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

I also object to this approach.

I don't believe the approach addresses my anti-competitive concerns (In
fact, if anything it exacerbates them). If we're going to use branding as
way for companies to 'honor' DNT, then we should allow all entities to use
that option.

Moreover, in order for branding to be an option, we would also need to
create specs on size, visibility, coloring, etc. If the current DAA Code
is acceptable in this area, then we should say so. I would imagine that
creating branding elements that take up more space than the Ad Choice Icon
would create issues for advertisers.


Alan



On 7/3/13 1:34 PM, "Ninja Marnau" <nmarnau@datenschutzzentrum.de> wrote:

>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 Partyıs 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 Monday, 8 July 2013 14:49:58 UTC