- From: Dan Auerbach <dan@eff.org>
- Date: Tue, 25 Jun 2013 23:34:11 -0700
- To: "public-tracking@w3.org" <public-tracking@w3.org>
- Message-ID: <51CA8B63.5030205@eff.org>
* De-identified data use A third party MAY use de-identified data for any purposes whatsoever. Short-term use and debugging A third party MAY use protocol information (e.g. HTTP header information and IP address information) for any purpose, subject to a one week retention period. Limited retention of data beyond this period for debugging purposes may occur, provided the data is only used for debugging purposes and only retained as long as necessary for those purposes. If data is being retained for more than 6 months for debugging purposes, notice must be given in the privacy policy that some data is being retained for greater than 6 months for debugging. Frequency capping Regardless of DNT signal, protocol information maybe collected, retained and used for up to 4 weeks to limit the number of times that a user sees a particular advertisement, often called frequency capping, as long as the data retained do not reveal the user's browsing history. Parties must notcollect or use unique identifiers of users, user agents or devices in association with this data. Parties must notconstruct profiles of users or user behaviors based on their ad frequency history, or otherwise alter the user's experience. Billing and auditing * ** *Regardless of DNT signal, protocol information maybe collected, retained and used for billing and auditing for up to 6 months, or longer if notice is given in the privacy policy with an explanation of why the extra retention is necessary. Parties must notcollect or use unique identifiers of users, user agents or devices in association with this data. This may include, for example, counting ad events, verifying positioning and quality of ad impressions, or data that an auditor explicitly requires to be retained.* ** * Security and Fraud To the extent proportionate and reasonably necessary for detecting security risks and fraudulent or malicious activity, parties maycollect, retain, and use protocol data regardless of a DNT signal for up to 6 months, or longer if notice is given in the privacy policy with an explanation of why the extra retention is necessary. Parties must notcollect or use unique identifiers of users, user agents or devices in association with this data. This includes data reasonably necessary for enabling authentication/verification, detecting hostile and invalid transactions and attacks, providing fraud prevention, and maintaining system integrity. In the context of this specific permitted use, this information maybe used to alter the user's experience in order to reasonably keep a service secure or prevent fraud. Data maybe kept beyond 6 months or the published retention period for a specific ongoing investigation or for legal purposes, but general data collection for security and fraud mustbe limited to 6 months or the published retention period. It is a best practice to approach security and fraud issues with a graduated responsewhere appropriate, retaining the minimal amount of data that is necessary for security and fraud purposes, and expanding the scope of data retention only when it becomes necessary to do so once a particular issue has been discovered.* -- Dan Auerbach Staff Technologist Electronic Frontier Foundation dan@eff.org 415 436 9333 x134
Received on Wednesday, 26 June 2013 06:34:41 UTC