RE: RE : ISSUE-262: guidance regarding server responses and timing

Shane,

 

If Ad-Exchange were processing data on behalf of the contracteeS (and I don’t think this is a minor change), it’ll mean that it is sharing data with all bidders on behalf of each individual bidder. So each bidder would be individually sharing the data with the other bidders and should respond “T” to the DNT request.

 

Vincent

 

De : Shane M Wiley [mailto:wileys@yahoo-inc.com] 
Envoyé : lundi 3 novembre 2014 17:23
À : Walter van Holst; public-tracking@w3.org
Objet : Re: RE : ISSUE-262: guidance regarding server responses and timing

 

Walter,

 

An Exchange meets all of the tests of a Service Provider:

 

- processes the data on behalf of the contractee [True - in this case there are multiple contractees];

 

- ensures that the data is only retained, accessed, and used as directed 
by the contractee [True - the data is only used in accordance with the contract.];

 

- has no independent right to use the data other than in a permanently 
deidentified form (e.g., for monitoring service integrity, load 
balancing, capacity planning, or billing) [True - Exchanges themselves hold no data for independent use (profiling users for example)]; and,

 

- has a contract in place with the contractee which is consistent with 
the above limitations. [True - all of these elements are supported in the license agreement with each Exchange seat holder.]"

 

Shane Wiley
VP, Privacy & Data Governance
Yahoo

 

________________________________

From: Walter van Holst <walter.van.holst@xs4all.nl>
To: public-tracking@w3.org 
Sent: Monday, November 3, 2014 5:20 AM
Subject: Re: RE : ISSUE-262: guidance regarding server responses and timing


On 2014-10-31 21:40, Shane M Wiley wrote:
> Vincent,
> 
> The 1:M nature of the transaction does create challenges but it is
> still a Service Provider and should be treated as such.

Frankly, I don't see a way to reconcile the 1:M nature of the 
relationship as reconcilable with the definition of Service Provider.

"For the data received in a given network interaction, a service 
provider is considered to be the same party as its contractee if the 

 


service provider:



- processes the data on behalf of the contractee;
- ensures that the data is only retained, accessed, and used as directed 
by the contractee;
- has no independent right to use the data other than in a permanently 
deidentified form (e.g., for monitoring service integrity, load 
balancing, capacity planning, or billing); and,
- has a contract in place with the contractee which is consistent with 
the above limitations."

The above simply requires that a bidding platform cannot broadcast 
tracking information in order to be considered a service provider.

Regards,

  Walter