server/static/dnt-policy/dnt-policy-1.0.txt

   1 Do Not Track Compliance Policy
   2
   3 Version 1.0
   4
   5 This domain complies with user opt-outs from tracking via the "Do Not Track"
   6 or "DNT" header  [http://www.w3.org/TR/tracking-dnt/].  This file will always
   7 be posted via HTTPS at https://example-domain.com/.well-known/dnt-policy.txt
   8 to indicate this fact.
   9
  10 SCOPE
  11
  12 This policy document allows an operator of a Fully Qualified Domain Name
  13 ("domain") to declare that it respects Do Not Track as a meaningful privacy
  14 opt-out of tracking, so that privacy-protecting software can better determine
  15 whether to block or anonymize communications with this domain.  This policy is
  16 intended first and foremost to be posted on domains that publish ads, widgets,
  17 images, scripts and other third-party embedded hypertext (for instance on
  18 widgets.example.com), but it can be posted on any domain, including those users
  19 visit directly (such as www.example.com). The policy may be applied to some
  20 domains used by a company, site, or service, and not to others.  Do Not Track
  21 may be sent by any client that uses the HTTP protocol, including websites,
  22 mobile apps, and smart devices like TVs. Do Not Track also works with all
  23 protocols able to read HTTP headers, including SPDY.
  24
  25 NOTE: This policy contains both Requirements and Exceptions. Where possible
  26 terms are defined in the text, but a few additional definitions are included
  27 at the end.
  28
  29 REQUIREMENTS
  30
  31 When this domain receives Web requests from a user who enables DNT by actively
  32 choosing an opt-out setting in their browser or by installing software that is
  33 primarily designed to protect privacy ("DNT User"), we will take the following
  34 measures with respect to those users' data, subject to the Exceptions, also
  35 listed below:
  36
  37 1. END USER IDENTIFIERS:
  38
  39   a. If a DNT User has logged in to our service, all user identifiers, such as
  40      unique or nearly unique cookies, "supercookies" and fingerprints are
  41      discarded as soon as the HTTP(S) response is issued.
  42
  43      Data structures which associate user identifiers with accounts may be
  44      employed to recognize logged in users per Exception 4 below, but may not
  45      be associated with records of the user's activities unless otherwise
  46      excepted.
  47
  48   b. If a DNT User is not logged in to our service, we will take steps to ensure
  49      that no user identifiers are transmitted to us at all.
  50
  51 2. LOG RETENTION:
  52
  53   a. Logs with DNT Users' identifiers removed (but including IP addresses and
  54      User Agent strings) may be retained for a period of 10 days or less,
  55      unless an Exception (below) applies. This period of time balances privacy
  56      concerns with the need to ensure that log processing systems have time to
  57      operate; that operations engineers have time to monitor and fix technical
  58      and performance problems; and that security and data aggregation systems
  59      have time to operate.
  60
  61   b. These logs will not be used for any other purposes.
  62
  63 3. OTHER DOMAINS:
  64
  65   a. If this domain transfers identifiable user data about DNT Users to
  66      contractors, affiliates or other parties, or embeds from or posts data to
  67      other domains, we will either:
  68
  69   b. ensure that the operators of those domains abide by this policy overall
  70      by posting it at /.well-known/dnt-policy.txt via HTTPS on the domains in
  71      question,
  72
  73     OR
  74
  75      ensure that the recipient's policies and practices require the recipient
  76      to respect the policy for our DNT Users' data.
  77
  78     OR
  79
  80      obtain a contractual commitment from the recipient to respect this policy
  81      for our DNT Users' data.
  82
  83     NOTE: if an “Other Domain” does not receive identifiable user information
  84     from the domain because such information has been removed, because the
  85     Other Domain does not log that information, or for some other reason, these
  86     requirements do not apply.
  87
  88   c. "Identifiable" means any records which are not Anonymized or otherwise
  89      covered by the Exceptions below.
  90
  91 4. PERIODIC REASSERTION OF COMPLIANCE:
  92
  93   At least once every 12 months, we will take reasonable steps commensurate
  94   with the size of our organization and the nature of our service to confirm
  95   our ongoing compliance with this document, and we will publicly reassert our
  96   compliance.
  97
  98 5. USER NOTIFICATION:
  99
 100   a. If we are required by law to retain or disclose user identifiers, we will
 101      attempt to provide the users with notice (unless we are prohibited or it
 102      would be futile) that a request for their information has been made in
 103      order to give the users an opportunity to object to the retention or
 104      disclosure.
 105
 106   b. We will attempt to provide this notice by email, if the users have given
 107      us an email address, and by postal mail if the users have provided a
 108      postal address.
 109
 110   c. If the users do not challenge the disclosure request, we may be legally
 111      required to turn over their information.
 112
 113   d. We may delay notice if we, in good faith, believe that an emergency
 114      involving danger of death or serious physical injury to any person
 115      requires disclosure without delay of information relating to the
 116      emergency.
