Colleagues,

I have updated my draft text to include language about permitted uses. Apologies for the delay.  It's attached as an RTF document and is in the body of this email below.  It is mean to deal with: 

Issue-10, What is a first party?

Issue-17, Data use by 1st Party

Issue-19, Data collection / Data use (3rd party)

Issue-22, Still have "operational use" of data (auditing of where ads are shown, impression tracking, etc.)

Issue-24, Possible exemption for fraud detection and defense

Issue-25, Possible exemption for research purposes

Issue-31, Minimization -- to what extent will minimization be required for use of a particular exemption? (conditional exemptions)

Issue-49, Third party as first party - is a third party that collects data on behalf of the first party treated the same way as the first party?

Issue-73, In order for analytics or other contracting to count as first-party: by contract, by technical silo, both silo and contract