It's no so cut and dry though. If you've ever watched golf on TV you will notice that the most prominent advertising is for insurance companies (User) not golf equipment (Content). They are advertising to the cohort of users that watch golf on tv (rich business people).
That's still content targeting: They're basing the ads they place next to content based on the expected audience for that content. Everyone watching that content sees that ad, no problem.
We get into issues when we're dealing with ads being placed based on who is viewing the content.
It's all user targeting.