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Consolidated Privacy Policy for MoFo and MoCo

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Catherine Brady

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Sep 30, 2008, 5:57:02 PM9/30/08
to gover...@lists.mozilla.org
Recently we updated the Privacy Policy for both mozilla.com and
mozilla.org. At that time, it seemed like we should consolidated these
into one single privacy policy. The reasons for the consolidation are:

* The Mozilla Corporation ("MoCo") and the Mozilla Foundation
("MoFo") share many of the same privacy practices.
* A single policy makes it easier for visitors to the Mozilla Web
sites. Now a visitor to a Mozilla Web site will know that both
companies share the same privacy practices and values. The visitor will
not have to try to decipher what, if any, differences there were between
the two policies.

In consolidating the policies, the only change we've made is to
distinguished between the practices of MoCo and MoFo where they differ.
There are no changes to our actual practices or collection of
information.

The draft consolidated Privacy Policy and the of current MoCo and MoFo
policies marked to show the proposed changes between them and the
consolidated policy, are available for your review at
https://wiki.mozilla.org/Legal:Unified_Privacy_Policy. You will see
that the consolidated policy is substantively the same as the current,
separate policies.

Please comment below if you have any questions or concerns about the
consolidated privacy policy.

Catherine

Reed Loden

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Sep 30, 2008, 10:58:56 PM9/30/08
to gover...@lists.mozilla.org
On Tue, 30 Sep 2008 14:57:02 -0700
Catherine Brady <cbr...@mozilla.com> wrote:

> Please comment below if you have any questions or concerns about the
> consolidated privacy policy.

My comments/issues below:

-----
"The Mozilla.com Web sites are operated by the Mozilla Corporation, and
the Mozilla.org Web sites are operated by the Mozilla Foundation. Since
the Mozilla Corporation and the Mozilla Foundation share many of the
same privacy practices, we will refer to them collectively as “Mozilla”
in this policy, when describing practices that apply to both of them."

Not to get technical, but the Mozilla Corporation technically
"operates" both websites since it hosts them both. Maybe "maintains" is
a better word here?

Is the comma before "when" needed?
-----
Both "Mozilla Foundation store" and "Mozilla Foundation Store" are used
in different places. Might could standardize on one capitalization form
of "store" to be consistent.
-----
"To that end, Mozilla may share potentially-personally-identifying
information with its employees, contractors and its subsidiaries and
related organizations."

This is missing the new "service providers" addition that is included
in later paragraphs.
-----
"it discloses that information only to those of its employees,
contractors, service providers and its subsidiaries and related
organizations that need to know that information in order to process it
on Mozilla's behalf and that have agreed not to disclose it to others"

Might be useful to have a comma after "service providers" to separate
it from the "its subsidiaries and related organizations" for clarity's
sake.
-----
Some places use "its subsidiaries and related organizations" while
others use "subsidiaries and related organizations". Could standardize
on one form (maybe without the "its" since that seems to work in most
places)?
-----
The changes under the "How We Use Cookies and Clear GIFs" section are
wrong, as both www.mozilla.com and www.mozilla.org employ the use of
clear gifs with Urchin for statistical/metrics purposes.
-----
"The Mozilla Foundation Web sites do this using Mozilla's own internal
analytics software, and currently does not utilize third party service
providers."

The comma before "and currently" isn't needed and is grammatically
incorrect.
-----
"The Mozilla Corporation Web sites do this by using either its own
internal analytics software or sending this information to a
third-party service provider to help Mozilla analyze this data and the
Mozilla Web sites using third-party web analytics tools are listed
here."

"or sending this" should be "or by sending this".
-----
"If you do not want to allow your session visitation information on
this Web site to be aggregated and analyzed by Mozilla (or its
third-party analytics providers, if you are using www.mozilla.com) you
may utilize the following opt-out mechanisms listed here."

This is only true for the sites that use the specified third-party
analytics provider(s) (Omniture), which is currently just *.mozilla.com.
You cannot opt out of the Urchin tracking on www.mozilla.org or
www.mozilla.com. Also, Omniture is used on more sites than just
www.mozilla.com, so might should use "*.mozilla.com" here.
-----
"Substantive changes will also be announced through the standard
mechanisms through which Mozilla communicates with the Mozilla
community, including Mozilla's "mozilla-announce" mailing list and
newsgroup."

