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diff --git a/src/data/dnt-policy.txt b/src/data/dnt-policy.txt new file mode 100644 index 0000000..ad946d1 --- /dev/null +++ b/src/data/dnt-policy.txt @@ -0,0 +1,218 @@ +Do Not Track Compliance Policy + +Version 1.0 + +This domain complies with user opt-outs from tracking via the "Do Not Track" +or "DNT" header [http://www.w3.org/TR/tracking-dnt/]. This file will always +be posted via HTTPS at https://example-domain.com/.well-known/dnt-policy.txt +to indicate this fact. + +SCOPE + +This policy document allows an operator of a Fully Qualified Domain Name +("domain") to declare that it respects Do Not Track as a meaningful privacy +opt-out of tracking, so that privacy-protecting software can better determine +whether to block or anonymize communications with this domain. This policy is +intended first and foremost to be posted on domains that publish ads, widgets, +images, scripts and other third-party embedded hypertext (for instance on +widgets.example.com), but it can be posted on any domain, including those users +visit directly (such as www.example.com). The policy may be applied to some +domains used by a company, site, or service, and not to others. Do Not Track +may be sent by any client that uses the HTTP protocol, including websites, +mobile apps, and smart devices like TVs. Do Not Track also works with all +protocols able to read HTTP headers, including SPDY. + +NOTE: This policy contains both Requirements and Exceptions. Where possible +terms are defined in the text, but a few additional definitions are included +at the end. + +REQUIREMENTS + +When this domain receives Web requests from a user who enables DNT by actively +choosing an opt-out setting in their browser or by installing software that is +primarily designed to protect privacy ("DNT User"), we will take the following +measures with respect to those users' data, subject to the Exceptions, also +listed below: + +1. END USER IDENTIFIERS: + + a. If a DNT User has logged in to our service, all user identifiers, such as + unique or nearly unique cookies, "supercookies" and fingerprints are + discarded as soon as the HTTP(S) response is issued. + + Data structures which associate user identifiers with accounts may be + employed to recognize logged in users per Exception 4 below, but may not + be associated with records of the user's activities unless otherwise + excepted. + + b. If a DNT User is not logged in to our service, we will take steps to ensure + that no user identifiers are transmitted to us at all. + +2. LOG RETENTION: + + a. Logs with DNT Users' identifiers removed (but including IP addresses and + User Agent strings) may be retained for a period of 10 days or less, + unless an Exception (below) applies. This period of time balances privacy + concerns with the need to ensure that log processing systems have time to + operate; that operations engineers have time to monitor and fix technical + and performance problems; and that security and data aggregation systems + have time to operate. + + b. These logs will not be used for any other purposes. + +3. OTHER DOMAINS: + + a. If this domain transfers identifiable user data about DNT Users to + contractors, affiliates or other parties, or embeds from or posts data to + other domains, we will either: + + b. ensure that the operators of those domains abide by this policy overall + by posting it at /.well-known/dnt-policy.txt via HTTPS on the domains in + question, + + OR + + ensure that the recipient's policies and practices require the recipient + to respect the policy for our DNT Users' data. + + OR + + obtain a contractual commitment from the recipient to respect this policy + for our DNT Users' data. + + NOTE: if an “Other Domain” does not receive identifiable user information + from the domain because such information has been removed, because the + Other Domain does not log that information, or for some other reason, these + requirements do not apply. + + c. "Identifiable" means any records which are not Anonymized or otherwise + covered by the Exceptions below. + +4. PERIODIC REASSERTION OF COMPLIANCE: + + At least once every 12 months, we will take reasonable steps commensurate + with the size of our organization and the nature of our service to confirm + our ongoing compliance with this document, and we will publicly reassert our + compliance. + +5. USER NOTIFICATION: + + a. If we are required by law to retain or disclose user identifiers, we will + attempt to provide the users with notice (unless we are prohibited or it + would be futile) that a request for their information has been made in + order to give the users an opportunity to object to the retention or + disclosure. + + b. We will attempt to provide this notice by email, if the users have given + us an email address, and by postal mail if the users have provided a + postal address. + + c. If the users do not challenge the disclosure request, we may be legally + required to turn over their information. + + d. We may delay notice if we, in good faith, believe that an emergency + involving danger of death or serious physical injury to any person + requires disclosure without delay