One Uploaded Policy Compliant Update App Anything Else to Do

Google Play has made it a bones requirement to make certain privacy-related disclosures to users, in accordance with applicative law. These disclosures are typically made available to users via a privacy notice that is easily attainable from within the app.

In short

• Platform requirements bated, under the vast bulk of legislations (and peculiarly nether the GDPR) privacy notices are legally required.
• If your app handles personal or sensitive user data, or is in the "Designed for Families" plan, you demand to add a valid privacy policy in two places: your app's Store listing folio and inside your app.
• If applicable, you have to disclose how y'all care for sensitive user and device data.
• If your app processes personal information for reasons unrelated to its functionality, you must highlight – prior to the collection and transmission – how the user data volition be used and collect user consent.
• If your app is likely to be used by kids, you are subject to boosted safe requirements.
• With iubenda you can create a privacy policy (and a Terms and Atmospheric condition document) for your Android app.

Here'southward what Google had to say in their Developer Policy Centre's User Data guidelines:

You must exist transparent in how you handle user data (e.g., information provided by a user, collected near a user, and nerveless about a user'due south use of the app or device), including by disclosing the collection, use, and sharing of the data, and you must limit utilise of the data to the description in the disclosure. If your app handles personal or sensitive user data, there are additional requirements described beneath. This policy establishes Google Play'southward minimum privacy requirements; yous or your app may need to comply with additional restrictions or procedures if required by an applicative police force.

Now, Google Play merely explicitly requires that a link to a privacy policy be visible on your app's shop listing page and within your app in cases where:

• Your app handles personal or sensitive user data, equally defined in the user data policies (including personally identifiable data, financial and payment data, authentication information, phonebook or contact data, microphone and camera sensor data, and sensitive device information).
• Your app is in the "Designed for Families" programme (regardless of access to sensitive permissions or data).

However, it is disquisitional to annotation hither that, platform requirements aside, under the vast majority of legislations, and specially under the GDPR, privacy notices are legally required.

Platform requirements bated, under the vast majority of legislations, and especially nether the GDPR, privacy notices are legally required.

Generally, failure to adhere to these laws can result in hefty fines, sanctions, audits and/or go out you open to litigation.

Privacy policy requirements for Android apps

A lot of people ask for sample privacy policies for apps. The exact required contents of a privacy policy depends upon the police force applicable to you lot and may even demand to address requirements across geographical boundaries and legal jurisdictions.

For this reason, it'southward e'er advisable that y'all arroyo your (legally mandated) privacy policy with the strictest applicable regulations in heed. You tin read more nigh determining your law of reference here or read our in-depth Legal Overview Guide here.

Let'south commencement with the legal minimum requirements. These are the most basic elements that a privacy policy should take:

• Who is the app owner?
• What information is being collected? How is that data beingness collected?
• What is the Legal footing for the drove? (due east.chiliad consent, necessary for your service, legal obligation etc.) – This is more specifically related to the GDPR and European union Law, all the same, even if you fall outside of GDPR obligations, under most countries' legislations, you lot'll still need to say why you're processing the personal data of users.
• For which specific purposes are the information nerveless? Analytics? E-mail Marketing?
• Which third parties will take admission to the data? Will any third party collect data through widgets (e.g. social buttons) and integrations (eastward.g. Facebook Connect)?
• What rights exercise users accept? Can they request to see the data you accept on them, tin they asking to rectify, erase or block their data? (under European regulations virtually of this is mandatory)
• Description of process for notifying users and visitors of changes or updates to the privacy policy
• Effective date of the privacy policy

Sensitive permissions

In addition to this, you need to make certain that you disclose your use of any of the following "dangerous" permission groups (personal or sensitive user information mentioned earlier) in your privacy policy:

• CALENDAR
• CAMERA
• CONTACTS
• LOCATION
• MICROPHONE
• PHONE
• SENSORS
• SMS
• STORAGE

Options

You have 2 options:

• remove all requests for user data or sensitive permissions (you lot volition non need to add a privacy policy if you lot remove these requests); or
• add a valid privacy policy in ii places: your app'south Store listing folio and within your app.

More on How to Add together Android and iOS Mobile Permissions for Device Data.

