Data append?

Colleagues,

Alan  Chapell and I have agreed  on text that should cover the situation regarding "data append" when DNT is received.  I look forward to discussing.

The text is below.

Regards,
John
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Normative: 
When DNT:1 is received:

-- A 1st Party MUST NOT combine or otherwise use identifiable data received from another party with data it has collected while a 1st Party.
-- A 1st Party MUST NOT share identifiable data with another party unless the data was provided voluntarily by the user and is necessary to complete a business transaction with the user.
-- A  Party MUST NOT use data gathered while a 1st Party when operating as a 3rd Party.

Non-Normative: 
When DNT:1 is received, a 1st Party retains the ability to customize content, services, and advertising only within the context of the first party experience. A 1st party takes the user interaction outside of the 1st party experience if it receives identifiable data from another party and uses that data for customization of content, services, or advertising.
 
When DNT:1 is received the 1st Party may continue to utilize user provided data in order to complete or fulfill a user initiated business transaction such as fulfilling an order for goods or a subscription.

When DNT:1 is received and a Party has become a 3rd Party it is interacting with the user outside of the 1st Party experience.  Using data  gathered while a 1st party is incompatible with interaction as a third party.