Add DNT policy

assets/dnt-policy.txt

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+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.