of information relating to the + emergency. + +EXCEPTIONS + +Data from DNT Users collected by this domain may be logged or retained only in +the following specific situations: + +1. CONSENT / "OPT BACK IN" + + a. DNT Users are opting out from tracking across the Web. It is possible + that for some feature or functionality, we will need to ask a DNT User to + "opt back in" to be tracked by us across the entire Web. + + b. If we do that, we will take reasonable steps to verify that the users who + select this option have genuinely intended to opt back in to tracking. + One way to do this is by performing scientifically reasonable user + studies with a representative sample of our users, but smaller + organizations can satisfy this requirement by other means. + + c. Where we believe that we have opt back in consent, our server will + send a tracking value status header "Tk: C" as described in section 6.2 + of the W3C Tracking Preference Expression draft: + + http://www.w3.org/TR/tracking-dnt/#tracking-status-value + +2. TRANSACTIONS + + If a DNT User actively and knowingly enters a transaction with our + services (for instance, clicking on a clearly-labeled advertisement, + posting content to a widget, or purchasing an item), we will retain + necessary data for as long as required to perform the transaction. This + may for example include keeping auditing information for clicks on + advertising links; keeping a copy of posted content and the name of the + posting user; keeping server-side session IDs to recognize logged in + users; or keeping a copy of the physical address to which a purchased + item will be shipped. By their nature, some transactions will require data + to be retained indefinitely. + +3. TECHNICAL AND SECURITY LOGGING: + + a. If, during the processing of the initial request (for unique identifiers) + or during the subsequent 10 days (for IP addresses and User Agent strings), + we obtain specific information that causes our employees or systems to + believe that a request is, or is likely to be, part of a security attack, + spam submission, or fraudulent transaction, then logs of those requests + are not subject to this policy. + + b. If we encounter technical problems with our site, then, in rare + circumstances, we may retain logs for longer than 10 days, if that is + necessary to diagnose and fix those problems, but this practice will not be + routinized and we will strive to delete such logs as soon as possible. + +4. AGGREGATION: + + a. We may retain and share anonymized datasets, such as aggregate records of + readership patterns; statistical models of user behavior; graphs of system + variables; data structures to count active users on monthly or yearly + bases; database tables mapping authentication cookies to logged in + accounts; non-unique data structures constructed within browsers for tasks + such as ad frequency capping or conversion tracking; or logs with truncated + and/or encrypted IP addresses and simplified User Agent strings. + + b. "Anonymized" means we have conducted risk mitigation to ensure + that the dataset, plus any additional information that is in our + possession or likely to be available to us, does not allow the + reconstruction of reading habits, online or offline activity of groups of + fewer than 5000 individuals or devices. + + c. If we generate anonymized datasets under this exception we will publicly + document our anonymization methods in sufficient detail to allow outside + experts to evaluate the effectiveness of those methods. + +5. ERRORS: + +From time to time, there may be errors by which user data is temporarily +logged or retained in violation of this policy. If such errors are +inadvertent, rare, and made in good faith, they do not constitute a breach +of this policy. We will delete such data as soon as practicable after we +become aware of any error and take steps to ensure that it is deleted by any +third-party who may have had access to the data. + +ADDITIONAL DEFINITIONS + +"Fully Qualified Domain Name" means a domain name that addresses a computer +connected to the Internet. For instance, example1.com; www.example1.com; +ads.example1.com; and widgets.example2.com are all distinct FQDNs. + +"Supercookie" means any technology other than an HTTP Cookie which can be used +by a server to associate identifiers with the clients that visit it. Examples +of supercookies include Flash LSO cookies, DOM storage, HTML5 storage, or +tricks to store information in caches or etags. + +"Risk mitigation" means an engineering process that evaluates the possibility +and likelihood of various adverse outcomes, considers the available methods of +making those adverse outcomes less likely, and deploys sufficient mitigations +to bring the probability and harm from adverse outcomes below an acceptable +threshold. + +"Reading habits" includes amongst other things lists of visited DNS names, if +those domains pertain to specific topics or activities, but records of visited +DNS names are not reading habits if those domain names serve content of a very +diverse and general nature, thereby revealing minimal information about the +opinions, interests or activities of the user. |