aboutsummaryrefslogtreecommitdiffstats
path: root/doc/dnt-policy.txt
diff options
context:
space:
mode:
authorzotlabs <mike@macgirvin.com>2018-04-05 22:15:15 -0700
committerzotlabs <mike@macgirvin.com>2018-04-05 22:15:15 -0700
commitb17f7410501acadbf547c68a4577c371826e69e3 (patch)
treecbaaea9abcada1e6dba4b63747688a90a5b0c89f /doc/dnt-policy.txt
parent4a45c35c4e0e27b737d80a6f151b0b50aaef3d1e (diff)
downloadvolse-hubzilla-b17f7410501acadbf547c68a4577c371826e69e3.tar.gz
volse-hubzilla-b17f7410501acadbf547c68a4577c371826e69e3.tar.bz2
volse-hubzilla-b17f7410501acadbf547c68a4577c371826e69e3.zip
bring back the dnt policy document, not sure when it was lost
Diffstat (limited to 'doc/dnt-policy.txt')
-rw-r--r--doc/dnt-policy.txt218
1 files changed, 218 insertions, 0 deletions
diff --git a/doc/dnt-policy.txt b/doc/dnt-policy.txt
new file mode 100644
index 000000000..ad946d1f8
--- /dev/null
+++ b/doc/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.