RE: ACTION-267 - Propose first/third party definitions from existing DAA documents

This is helpful.


Just so we are all on the same page can you clarify affiliate vs.
non-affiliate.   Is it correct to assume affiliate means a wholly owned


So a Third Party who collects data from an affiliate is not a third party.
So this would or could mean a totally separate brand which the user has no
knowledge of?  




From: Rachel Thomas [] 
Sent: Tuesday, October 09, 2012 1:16 PM
Subject: ACTION-267 - Propose first/third party definitions from existing
DAA documents


Folks - As promised, I am submitting the Digital Advertising Alliance (DAA)
definitions of "first party" and "third party" for consideration / inclusion
in section 3.5
first-third-parties>  ("First and Third Parties") of the W3C TPWG "Tracking
Compliance and Scope" document.  Below are both formal definitions and
related commentary from the DAA Self-Regulatory Principles for Multi-Site




Definition: A First Party is the entity that is the owner of the Web site or
has Control over the Web site with which the consumer interacts and its


Commentary: The actions of agents and other entities that similarly perform
business operations of First Parties are treated as if they stand in the
shoes of First Parties under these Principles and thus such actions are not
included in Multi-Site Data.




Definition: An entity is a Third Party to the extent that it collects
Multi-Site Data on a non-Affiliate's Web site.


Commentary:  As described in the OBA Principles, in certain situations where
it is clear that the consumer is interacting with a portion of a Web site
that is being operated by a different entity than the owner of the Web site,
the different entity would not be a Third Party for purposes of the
Principles, because the consumer would reasonably understand the nature of
the direct interaction with that entity. The situation where this occurs
most frequently today is where an entity through a "widget" or "video
player" enables content on a Web site and it is clear that such content and
that portion of the Web sites is provided by the other entity and not the
First Party Web site. The other entity (e.g. the "widget" or "video player")
is directly interacting with the consumer and, from the consumer's
perspective, acting as a First Party. Thus, it is unnecessary to apply to
these activities the Principles governing data collection and use by Third
Parties with which the consumer is not directly interacting. 


Very best,



Rachel Nyswander Thomas

Vice President, Government Affairs

Direct Marketing Association

(202) 861-2443 office

(202) 560-2335 cell



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Received on Wednesday, 10 October 2012 03:58:12 UTC