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

From: Jeffrey Chester <jeff@democraticmedia.org>
Date: Thu, 30 Oct 2014 19:48:24 -0400
Cc: Rob van Eijk <rob@blaeu.com>, TOUBIANA Vincent <vtoubiana@cnil.fr>, Justin Brookman <jbrookman@cdt.org>, Nicholas Doty <npdoty@w3.org>, "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>, "Roy T. Fielding" <fielding@gbiv.com>
Message-Id: <77527F0F-5BE5-431A-ACBB-EC8E50BA6BB3@democraticmedia.org>
To: Shane M Wiley <wileys@yahoo-inc.com>
We also have programmatic direct, which can work involving ad agency trading desks, publishers, third party data providers, measurement companies.

The exchange can also have rules and relationships, depending on who it is, like Doubleclick.  
Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org
www.digitalads.org
202-986-2220

On Oct 30, 2014, at 6:18 PM, Shane M Wiley <wileys@yahoo-inc.com> wrote:

> Rob,
> 
> That is incorrect.
> 
> #1 - The exchange houses the bid transaction but does not set the rules of the bid "winner" - the bid requester sets these rules (but is most often the highest bidder but sometimes quality is selected over bid price).
> #2 - The exchange houses the bid transaction but does not initiate the request - the bid requester (the inventory supply - typically a publisher or 1st party) actually launches the request and the Exchange forwards the request to those parties interested in bidding (the content demand - typically an advertiser or 3rd party).
> 
> - Shane
> 
> -----Original Message-----
> From: Rob van Eijk [mailto:rob@blaeu.com] 
> Sent: Thursday, October 30, 2014 3:11 PM
> To: Shane M Wiley
> Cc: TOUBIANA Vincent; Justin Brookman; Nicholas Doty; Tracking Protection Working Group; Roy T. Fielding
> Subject: RE: ISSUE-262: guidance regarding server responses and timing
> 
> Shane,
> I diagree for two reasons. (1) The key function of the ad exchange is select the highest bidder and (2) the ad exachange initiates the bidding process with a bid requests and therefore initiates the communication with all bidders. These two conditions rule out "mere conduit" in the EU.
> Rob
> 
> Shane M Wiley schreef op 2014-10-30 17:50:
>> Rob,
>> 
>> Incorrect - they are merely a conduit.
>> 
>> I don't believe I'm asking for a specific exception for Exchanges but 
>> rather for any Service Provider where the actual transaction recipient 
>> is not visible to the user agent and therefore cannot receive their 
>> appropriate DNT signal for their domain appropriately.  The overriding 
>> rule should be once a party is able to receive their domain's own DNT 
>> signal then they must honor it.
>> 
>> - Shane
>> 
>> -----Original Message-----
>> From: Rob van Eijk [mailto:rob@blaeu.com]
>> Sent: Thursday, October 30, 2014 2:35 AM
>> To: TOUBIANA Vincent
>> Cc: Shane M Wiley; Justin Brookman; Nicholas Doty; Tracking Protection 
>> Working Group; Roy T. Fielding
>> Subject: RE: ISSUE-262: guidance regarding server responses and timing
>> 
>> TOUBIANA Vincent schreef op 2014-10-30 10:14:
>>> Also, what I understood from previous discussion was that only the 
>>> data contained in the current Bid Request was used to assess the Bid, 
>>> while now I understand from the "Real Time Bidder Policy"  is that 
>>> the "assessment" is also based on data collected from previous bid 
>>> requests, even if the bidder lost.
>> 
>> Precisely, the ad exchange plays a role that goes beyond "mere 
>> conduit".
>> 
>> Shane M Wiley schreef op 2014-10-29 23:08:
>>>> As the Exchange is a neutral party I’d recommend we attempt to 
>>>> develop a carve-out/permitted use for this type of entity.
>> 
>> I object to a permitted use for data exchanges. There are many 
>> different types of exchanges - e.g. private, public, data, etc. - and 
>> new (technical and business)models for exchanges will follow. The Ad 
>> Exchange is - in my view - (jointly) responsible for the ad boundaries 
>> that are used by the bidding algorithms. A permitted use for these 
>> entities is synonymous with 'kicking the can down the road'.
>> 
>>>> If we create a paradigm such that all members of an Exchange must 
>>>> support DNT, then the Exchange will not support DNT – and as others 
>>>> will likely see this as a competitive disadvantage they will not 
>>>> support it either.
>> 
>> I am not convinced by the argument, that due to a perceived 
>> competitive disadvantage other Exchanges will not implement either.
>> The effect could well be that users will shunt exchanges that ignore 
>> DNT, which could turn engineering privacy into the rtb protocol a 
>> competitive advantage.
>> 
>> Rob
>> 
>> 
>> TOUBIANA Vincent schreef op 2014-10-30 10:14:
>>> So we agree that the constraint is not on the retention of the data 
>>> but it's on the use that can be made of it (i.e. no destruction).
>>> 
>>> Also, what I understood from previous discussion was that only the 
>>> data contained in the current Bid Request was used to assess the Bid, 
>>> while now I understand from the "Real Time Bidder Policy"  is that 
>>> the "assessment" is also based on data collected from previous bid 
>>> requests, even if the bidder lost.
>>> 
>>> Vincent
>>> 
>>> DE : Shane M Wiley [mailto:wileys@yahoo-inc.com] ENVOYÉ : jeudi 30 
>>> octobre 2014 00:45 À : TOUBIANA Vincent; Justin Brookman; Nicholas 
>>> Doty CC : Tracking Protection Working Group; Roy T. Fielding OBJET :
>>> RE: ISSUE-262: guidance regarding server responses and timing
>>> 
>>> The "Data Use" and "Real Time Bidder Policy" sections cover use of 
>>> data only for assessment and analytics (prediction algo - not user 
