies, influencer marketing and thought leadership, in an attempt to make the case for thought leadership over influencer marketing. You can certainly tap into a customer (influencer) population as part of a thought leadership strategy, but by and large, thought leadership is about conveying ideas and building an expert reputation for the individuals and their organization, as a conduit to sales. Expertise does matter, and we may reach out to other experts in our field, with greater or lesser degrees of influence, to support and distribute our idea, but it is not the expertise of the customers. It is that of the brand and its representatives that is the focus.

Each strategy, influencer marketing and thought leadership, has its place in the marketing mix, and we don’t have to pick between them.

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Agree with my ideas, but not sure how to get started? I can help with everything from strategy development and content creation to influencer, digital and social marketing, performance audits and presentation decks. Even better, the first hour is free. Email sgetgood@getgood.com to book your free consultation. I’ll give you some thought starters during our conversation, and we can go from there.

This week in influencer marketing: New York Times “discovers” Influencer fraud; Washington Post columnist laments changes in online mom influencers; Facebook changes the rules. Again.

February 3, 2018 by Susan Getgood

In my post on January 22d, I noted that there was at least one article about influencer marketing every day, often more.

This week was no different, except for a change, the articles weren’t only in industry press. They also were in the papers that many consider the newspapers of record of the United States, The New York Times and The Washington Post.

New York Times “discovers” influencer fraud

This is not news. We’ve long known that the social platforms are chock full of fake accounts. ALL OF THEM. But most especially Twitter, the subject of the NYT story last weekend and follow-up posted on Thursday.

What is news is that it made it to the front page of a paper of record.

The NYT article dug into the business practices of Devumi, a firm used by celebrities, politicians, athletes and other prominent Twitter users to boost their followers. Long story short: lots of fake followers, often based on the identities of real people, artificial scale at best, fraud at worst.

The follow-up article reported that in the days after the original piece, many fraudulent accounts just vanished. Oh, and the company moved OUT of Florida, where it was about to be the focus of an investigation, reportedly to Colorado.

Lots to unpack in this, from the responsibility of the social platforms to better secure their systems to the imperative of scale to prove influence. The latter is what interests me for the purposes of today’s post, although I expect I will comment on the responsibility issue at some future point.

Certainly, there are celebrity influencers with huge Twitter followings on the roster of the companies that sell fake followers. It stands to reason that in the search for scale, some took a shortcut. Not news. Influencer marketing agencies and platforms know this, and have taken what steps they can to guard against it, as reported in Digiday.

From my perspective, this news is one large exclamation point to the value of quality over quantity when it comes to influencer marketing. Don’t get trapped into a numbers game that is easily gamed. Focus on building real relationships with the influencers who are your customers, your fans, your advocates. Less is more.

Advertising is and always will be about scale. It’s job is to cost effectively reach the largest number of interested people with your message in the shortest amount of time.

But influencer marketing is a different animal. Solid influencer marketing builds on relationships with influential customers who choose to advocate for your brand to reach other customers in authentic ways. Too much focus on scale perverts the fundamental nature of social influence. Not that scale isn’t important. But not at the cost of everything else that makes social influence effective.

Perhaps now the demand for scale will be tempered a little bit with an understanding that scale does not necessarily equal quality. My hope is that more folks will be receptive to this approach and stop chasing BIG follower numbers, choosing instead to match their influencer approach to their marketing objectives. When scale makes sense, such as launching a new product, and you need to raise awareness, turn to microinfluencers or celebrities to spread the word fast to many. But your bread and butter influencer strategy should be grounded in your true advocates, of any size, whose passion for your brand has real influence, and convinces others to try, buy, believe.

I am the eternal optimist.

WaPo columnist laments the changes in online mom influence

I feel like I have read this piece before. That’s not true, of course, but I have read so many like it in the past 15 years. From the fears of the longtime netizens when the web first began to commercialize to the circa 2008/2009 lamentations about the commercialization of blogs (which BTW led to the creation of Blog With Integrity,) and regularly since then, the constant refrain is that somehow sponsored content must be less authentic than spontaneous endorsement because it is solicited and curated.

