Re: Use of 1st Party Data in a 3rd Party Context

Thanks Yianni for the draft. But I do not see how branding and 
transparency would honor the user's choice to send DNT:1.

I disagree to treat third parties, which had contact with the user as a 
first party before, any other way than purely third parties.

They are allowed to use the data previously collected in first party 
environment only when they have
1) consent (e.g. web-wide exception) or
2) meaningful interaction so thay may act as a first party.

Otherwise, the user's choice is not to be tracked and this means not to 
link this user with the previously collected first party data.

Ninja

Am 03.07.2013 17:03, schrieb Yianni Lagos:
> Hello,
>
> I drafted the below language for consideration by the group after
> discussions with a number of the working group members.
>
> If a Party receives a network transaction to which a DNT:1 header is
> attached, during that network transaction, that Party must not use data
> it previously collected while a First Party to customize the experience
> of a user while operating as a Third Party, unless that Party’s identity
> is transparent to the user.  For example, the use of prominent branding
> directly on or around the content or advertisement would create
> transparency.
>
>
> Thank you,
> Yianni
>
>

-- 

Ninja Marnau
mail: NMarnau@datenschutzzentrum.de - http://www.datenschutzzentrum.de
Telefon: +49 431/988-1285, Fax +49 431/988-1223
Unabhaengiges Landeszentrum fuer Datenschutz Schleswig-Holstein
Independent Centre for Privacy Protection Schleswig-Holstein

Received on Wednesday, 3 July 2013 18:15:24 UTC