Prominent disclosures

If your app processes the personal information of users for reasons unrelated to the functionality of your app, you're required to make additional, easily visible disclosures almost this usage and collect user consent where required.

If your app processes personal data for reasons unrelated to its functionality, you must highlight – prior to the collection and transmission – how the user data will exist used and collect user consent.

Here'due south what Google states nearly prominent disclosures:

If your app collects and transmits personal or sensitive user data unrelated to functionality described prominently in the app's list on Google Play or in the app interface, then prior to the collection and transmission, it must prominently highlight how the user data will be used and have the user provide affirmative consent for such use.

Your in-app disclosure:

• Must be within the app itself, not only in the Play list or a website;
• Must be displayed in the normal usage of the app and not require the user to navigate into a menu or settings;
• Must describe the type of data being collected;
• Must explicate how the information will be used;
• Cannot only be placed in a privacy policy or terms of service; and
• Cannot be included with other disclosures unrelated to personal or sensitive data collection.

Your app's asking for consent:

• Must nowadays the consent dialog in a clear and unambiguous mode;
• Must crave affirmative user action (due east.g. tap to accept, tick a check-box, a verbal command, etc.) in order to accept;
• Must not brainstorm personal or sensitive information collection prior to obtaining affirmative consent;
• Must not consider navigation away from the disclosure (including borer abroad or pressing the back or abode button) every bit consent; and
• Must not apply auto-dismissing or expiring messages.

It'south worth noting that it seems that Google considers any data drove activeness that isn't made obvious from your app page or from within your interface to exist covered by this prominent disclosure policy.

Therefore a separate user notice is required in add-on to your privacy policy – which your notice should ultimately link – to for a full explanation of the data processed. Over again, the information must non be candy until you have affirmative consent by your user.

Furthermore, under regulations similar the GDPR, you are legally required to obtain informed, explicit consent before processing whatsoever personal data of users specifically where it falls outside the what's required for the performance of your service.

Options

With this in mind, you take two options when it comes to dealing with this kind of data processing. You can either:

• remove this type of data collection; or
• properly inform via in-app disclosures, link that find to the respective privacy policy and collect valid consent.

Privacy policy example for an Android app

Here's an example of privacy policy for an Android app, created with our generator.

Google Play and child rubber

Google has introduced a few policy updates in order to make the Play Store more child-friendly. If an app is likely to be used by kids, developers are subject to additional prophylactic requirements which came into force on September i, 2019.

Target Audience and App Content

Apps on Google Play are categorized, and policies practical, co-ordinate to the following target audience groups: children, children and older users, older users. Google states that they will verify that the target audience selected is in fact correct.

All apps whose target audience is primarily children must follow Families policy and Designed for Families plan requirements.

In curt:

• App content that is accessible to children must be appropriate for children.
• Both new and existing apps are now bailiwick to the target audience questionnaire. You must accurately answer the questions in the Google Play Panel and ensure that those answers are correctly updated if yous brand any changes to your app.

APIs, SDKs and neutral age screen

Apps that solely target children must non contain whatsoever APIs or SDKs that are non approved for use in kid-directed services. Apps that target both children and older audiences should not implement APIs or SDKs that are non approved for apply in child-directed services unless they are used behind a neutral age screen or implemented in a fashion that does not result in the collection of data from children.

Co-ordinate to the Play Panel Aid:

A neutral age screen is a mechanism to verify a user's historic period in a way that doesn't encourage them to falsify their historic period and gain access to areas of your app that aren't designed for children, for case an age gate. An example of this would be a organisation that asks users to freely enter their month, day, and year of birth. An wrong setup of a neutral age screen would be presetting the birth date to the required age (due east.yard., 13 years old) or indicating that a certain age is required to admission areas of the app.

Ads

In lodge to brand sure that any ads served to children (or users of unknown age) are appropriate and compliant with Google'due south policies, you must use Google Play certified ad networks.

Apps with unintentional appeal to children

Google too wants developers to ensure that their apps don't inadvertently attract children (for example with youthful animations or young characters in the graphic assets) if their content is actually designed for adults. More info on how to display the "Not designed for children" characterization in the shop listing can be institute here.

