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3.0 P3P Implications
The data elements for a Web Bug are very similar to Web Logs. This type of information is aggregate data that doesn't show PII. The purpose of collecting the data is really to determine what visitors are looking at. To this end, the P3P purpose of data collection will be Pseudo Analysis and/or Pseudo Decision.
Use of web bugs can also be tied to a cookie that tracks visitors. If this cookie enables a web site to connect the web bug to PII then the purpose of data collection will then be Individual Analysis and/or Individual Decision.
In addition to the implications of P3P purposes there is also a consideration of the recipient of the data. The usual mechanism for these devices is for a third party to offer this service to web sites. There are no concerns for the web site unless they give user information to the web bug provider. If the web site operator does not transmit PII to the web bug provider then there need not be a declaration of additional recipients. However, in any case, the HTML readable privacy policy should disclose the name of the web bug provider.
Web Bugs (clear gifs) can also be used in emails to determine if a user opens the email. If you use these devices please see the discussion of the P3P implications.
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