Georg Koppen:
That said, I think the draft conflates fingerprinting and linkability a distinction we should keep as it helps us structuring the tracking landscape in a meaningful way. This can be seen in 3.3 and 5.4 which is actually the thing we describe as linkability. If that is in the scope of the draft, too, maybe it should be "Tracking Guidance" and not "Fingerprinting Guidance". The difference between linkability and fingerprinting can sometimes even be found in the text itself:
"Fingerprinting also allows for tracking across origins: different sites may be able to combine information about a single user even where a cookie policy would block accessing of the cookies between origins, because the fingerprinting is relatively unique and the same for all origins."
But then on the other hand there are things like
"Passive fingerprinting would trivially include cookies."
I just saw that I always forgot to add "identifier" before "linkability" in my feedback. My bad. So, my criticism was that the draft does not differentiate between linkability by fingerprinting and linkability by identifier.
Georg