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Fix whitespace in dnt-policy.txt
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Do Not Track Compliance Policy
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Do Not Track Compliance Policy
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Version 1.0
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Version 1.0
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@ -32,23 +32,23 @@ When this domain receives Web requests from a user who enables DNT by actively
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choosing an opt-out setting in their browser or by installing software that is
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choosing an opt-out setting in their browser or by installing software that is
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primarily designed to protect privacy ("DNT User"), we will take the following
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primarily designed to protect privacy ("DNT User"), we will take the following
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measures with respect to those users' data, subject to the Exceptions, also
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measures with respect to those users' data, subject to the Exceptions, also
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listed below:
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listed below:
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1. END USER IDENTIFIERS:
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1. END USER IDENTIFIERS:
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a. If a DNT User has logged in to our service, all user identifiers, such as
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a. If a DNT User has logged in to our service, all user identifiers, such as
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unique or nearly unique cookies, "supercookies" and fingerprints are
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unique or nearly unique cookies, "supercookies" and fingerprints are
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discarded as soon as the HTTP(S) response is issued.
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discarded as soon as the HTTP(S) response is issued.
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Data structures which associate user identifiers with accounts may be
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Data structures which associate user identifiers with accounts may be
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employed to recognize logged in users per Exception 4 below, but may not
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employed to recognize logged in users per Exception 4 below, but may not
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be associated with records of the user's activities unless otherwise
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be associated with records of the user's activities unless otherwise
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excepted.
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excepted.
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b. If a DNT User is not logged in to our service, we will take steps to ensure
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b. If a DNT User is not logged in to our service, we will take steps to ensure
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that no user identifiers are transmitted to us at all.
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that no user identifiers are transmitted to us at all.
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2. LOG RETENTION:
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2. LOG RETENTION:
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a. Logs with DNT Users' identifiers removed (but including IP addresses and
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a. Logs with DNT Users' identifiers removed (but including IP addresses and
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User Agent strings) may be retained for a period of 10 days or less,
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User Agent strings) may be retained for a period of 10 days or less,
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@ -58,13 +58,13 @@ listed below:
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and performance problems; and that security and data aggregation systems
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and performance problems; and that security and data aggregation systems
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have time to operate.
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have time to operate.
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b. These logs will not be used for any other purposes.
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b. These logs will not be used for any other purposes.
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3. OTHER DOMAINS:
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3. OTHER DOMAINS:
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a. If this domain transfers identifiable user data about DNT Users to
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a. If this domain transfers identifiable user data about DNT Users to
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contractors, affiliates or other parties, or embeds from or posts data to
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contractors, affiliates or other parties, or embeds from or posts data to
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other domains, we will either:
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other domains, we will either:
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b. ensure that the operators of those domains abide by this policy overall
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b. ensure that the operators of those domains abide by this policy overall
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by posting it at /.well-known/dnt-policy.txt via HTTPS on the domains in
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by posting it at /.well-known/dnt-policy.txt via HTTPS on the domains in
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@ -75,7 +75,7 @@ listed below:
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ensure that the recipient's policies and practices require the recipient
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ensure that the recipient's policies and practices require the recipient
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to respect the policy for our DNT Users' data.
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to respect the policy for our DNT Users' data.
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OR
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OR
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obtain a contractual commitment from the recipient to respect this policy
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obtain a contractual commitment from the recipient to respect this policy
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for our DNT Users' data.
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for our DNT Users' data.
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@ -88,14 +88,14 @@ listed below:
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c. "Identifiable" means any records which are not Anonymized or otherwise
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c. "Identifiable" means any records which are not Anonymized or otherwise
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covered by the Exceptions below.
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covered by the Exceptions below.
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4. PERIODIC REASSERTION OF COMPLIANCE:
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4. PERIODIC REASSERTION OF COMPLIANCE:
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At least once every 12 months, we will take reasonable steps commensurate
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At least once every 12 months, we will take reasonable steps commensurate
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with the size of our organization and the nature of our service to confirm
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with the size of our organization and the nature of our service to confirm
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our ongoing compliance with this document, and we will publicly reassert our
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our ongoing compliance with this document, and we will publicly reassert our
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compliance.
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compliance.
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5. USER NOTIFICATION:
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5. USER NOTIFICATION:
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a. If we are required by law to retain or disclose user identifiers, we will
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a. If we are required by law to retain or disclose user identifiers, we will
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attempt to provide the users with notice (unless we are prohibited or it
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attempt to provide the users with notice (unless we are prohibited or it
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@ -105,7 +105,7 @@ listed below:
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b. We will attempt to provide this notice by email, if the users have given
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b. We will attempt to provide this notice by email, if the users have given
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us an email address, and by postal mail if the users have provided a
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us an email address, and by postal mail if the users have provided a
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postal address.
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postal address.
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c. If the users do not challenge the disclosure request, we may be legally
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c. If the users do not challenge the disclosure request, we may be legally
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required to turn over their information.
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required to turn over their information.