In this article, the author misses the good old days of mom blogs, which she recalls as the authentic stories of parenting challenges, and bemoans the careful polish of today’s sponsored Instagram posts. Fair enough, and everyone is entitled to an opinion, But here’s the thing: the good old days always look better than today in the rosy glow of history. Some day, today will be the good old days.

The reality? There was good sponsored content and bad sponsored content “back then” and mom bloggers didn’t necessarily share everything even if it appeared more raw. The social currency was then and will always be the trust of your audience and the care which the endorser takes to ground her endorsement in a context that resonates for her readers.

There is no single perfect social platform, only the one where your customers are. “Back then,” blogs were the logical successor to forums and chat rooms, where many of the early parenting communities took root. Today, 15 years later, the new parent is likely from a completely different generational cohort. One that largely grew up digital, mobile phone in hand. Bottom line, if you are trying to reach millennial parents, visual formats like Instagram, Snapchat and video are a good bet for your marketing message.

That doesn’t mean that long-form is dead, or that no one is writing blogs anymore, or that Instagram has simply become a product billboard. Your social experience is what you make it. There is plenty of good writing, video and podcasting out there, if you want to find it. It may be advertiser supported, or part of a more traditional media property, or even behind a paywall, but it’s there, in parenting and any other vertical you care to name. There will ALWAYS be people who want to tell stories.

The question you have to ask yourself as a reader, is how do you want to support those storytellers? If you are getting the content for free, whether through Instagram, a podcast or a blog, you need to accept a certain amount of advertising with your content. You can decide how MUCH you want, but it isn’t fair to deny the storyteller fair compensation.

For their part, marketers need to be honest with themselves. Very little endorsement is truly spontaneous. Very few brands can generate unsolicited endorsement at scale. You need to pay to play somewhere. Isn’t it great that we can direct some of those dollars right back to our customers? I think so.

eMarketer is bullish on Instagram

eMarketer reports that Instagram is the most popular influencer platform, per research by influencer platform Zine.

Of course it is popular. It is easy to do, for the brands and the influencers, perfect for fashion, beauty and food, fast (no waiting 6 months to see uptake like with Pinterest) and the metrics are still squishy enough that “engagement” still counts as success. There are more Instagram influencer agencies, networks and platforms than I can even count any more, and new ones every day. All vying of course to be acquired by a bigger fish. Maybe even the biggest fish, Instagram/Facebook itself.

But it isn’t the only way to engage your influential customers as online advocates and evangelists. Blogs, Facebook, YouTube, bespoke online communities, your own website, media sites, even Reddit, Twitter and Pinterest, all have something to offer to the influencer marketing mix, depending on your objectives, your product, your timeframe, your customers themselves.

So use caution when faced with data showing Instagram as the winner in the sponsored content stakes or as doubling in size from 2016 to 2017, as one recent study from Klear touted. Of course the use of Instagram for sponsored posts grew significantly year on year, but Klear measured based on the presence of a disclosure hashtag, either #ad or #sponsored. This leads to a faulty analysis. You can’t compare the market in the (relative) wild west of 2016 , when many were largely still ignoring FTC rules, to 2017, when the FTC regularly issued warnings to influencers about poor disclosure and people started cleaning up their game.

Increase, yes. Double? Doubtful. There are probably a whole lotta posts in 2016 going uncounted. But, yay for better disclosure practices in 2017. Better disclosure is a good thing for consumers and for the social marketing industry, and about time.

Facebook changes the rules. Again.

Facebook has narrowed the acceptable uses of its branded content tool. In a nutshell, the person or entity POSTING the item must be the creator of or significantly featured in the content being promoted. You can post a sponsored video you created or star in but you can’t post a video for the sponsor in which you did not participate. Effectively making ads the default solution for most current video distribution.

In my opinion, this will translate into a short term decrease in opportunity for influencers who use their Facebook page for sponsored content, but a long term gain, as brands return to using more influencer generated/featured content in their marketing programs.

Wanna hear me talk about all this?

I was a guest on This Week in Digital Media, a Facebook Live show hosted by Chloe DiVita , and we discussed all these topics at some length. Watch here: https://www.facebook.com/PerceptivePresence/videos/182048805886795/

Photo credit: Matt Britton