 117
 118 EXCEPTIONS
 119
 120 Data from DNT Users collected by this domain may be logged or retained only in
 121 the following specific situations:
 122
 123 1. CONSENT / "OPT BACK IN"
 124
 125   a. DNT Users are opting out from tracking across the Web.  It is possible
 126      that for some feature or functionality, we will need to ask a DNT User to
 127      "opt back in" to be tracked by us across the entire Web.
 128
 129   b. If we do that, we will take reasonable steps to verify that the users who
 130      select this option have genuinely intended to opt back in to tracking.
 131      One way to do this is by performing scientifically reasonable user
 132      studies with a representative sample of our users, but smaller
 133      organizations can satisfy this requirement by other means.
 134
 135   c. Where we believe that we have opt back in consent, our server will
 136      send a tracking value status header "Tk: C" as described in section 6.2
 137      of the W3C Tracking Preference Expression draft:
 138
 139      http://www.w3.org/TR/tracking-dnt/#tracking-status-value
 140
 141 2. TRANSACTIONS
 142
 143    If a DNT User actively and knowingly enters a transaction with our
 144    services (for instance, clicking on a clearly-labeled advertisement,
 145    posting content to a widget, or purchasing an item), we will retain
 146    necessary data for as long as required to perform the transaction. This
 147    may for example include keeping auditing information for clicks on
 148    advertising links; keeping a copy of posted content and the name of the
 149    posting user; keeping server-side session IDs to recognize logged in
 150    users; or keeping a copy of the physical address to which a purchased
 151    item will be shipped.  By their nature, some transactions will require data
 152    to be retained indefinitely.
 153
 154 3. TECHNICAL AND SECURITY LOGGING:
 155
 156   a. If, during the processing of the initial request (for unique identifiers)
 157      or during the subsequent 10 days (for IP addresses and User Agent strings),
 158      we obtain specific information that causes our employees or systems to
 159      believe that a request is, or is likely to be, part of a security attack,
 160      spam submission, or fraudulent transaction, then logs of those requests
 161      are not subject to this policy.
 162
 163   b. If we encounter technical problems with our site, then, in rare
 164      circumstances, we may retain logs for longer than 10 days, if that is
 165      necessary to diagnose and fix those problems, but this practice will not be
 166      routinized and we will strive to delete such logs as soon as possible.
 167
 168 4. AGGREGATION:
 169
 170   a. We may retain and share anonymized datasets, such as aggregate records of
 171      readership patterns; statistical models of user behavior; graphs of system
 172      variables; data structures to count active users on monthly or yearly
 173      bases; database tables mapping authentication cookies to logged in
 174      accounts; non-unique data structures constructed within browsers for tasks
 175      such as ad frequency capping or conversion tracking; or logs with truncated
 176      and/or encrypted IP addresses and simplified User Agent strings.
 177
 178   b. "Anonymized" means we have conducted risk mitigation to ensure
 179      that the dataset, plus any additional information that is in our
 180      possession or likely to be available to us, does not allow the
 181      reconstruction of reading habits, online or offline activity of groups of
 182      fewer than 5000 individuals or devices.
 183
 184   c. If we generate anonymized datasets under this exception we will publicly
 185      document our anonymization methods in sufficient detail to allow outside
 186      experts to evaluate the effectiveness of those methods.
 187
 188 5. ERRORS:
 189
 190 From time to time, there may be errors by which user data is temporarily
 191 logged or retained in violation of this policy.  If such errors are
 192 inadvertent, rare, and made in good faith, they do not constitute a breach
 193 of this policy.  We will delete such data as soon as practicable after we
 194 become aware of any error and take steps to ensure that it is deleted by any
 195 third-party who may have had access to the data.
 196
 197 ADDITIONAL DEFINITIONS
 198
 199 "Fully Qualified Domain Name" means a domain name that addresses a computer
 200 connected to the Internet.  For instance, example1.com; www.example1.com;
 201 ads.example1.com; and widgets.example2.com are all distinct FQDNs.
 202
 203 "Supercookie" means any technology other than an HTTP Cookie which can be used
 204 by a server to associate identifiers with the clients that visit it.  Examples
 205 of supercookies include Flash LSO cookies, DOM storage, HTML5 storage, or
 206 tricks to store information in caches or etags.
 207
 208 "Risk mitigation" means an engineering process that evaluates the possibility
 209 and likelihood of various adverse outcomes, considers the available methods of
 210 making those adverse outcomes less likely, and deploys sufficient mitigations
 211 to bring the probability and harm from adverse outcomes below an acceptable
 212 threshold.
 213
 214 "Reading habits" includes amongst other things lists of visited DNS names, if
 215 those domains pertain to specific topics or activities, but records of visited
 216 DNS names are not reading habits if those domain names serve content of a very
 217 diverse and general nature, thereby revealing minimal information about the
 218 opinions, interests or activities of the user.