Terms and Weather condition for Mobile Apps

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Terms and Conditions (as well called ToS – Terms of Service, Terms of Use or EULA – End User License Agreement) set the way in which your product, service or content may be used, in a legally binding style. Not simply are crucial for protecting y'all from potential liabilities, but (especially in cases where something is being sold to consumers) they often contain legally mandated information such as users' rights, withdrawal or cancellation disclosures.

In general, you'll likely need to ready Terms and Conditions if you take an app that participates in some form of commerce (whether selling to users directly or facilitating trading). Additionally, some specific instances where they might be needed are where you:

• need to brand legally required disclosures related to consumer rights (specially withdrawal and cancellation rights);
• have different user levels (eg. registered vs non-registered);
• your platform allows users to sell or merchandise with other users;
• facilitate or otherwise process payments and/or other sensitive user data;
• desire to ready the rules for user behavior and state grounds for termination of accounts;
• participate in chapter programs;
• provide a software or service which can potentially crusade harm if misused;
• would similar to have some legally enforceable control over, and set rules about, how your app may exist used.

Particular accent should exist given to account termination clauses, payment atmospheric condition and the limitation of liability clauses (and disclaimers).

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Our Term and Conditions Generator helps you lot to easily generate and manage documents that are engineered to meet the specific requirements of all major app stores and upwardly to date with the master international legislations.

How to add together a privacy policy to your Android app

iubenda makes solving this issue easy: with hundreds of available clauses, our privacy policies contain all elements commonly required beyond many regions and services, while applying the strictest standards by default – giving you the option to fully customize equally needed.

Our policies are created by lawyers, monitored by our lawyers and hosted on our servers to ensure that they are ever up-to-appointment with the latest legal changes and third-party requirements.

The process is straightforward and intuitive, only:

1. click to add your services;
2. fill out your web/app owner and contact details;
3. embed.

Click hither to read the full guide on how to generate a Privacy Policy.

Here'due south how you lot can use iubenda to create a privacy policy for your Android app:

1. Add together your services

• If you utilise Twitter or other auth (=OAuth) services for user management, and so add the respective service by clicking "Add a service" so start typing the name of the service you lot'd like to add. Remember to include all services processing personal information. If you handle user registration yourself, don't forget to add the "Direct Registration" service.
• Select each applicable service from the list of suggestions that show upward and customize by but adding the specific types of personal data you lot collect. Our lawyer-crafted clauses automatically include the relevant user-rights disclosures and service definitions based on your input here.
• Add together our service chosen "Device permissions for Personal Data access" if your app requests sensitive permissions (e.g. photographic camera, microphone, accounts, contacts, or phone) or user data:
• If you'd like to add a custom service clause, merely click the "Create custom service" button and fill out the congenital-in form.

2. Fill out your app owner and contact details

Enter:

• proper name and full address;
• email address.

Congratulations! Your policy has been created. Simply check that all the details are correct, and then embed.

three. Embed

As we said in a higher place, you have to include a link to your privacy policy inside the app and in the Google Play Store app listing (and – potentially – on the marketing site you operate for it).

Inside the app

For apps, the direct link or direct text embedding methods are best. If your app processes user data while offline, be certain to provide users with an in-app offline method of accessing the privacy policy in order to be legally compliant.

Whichever embed method yous choose, retrieve that you're required to choose a location that is hands accessible and visible to users. Here's an example by Instagram:

Google Play Store listing

When your app is set, in add-on to the app's internal link, yous'll have to include a link to your privacy policy on the Google Play Store. Hither's how to encounter this requirement:

• Get to your Google Play Console
• Select an app
• Select Store presence > Store listing
• Nether "Privacy Policy", enter the iubenda direct link (since we host your policy, you lot won't go the "You are not allowed that domain for a privacy policy URL" error)
• Save your changes

This will make sure that yous have your privacy policy linked under Additional information > Developer on the Google Play Store like and then:

Meet also

• How to Add together Android and iOS Mobile Permissions for Device Data
• Privacy Policy for iOS & macOS Apps
• How to Set up Your App for the Cookie Constabulary
• Legal Requirements for Websites and Apps Used by Children

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Source: https://www.iubenda.com/en/help/11552-privacy-policy-for-android-apps

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