"mozilla-announce" was renamed to
"announce" (anno...@lists.mozilla.org) a while back. Might also be
useful to give a link directly to the announce subscription page at
https://lists.mozilla.org/listinfo/announce.
-----
"If you have questions about this privacy policy, please contact the
Mozilla Foundation at pri...@mozilla.org. or the Mozilla Corporation
at pri...@mozilla.com."

Period after "pri...@mozilla.org" isn't needed.
-----

That's my initial run-through. I may have more to say later.

Hope this helps,
~reed

--
Reed Loden - <re...@reedloden.com>

Johnathan Nightingale

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Oct 1, 2008, 9:05:12 AM10/1/08
to cbr...@mozilla.com, gover...@lists.mozilla.org
Hi Catherine,

I'm really glad to see this work happening - even though I understand
the factors that lead to it, having different privacy policies for
different parts of the site always felt like a source of potential
confusion at best, and at worst, might have actually seemed like we
were trying to be sneaky.

One quick note based on the current draft: It looks like the various
parts of the policy which link off to other pages have lost their
linking. You were probably already aware of this, but in case it got
lost in the shuffle, I noticed missing links in:

- Updating Personally identifiable information - link to bugzilla
account settings ( https://bugzilla.mozilla.org/userprefs.cgi?tab=account
)
- How We Use Cookies and Clear GIFs - links to our page about third
party service providers ( http://www.mozilla.com/en-US/third-
party.html )
- Opt-out procedures - Link to opt-out mechanisms ( http://www.mozilla.com/en-US/opt-out.html
)
- Privacy Policy Changes - Links to newsgroup and mailing list

Thanks for doing this work,

Johnathan

> Please comment below if you have any questions or concerns about the
> consolidated privacy policy.
>

> Catherine
> _______________________________________________
> governance mailing list
> gover...@lists.mozilla.org
> https://lists.mozilla.org/listinfo/governance

---
Johnathan Nightingale
Human Shield
joh...@mozilla.com

Catherine Brady

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Oct 3, 2008, 5:19:32 PM10/3/08
to Johnathan Nightingale, gover...@lists.mozilla.org
Reed - thank you for your detailed review and input. We've incorporated
all your changes except one. I've asked Ken and Justin for their input
on whether or not Urchin employs clear GIFs. Depending on their answer,
we may amend the privacy policy further.

Johnathan - prior to posting the consolidated policy, we will make sure
all the hyperlinks work.

Catherine

Reed Loden

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Oct 3, 2008, 6:16:16 PM10/3/08
to Catherine Brady, gover...@lists.mozilla.org
On Fri, 03 Oct 2008 14:19:32 -0700
Catherine Brady <cbr...@mozilla.com> wrote:

> Reed - thank you for your detailed review and input. We've
> incorporated all your changes except one. I've asked Ken and Justin
> for their input on whether or not Urchin employs clear GIFs.
> Depending on their answer, we may amend the privacy policy further.

I can promise you it does... ;)

http://www.mozilla.org/images/__utm.gif
http://www.mozilla.com/img/__utm.gif

Justin

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Oct 7, 2008, 11:24:20 PM10/7/08
to
On Oct 3, 3:16 pm, Reed Loden <r...@reedloden.com> wrote:
> On Fri, 03 Oct 2008 14:19:32 -0700
>
We do use clear GIFs on mozilla.org, but no change is needed in our
policy as they are hosted on the same server as the website and all
other site images. It's needed in the Omniture case because the GIF
is hosted by Omniture and is used to transfer tracking information to
them - something we need to disclose in the privacy policy. There is
no difference between __utm.gif and any other image hosted on
mozilla.com servers.

-Justin

> Catherine Brady <cbr...@mozilla.com> wrote:
> > Reed - thank you for your detailed review and input.  We've
> > incorporated all your changes except one.  I've asked Ken and Justin
> > for their input on whether or not Urchin employs clear GIFs.
> > Depending on their answer, we may amend the privacy policy further.
>
> I can promise you it does... ;)
>

> http://www.mozilla.org/images/__utm.gifhttp://www.mozilla.com/img/__utm.gif
>
> ~reed
>
> --
> Reed Loden - <r...@reedloden.com>

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