Helping users comply with the Lei Geral de Proteção de Dados (LGPD)

Google has a long history of taking a user-first approach in everything we do. As a part of our commitment to users, we never sell personal information and give users transparency and control over their ad experiences via tools like My Account, Why this Ad, and Mute this Ad. We also invest in initiatives such as the Coalition for Better Ads, the Digital News Initiative, the Google News Initiative and ads.txt in order to support a healthy, sustainable ads ecosystem and help you, our publishers, grow. 

The Lei Geral de Proteção de Dados (LGPD) is a new Brazilian privacy law that is due to go into effect on August 16th, 2020. It applies to the processing of personal data, which can include online identifiers, of users located in Brazil. We are committed to supporting advertisers, publishers, and other partners as they work to comply with the LGPD and will work with them to make this transition as smooth as possible. 

The LGPD shares many concepts with the European General Data Protection Regulation (GDPR) and our products already provide features that customers can use to support their LGPD compliance efforts, including the ability to serve non-personalized ads to users and make other choices about data processing based on a user's geographic location.

This article provides additional details about how we can help assist with your LGPD compliance.

Contract updates

We already offer data protection terms for the GDPR and California Consumer Privacy Act. The GDPR terms reflect Google's status as either a processor or a controller. We will be updating those existing data protection terms to add additional, LGPD-specific terms, effective August 16th, 2020. Google’s status under the LGPD as either a controller or processor will be the same as under the GDPR. The LGPD terms will be incorporated into our existing data protection terms, so no action is required to accept the LGPD terms where the existing data protection terms already form part of your contract.

Learn more about how we use Ad Manager and Ad Exchange data

If you use Google advertising products, we encourage you to link to How Google uses information from sites or apps that use our services (e.g., from your privacy policy), which explains how Google manages data in our ads products. Doing so will give users information about Google's uses of their personal data, and assist with compliance with your transparency obligations.

Controls for ads personalization and third-party ad technology providers

In addition to the updated LGPD terms, we plan to offer product controls to assist our customers with their LGPD compliance. You can refer to the below for more information on relevant product features to assist with your LGPD compliance. If you believe you may be in scope of the LGPD, we recommend that you work with your legal advisors to assess whether any changes are required.

Google Ad Manager, AdSense, and AdMob

Only Ad Technology Providers that have shared a link with Google explaining their data usage, provided certain information, and agreed to comply with our data usage policy will be permitted to serve and measure ads for Brazilian traffic. We will publish the list of Ad Technology Providers that applies to Brazil, together with links to their privacy policies, to ensure publishers can provide transparency to their users, as part of their LGPD compliance.

Ad technology providers that are not listed can contact Google to seek certification. However, there are no immediate plans to update the list of Ad Technology Providers.

You can also choose to leverage our existing Non-Personalized Ads solution to present Brazilian users with a choice between personalized ads and non-personalized ads (or to choose to serve only non-personalized ads to users in Brazil). Campaigns that reach users based on demographics and categories of apps they've installed, for instance, are not eligible to serve on non-personalized inventory. The choices users make on publisher properties that offer non-personalized ads will determine the availability of personalized and non-personalized inventory for these properties.

Additionally, you can mark your ad requests to receive treatment for users in Brazil under the age of consent. This feature is designed to help facilitate compliance with the privacy legislation in various regions, including the EEA, the UK, and Brazil. Note that you may have other legal obligations under LGPD. Learn more about TFUA

YouTube

As announced in October 2019, Google has been working with key measurement companies including Nielsen, Comscore, Oracle Moat, DoubleVerify, Dynata, Kantar, and Integral Ad Science to migrate their YouTube ad measurement services to Ads Data Hub (ADH) in 2020. Additionally, advertisers can enable YouTube reporting via the partners we have already integrated with ADH.

Data collection, deletion, and retention controls

In addition to the updated LGPD terms, we plan to offer product controls to assist our customers with their LGPD compliance. You can refer to the below for more information on relevant product features to assist with your LGPD compliance. If you believe you may be in scope of the LGPD, we recommend that you work with your legal advisors to assess whether any changes are required.

Google Analytics data

Google Analytics has long provided features and policies to help you safeguard your data. The following features, in particular, may prove useful as you evaluate the impact of the LGPD for your company's unique situation and Analytics implementation.

• Data retention: Use the Data Retention controls to manage how long your user and event data is held on our servers.
• Users: The User Deletion API lets you manage the deletion of data associated with individual user identifiers (e.g., site visitors) from your Google Analytics and/or Analytics 360 properties.
• Properties and accounts: Google Analytics customers can also delete data for their properties and/or delete data for their accounts.
• Remarketing: Advertisers control which users are added to remarketing lists and which are not. If you use Google Analytics, you can ensure that advertising features are disabled for users who have indicated they do not want to receive personalized ads. To disable advertising features for those users, including remarketing and advertising reporting features, see Disable advertising features in the Display Features guide.