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How we treat DNT on Mozilla web properties

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mer...@mozilla.com

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Mar 1, 2016, 12:17:45 PM3/1/16
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Hi all,

As you probably know already, Mozilla, like many companies around the Web, uses third-party tools and services to better understand the visitor trends and user actions on our web properties. You can read more about those services on our Websites Privacy Notice [1]. These services are important to measuring our success and to making decisions about how we can build a great product for our users. We also believe it is important to provide users with meaningful controls over services like these. That brings us to the subject of Do Not Track (DNT) and our web properties.

In the past, we have not had a standard approach regarding how we apply DNT to the third-party services we use on our web properties. We've left that decision up to the managers of those properties. In some case, that means we turn off services like Google Analytics when we see a DNT signal. In other cases we leave them on. This is a subject that Mozilla's community has been discussing for several years [2][3][4].

We think now is the right time to take a more consistent approach. After reviewing earlier community discussions and consulting with those who utilize these tools at Mozilla, below is the policy we are putting in place. This is a custom DNT implementation that would apply to those third-party services we specifically use and is intended to be in the spirit of the W3C's draft DNT specification [5].

The policy: Generally, Mozilla will seek to work with third-party services that honor the user's DNT preference. Because many third-party services do not honor DNT, and restricting our use to only those that do so would present significant challenges in collecting useful analytics information, we will also use services that disregard DNT. However, Mozilla will instead honor the user's tracking preference and turn off those services for users that have enabled DNT.

- This policy is intended to apply to those services that are reasonably judged to fall within the W3C's draft DNT tracking definition. More specifically, the policy applies to cross-site tracking that combines data from across non-commonly owned sites about the user's web browsing activity. It does not apply to those tools Mozilla may use that operate purely in a service provider role and that collect and combine data only from Mozilla Web properties.

- This approach will not apply for Internet Explorer 10 and 11. The DNT signal is intended to reflect the user's tracking preference. Because DNT was on by default in I.E. 10 and 11, it does not reflect the user's explicit choice regarding tracking.

Implementation: Here is how this policy should be applied to the services we specifically enlist on our Web properties:

- When DNT is on, Mozilla's Web properties should turn off Google Analytics (GA) if the Advertising Reporting Feature is enabled. When that feature is enabled, GA begins to collect demographics and interest information from Google advertising cookies and combine that information with data about users visiting Mozilla Web properties. It therefore falls within the definition of cross-site tracking. If the Advertising Reporting Feature is not enabled, GA does not collect information from Google advertising cookies. In those cases, it is operating in a service provider capacity, and allowing the practice is consistent with the user's DNT signal.

- Flashtalking should be turned off when DNT is on. Flashtalking is a tool Mozilla uses to measure the effectiveness of our advertising campaigns. It allows us to determine if a user who installs the browser previously clicked or viewed an ad for Firefox. In doing so, it is combining data across sites.

- Optimizely may be used regardless of the user's DNT preference. It does not combine data about visitors to Mozilla Web properties with data from non-Mozilla properties. It is operating in a service provider capacity on behalf of Mozilla, with IP anonymization and random IDs that are specific to Mozilla's account.

1. https://www.mozilla.org/en-US/privacy/websites/
2. https://bugzilla.mozilla.org/show_bug.cgi?id=697436#c14
3. https://bugzilla.mozilla.org/show_bug.cgi?id=858839#c18
4. https://bugzilla.mozilla.org/show_bug.cgi?id=1136169
5. http://www.w3.org/2011/tracking-protection/drafts/tracking-compliance.html
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