Some things I like and dislike about it. Like you said @Free, it doesn’t rely on warning boxes. Great thinking there.
A couple of areas still need work. I don’t understand the section where they give the states permission to enforce the law. Do they understand how the Constitution works? States don’t need permission to innovate new laws. Look at marijuana legalization and the Wyoming Blockchain Coalition. Better to work with states instead of going straight to the belly of the beast.
You also have a potential loophole in the definition of “party:”
“Party” means a User, an Organization, or a group of legal entities that share common ownership and control, operate as an integrated enterprise, and have a group identity that is easily discoverable by a User. Common branding or publishing a list of affiliates that is readily available online via a prominent link from a Resource where a party describes its DNT practices are deemed easily discoverable.
Does this mean that you can just create a phony umbrella group that’s your company + all your scummy partners and throw up a website to promote them to first parties? Now it’s not Google tracking you but “The Google Data Excellence Project.” or some other B.S. Boom, done, track away.