>>> specific). Not to be used for any form of profiling. This is in-line 
>>> with what I've been saying.
>>> 
>>> - Shane
>>> 
>>> FROM: TOUBIANA Vincent [mailto:vtoubiana@cnil.fr]
>>> SENT: Wednesday, October 29, 2014 4:04 PM
>>> TO: Shane M Wiley; Justin Brookman; Nicholas Doty
>>> CC: Tracking Protection Working Group; Roy T. Fielding
>>> SUBJECT: RE: ISSUE-262: guidance regarding server responses and 
>>> timing
>>> 
>>> Thank you for the clarification Shane, but from what I understand of 
>>> these guidelines 
>>> (https://www.google.com/doubleclick/adxbuyer/guidelines.html [1]) at 
>>> least Google has a different retention policy for bidders.
>>> Also, could you confirm or infirm that user-agent will not be in a 
>>> position to block the UID once they receive the "?" response?
>>> 
>>> Vincent
>>> 
>>> -----Original Message-----
>>> From: Shane M Wiley [mailto:wileys@yahoo-inc.com]
>>> Sent: Wed 10/29/2014 11:28 PM
>>> To: TOUBIANA Vincent; Justin Brookman; Nicholas Doty
>>> Cc: Tracking Protection Working Group; Roy T. Fielding
>>> Subject: RE: ISSUE-262: guidance regarding server responses and 
>>> timing
>>> 
>>> Justin is correct, Vincent is incorrect - Bidders are subject to 
>>> bid-loss/data destruction constraint, not the Exchange (since it's 
>>> the Exchange hosting the bid transaction).
>>> 
>>> - Shane
>>> 
>>> From: TOUBIANA Vincent [mailto:vtoubiana@cnil.fr]
>>> Sent: Wednesday, October 29, 2014 3:19 PM
>>> To: Justin Brookman; Nicholas Doty
>>> Cc: Tracking Protection Working Group; Roy T. Fielding
>>> Subject: RE: ISSUE-262: guidance regarding server responses and 
>>> timing
>>> 
>>>> Also, I believe Shane indicated on a previous call that losing
>>> bidders are typically prohibited from retaining (or using?) lost bid 
>>> data.
>>> 
>>> If this prohibition applies, I believe it's only for the ad-exchange.
>>> I don't think the bidders are subject to this constraint.
>>> 
>>>> And a particularly wary user agent could always deny access to
>>> cookies or otherwise limit an exchange's access to tracking resources 
>>> when it receives a ? TSV . . .
>>> 
>>> That would not work: the user-agent receives the "?" only after it 
>>> has sent its UID to the ad-exchange. It has then no control over the 
>>> diffusion of the (UID,URL) to the bidders.
>>> 
>>> Vincent
>>> 
>>> On Oct 21, 2014, at 6:43 PM, Nicholas Doty <npdoty@w3.org> wrote:
>>> 
>>>> Our discussion last week of ISSUE-262 (guidance regarding server
>>> responses and timing) focused on a question of ad exchanges or other 
>>> servers that communicate with a number of other servers, for one of 
>>> which it acts as a service provider. The question was how the 
>>> exchange/real-time-bidding server should respond, for users that 
>>> fetch the tracking status resource. In some cases, if the exchange 
>>> server knows that all of its potential winning bidders/potential 
>>> responders have a common DNT policy, the server could just respond 
>>> statically with the tracking status resource that corresponds to the 
>>> request and those downstream servers. But what if the server's 
>>> downstream servers don't have a common DNT policy (some comply and 
>>> some don't; some claim consent and some don't; etc.)?
>>>> 
>>>> Based on IRC conversation, here is what I would suggest for that
>>> case:
>>>> 
>>>> A server that doesn't know ahead of time what server will win the
>>> bid and where those downstream servers have varying/incompatible 
>>> policies, the exchange server can respond to any tracking status 
>>> resource requests with the tracking status value of "?", which we had 
>>> previously defined for any resources for which the tracking behavior 
>>> is dynamic.
>>>> 
>>>> 
>>> http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#T
>>> S
>>> V-
>>> [2]
>>> <http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#
>>> T
>>> SV-
>>> [2]> ?
>>>> 
>>>> In order to comply with the TPE, the exchange server would need to
>>> determine the appropriate tracking status from the downstream server 
>>> that wins the bid and supplies the response. And in the response to 
>>> the resource request (to load the ad, for example), the exchange 
>>> server would send a Tk response header with the appropriate value. 
>>> The server might also send a "status-id" field so that interested 
>>> users could query the tracking-status resource that could then be 
>>> specific to that fulfilling server (links to privacy policy, etc.).
>>>> 
>>>> Roy suggests that we might need to make a small change to the
>>> requirements about the cached life of these values to correspond to 
>>> this case (where the same URL might be fulfilled in different ways by 
>>> different servers within a 24 hour period). I believe we'd indicate 
>>> that the Tk: response value does not need to be valid for at least 24 
>>> hours, but only for the request itself. That wouldn't change any of 
>>> the expected caching behavior of tracking status resources. I believe 
>>> that would just be a clarification added to either 6.7.2 or 6.3.1.
>>>> 
>>>> (The question also doesn't arise for advertising models where the
>>> user agent is redirected to another server to deliver the ad itself 
>>> -- in that case each server just responds to any tracking status 
>>> resource requests based on its individual policy.)
>>>> 
>>>> Thanks,
>>>> Nick
>>> 
>>> 
>>> 
>>> Links:
>>> ------
>>> [1] https://www.google.com/doubleclick/adxbuyer/guidelines.html
>>> [2]
>>> http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#T
>>> S
>>> V-
Received on Thursday, 30 October 2014 23:48:51 UTC

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