TLDR:
- https://quad9.net/policy/ and https://quad9.net/privacy/ are the
multiple pages of legalese
- it is a long text, not actually mentioning any actual technology
- nobody using 9.9.9.9 will read it as they are using an IP, not a
website with text
- it can change whenever, there are no versions, there is no history
of what changed (archive.org possibly)
- for a variety of reasons IP (and thus PII) might be gathered
anyway
- IP prefixes are summarized, but unknown till which size (IPv6
/48?)
- Undefined what happens with packets towards 9.9.9.9 (is somebody
doing PDNS, or otherwise grabbing bits?)
- Nothing mentioned about RFC7871 (EDNS Client Subnet) which is
required for helping CDNs/Geo-DNS...
more inline ;)
Oh and for the record: Woody, you are not the "problem" here, the
companies around Quad9 though, they have a commercial interest in the
data... somebody has to pay for it, and that can mostly only be solved
with the personal data collection nothing is for free in the end and
bills (and woody's :) have to be paid.
On 2018-11-01 06:24, Bill Woodcock wrote:
On Oct 29, 2018, at 11:38 PM, Jeroen Massar wrote:
[snip]
How can something be "GDPR compliant" when no consent is given at all?
By not collecting any PII.
That is indeed a great start, what one does not have, one cannot abuse.
Have you layered HTTP on top of DNS to provide a 20-pager of legalise
that nobody can be bothered to read as it will change at a moment's
notice?
No.
Stating "it doesn’t collect source IP addresses" means "but we collect
everything else”.
That’s an obviously false statement, and doesn’t usefully contribute
to the conversation.
Strange as https://quad9.net/privacy/ reads:
"We share anonymized data on specific domains (such as domain,
timestamp, geolocation, number of hits, first seen, last seen) with our
threat intelligence partners."
That says "Domains" and possibly labels.
It also says "geolocation" which is derived from an IP, which can be
wildly wrong but also extremely specific...
It is not specified at all what is actually really collected. It would
be great to have a list, or a log example or heck the tool (as it is
likely open source...) of what is actually logged/collected/"shared with
partners".
But more importantly, for us 'geeky people' who run our own domains,
that domain identifies an individual and thus a domain in effect points
to PII. while 'gmail' is general, 'massar.ch' is not so general any
more...
Next to that labels can include IP addresses (e.g. 1.2.3.4.in-addr.arpa,
but also the forward 4-3-2-1.dsl.isp.example) Noting that these are
looked up by every SMTP server on the planet.
Are you saying you are dropping these labels? As otherwise, you are
collecting PII.
https://quad9.net/policy/ reads:
"This policy may be amended by Quad9, and the new version of the policy
shall become effective upon its posting "
so, as it is not versioned, and previous versions are not available,
that 'policy' can be changed any time.
Today it might look okay, tomorrow, it will not, and then 9.9.9.9 is
hardcoded like 8.8.8.8 and nobody gave consent on the change in policy.
Lets look a bit deeper:
"When you use Quad9 DNS Services, the information we gather aides us to
personalize, improve and operate our infrastructure. "
Personalize? So, as in, P(ersonaliz)eII , how does one "personalize"
when you claim to not collect Personal Information?
"Our normal course of data management does not have any IP address
information or other PII logged to disk or transmitted out of the
location in which the query was received."
What is the "not-normal course"? When is that applied? What happens
then?
Did you note the 20 pages of legalese I mentioned, indeed, there is
about that amount on those pages. Would be cool to have a bullet list of
what is collected...
"We may aggregate certain counters to larger network block levels for
statistical collection purposes"
So, you keep addresses, but at "block" level. For IPv6, is that on /64,
/56 or /48? And for IPv4 /31? ... would be great to specify otherwise
that is a meaningless statement.
"observed behaviors which we deem malicious or anomalous"
Is "trying to resolve a malware URL" considered "malicious"? would be
great to specify this.
(I guess what I know what is written, but hey, it is a policy, thus
legalese and thus, needs to be specific).
"We do keep some generalized location information (at the
city/metropolitan area level) so that we can conduct debugging and
analyze abuse phenomena."
Are you saying that certain "cities" have more abuse than others!? :)
Look, just state that for debugging, IP addresses will be seen, nobody
minds they are in the clear.
But just do not log it and definitely do not automatically share with
"3rd parties"...
I'll skip commenting on the cookie section as that section just violates
any form of 'privac