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@ -120,17 +120,17 @@ EXCEPTIONS
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Data from DNT Users collected by this domain may be logged or retained only in
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Data from DNT Users collected by this domain may be logged or retained only in
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the following specific situations:
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the following specific situations:
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1. CONSENT / "OPT BACK IN"
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1. CONSENT / "OPT BACK IN"
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a. DNT Users are opting out from tracking across the Web. It is possible
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a. DNT Users are opting out from tracking across the Web. It is possible
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that for some feature or functionality, we will need to ask a DNT User to
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that for some feature or functionality, we will need to ask a DNT User to
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"opt back in" to be tracked by us across the entire Web.
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"opt back in" to be tracked by us across the entire Web.
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b. If we do that, we will take reasonable steps to verify that the users who
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b. If we do that, we will take reasonable steps to verify that the users who
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select this option have genuinely intended to opt back in to tracking.
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select this option have genuinely intended to opt back in to tracking.
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One way to do this is by performing scientifically reasonable user
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One way to do this is by performing scientifically reasonable user
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studies with a representative sample of our users, but smaller
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studies with a representative sample of our users, but smaller
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organizations can satisfy this requirement by other means.
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organizations can satisfy this requirement by other means.
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c. Where we believe that we have opt back in consent, our server will
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c. Where we believe that we have opt back in consent, our server will
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send a tracking value status header "Tk: C" as described in section 6.2
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send a tracking value status header "Tk: C" as described in section 6.2
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@ -138,7 +138,7 @@ the following specific situations:
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http://www.w3.org/TR/tracking-dnt/#tracking-status-value
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http://www.w3.org/TR/tracking-dnt/#tracking-status-value
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2. TRANSACTIONS
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2. TRANSACTIONS
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If a DNT User actively and knowingly enters a transaction with our
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If a DNT User actively and knowingly enters a transaction with our
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services (for instance, clicking on a clearly-labeled advertisement,
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services (for instance, clicking on a clearly-labeled advertisement,
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@ -151,19 +151,19 @@ the following specific situations:
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item will be shipped. By their nature, some transactions will require data
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item will be shipped. By their nature, some transactions will require data
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to be retained indefinitely.
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to be retained indefinitely.
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3. TECHNICAL AND SECURITY LOGGING:
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3. TECHNICAL AND SECURITY LOGGING:
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a. If, during the processing of the initial request (for unique identifiers)
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a. If, during the processing of the initial request (for unique identifiers)
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or during the subsequent 10 days (for IP addresses and User Agent strings),
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or during the subsequent 10 days (for IP addresses and User Agent strings),
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we obtain specific information that causes our employees or systems to
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we obtain specific information that causes our employees or systems to
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believe that a request is, or is likely to be, part of a security attack,
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believe that a request is, or is likely to be, part of a security attack,
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spam submission, or fraudulent transaction, then logs of those requests
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spam submission, or fraudulent transaction, then logs of those requests
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are not subject to this policy.
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are not subject to this policy.
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b. If we encounter technical problems with our site, then, in rare
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b. If we encounter technical problems with our site, then, in rare
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circumstances, we may retain logs for longer than 10 days, if that is
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circumstances, we may retain logs for longer than 10 days, if that is
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necessary to diagnose and fix those problems, but this practice will not be
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necessary to diagnose and fix those problems, but this practice will not be
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routinized and we will strive to delete such logs as soon as possible.
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routinized and we will strive to delete such logs as soon as possible.
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4. AGGREGATION:
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4. AGGREGATION:
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@ -179,13 +179,13 @@ the following specific situations:
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that the dataset, plus any additional information that is in our
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that the dataset, plus any additional information that is in our
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possession or likely to be available to us, does not allow the
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possession or likely to be available to us, does not allow the
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reconstruction of reading habits, online or offline activity of groups of
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reconstruction of reading habits, online or offline activity of groups of
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fewer than 5000 individuals or devices.
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fewer than 5000 individuals or devices.
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c. If we generate anonymized datasets under this exception we will publicly
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c. If we generate anonymized datasets under this exception we will publicly
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document our anonymization methods in sufficient detail to allow outside
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document our anonymization methods in sufficient detail to allow outside
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experts to evaluate the effectiveness of those methods.
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experts to evaluate the effectiveness of those methods.
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5. ERRORS:
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5. ERRORS:
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From time to time, there may be errors by which user data is temporarily
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From time to time, there may be errors by which user data is temporarily
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logged or retained in violation of this policy. If such errors are
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logged or retained in violation of this policy. If such errors are
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@ -215,4 +215,4 @@ threshold.
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those domains pertain to specific topics or activities, but records of visited
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those domains pertain to specific topics or activities, but records of visited
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DNS names are not reading habits if those domain names serve content of a very
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DNS names are not reading habits if those domain names serve content of a very
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diverse and general nature, thereby revealing minimal information about the
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diverse and general nature, thereby revealing minimal information about the
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opinions, interests or activities of the user.
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opinions, interests or activities of the user.
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