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Align all descriptions of GPC to say it restricts sharing and targeting between different organizations. #104

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@jyasskin jyasskin commented May 14, 2025

This is an alternative to #102 to be more clear that GPC also opts into the Colorado/Connecticut/New Jersey/Virginia/Utah framework. As discussed in my last comment on #102, we don't need to mention cross-organization targeting—"sharing" covers this use—but folks might like the extra clarity. Those laws (e.g. Virginia) share a definition of "targeted advertising":

"Targeted advertising" means displaying advertisements to a consumer where the advertisement is selected based on personal data obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests. "Targeted advertising" does not include: ...

I've paraphrased this into this PR's definition of "cross-organization targeted advertising". Google isn't tied to the specific paraphrase here. I did want to point out that we've avoided the word "affiliate" even though the laws use it. They define it as legal entities under common control, but the rest of the world uses it in affiliate marketing to refer to unrelated businesses that send each other sales, so it's best to avoid the confusion here.

Google also isn't tied to using "organization" in the term. "Party" and "entity" are also options. We avoided "site" because that's not the boundary the laws look at, and because actually blocking information sharing at the site boundary would require new information boundaries inside existing companies that run multiple websites. We also didn't use an unqualified "targeted advertising" even though the laws use that phrase, because the laws explicitly define it in a way that differs from an average person's understanding of the phrase.


Preview (#dfn-cro…) (#abstrac…) (#introdu…) (#definit…) (#legal-e…) | Diff

@martinthomson
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I like this, but wonder if this doesn't go a little further than you intended. It's possible that you intended this as well :)

My reading is that this change would make Protected Audience incompatible with a choice to enable GPC. That might align with expectations, but it doesn't align with the goals of Protected Audience.

@jyasskin jyasskin linked an issue May 15, 2025 that may be closed by this pull request
index.html Outdated
<dfn data-lt="cross-organization ad targeting|">Cross-organization targeted
advertising</dfn> means showing a person advertisements, where the advertisement is selected
based on data about that person that was gathered from organizations beyond just the one
they're interacting with when they see the advertisement.
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An explicit mention that "organization" is something that varies by the jurisdiction could be useful.

@bvandersloot-mozilla
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s/organization/party/g could make it clearer that this is just keeping the same ambiguity we already had about what constitutes prohibited sharing, by reusing the noun from do-not-sell-or-share interaction's definition

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I've suggested changes here to match what I think the best path forward is here. It matches my last comment and leans into the existing ambiguity in "party" while explicitly identifying some ad targeting as a form of sharing, rather than something elsyoue entirely.

Comment on lines +104 to +105
third parties, or to have their data used for cross-organization ad targeting.
This standard is intended to work with existing and upcoming legal frameworks
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Suggested change
third parties, or to have their data used for cross-organization ad targeting.
This standard is intended to work with existing and upcoming legal frameworks
third parties. This standard is intended to work with existing and upcoming legal frameworks

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Undoing this change. I think the implicit inclusion of ads stuff is best for the abstract.

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I'm not sure about this change: @j-br0 and @AramZS seem to be arguing that cross-party ad targeting isn't just a kind of sharing (or else #102 would be acceptable), and if that's a common opinion, I think the abstract should mention both.

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It wasn't as clear to me that they were opposed from the discussion, but I may have missed it in the subtlety of performing vs facilitating cross party ad targeting. I agree that if the editors think it is useful to identify as an independent behavior to call out in the abstract that we should continue to do so and the diff you already have in this PR is good.

index.html Outdated
@@ -161,7 +162,7 @@ <h2>Definitions</h2>
<p>
A <dfn>do-not-sell-or-share interaction</dfn> is an interaction with a website in which the
person is requesting that their data not be sold to or shared with any party other than the
one the person intends to interact with, or to have their data used for cross-site ad targeting,
one the person intends to interact with, or to have their data used for [=cross-organization ad targeting=],
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Suggested change
one the person intends to interact with, or to have their data used for [=cross-organization ad targeting=],
one the person intends to interact with, or to have their data used for [=cross-site ad targeting=],

s/organization/party/

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Your suggestion says "site" here, but I've switched it to "party".

jyasskin and others added 2 commits May 16, 2025 08:57
s/organization/party/g

Co-authored-by: bvandersloot-mozilla <[email protected]>
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Thanks Ben! I've merged all but one of your suggestions, which could use a bit more discussion.

Comment on lines +104 to +105
third parties, or to have their data used for cross-organization ad targeting.
This standard is intended to work with existing and upcoming legal frameworks
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I'm not sure about this change: @j-br0 and @AramZS seem to be arguing that cross-party ad targeting isn't just a kind of sharing (or else #102 would be acceptable), and if that's a common opinion, I think the abstract should mention both.

index.html Outdated
@@ -161,7 +162,7 @@ <h2>Definitions</h2>
<p>
A <dfn>do-not-sell-or-share interaction</dfn> is an interaction with a website in which the
person is requesting that their data not be sold to or shared with any party other than the
one the person intends to interact with, or to have their data used for cross-site ad targeting,
one the person intends to interact with, or to have their data used for [=cross-organization ad targeting=],
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Your suggestion says "site" here, but I've switched it to "party".

@michaelkleber
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My reading is that this change would make Protected Audience incompatible with a choice to enable GPC. That might align with expectations, but it doesn't align with the goals of Protected Audience.

My very strong take-away from yesterday's discussion is that the relationship between GPC and any particular advertising mechanism is up to various regulators, and we should anything that looks like we're infringing on that. Following Ben's lead and suggesting wording that leans into that existing ambiguity.

@j-br0 j-br0 added the agenda+ Request to add this issue to the agenda of our next telcon or F2F label Jul 16, 2025
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Consistency in use of sell/share/track/target terminology
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