User Data

 
You must be transparent in how you handle user data (e.g., information collected from or about a user, including device information). That means disclosing your app’s access, collection, use, and sharing of the data, and limiting the use of the data to the purposes disclosed. In addition, if your app handles personal and sensitive user data, please also refer to the additional requirements in the "Personal and Sensitive Information" section below. These Google Play requirements are in addition to any requirements prescribed by applicable privacy and data protection laws. If you include third party code (e.g., SDKs) in your app, you must ensure that the third party code used in your app is compliant with Google Play Developer Program policies. 

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Personal and Sensitive Information

Personal and sensitive user data includes, but isn't limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call related data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data. If your app handles personal and sensitive user data, then you must:

  • Limit your access, collection, use, and sharing of personal and sensitive user data acquired through the app to purposes directly related to providing and improving the features of the app (e.g., user anticipated functionality that is documented and promoted in the app's description on Google Play). Sharing personal and sensitive user data includes using SDKs or other third party services that cause data to be transferred to a third party. Apps that extend usage of personal and sensitive user data for serving advertising must be in compliance with our Ads Policy.
  • Handle all personal and sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).
  • Use a runtime permissions request whenever available, prior to accessing data gated by Android permissions.
  • Not sell personal and sensitive user data.

Prominent Disclosure & Consent Requirement

In cases where users may not reasonably expect that their personal and sensitive user data will be required to provide or improve the policy compliant features or functionality within your app (e.g., data collection occurs in the background of your app), you must meet the following requirements:

You must provide an in-app disclosure of your data access, collection, use, and sharing. The in-app disclosure:

  • Must be within the app itself, not only in the app description or on 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 data being accessed or collected;
  • Must explain how the data will be used and/or shared;
  • Cannot only be placed in a privacy policy or terms of service; and
  • Cannot be included with other disclosures unrelated to personal and sensitive user data collection.

Your in-app disclosure must accompany and immediately precede a request for user consent and, where available, an associated runtime permission. You may not access or collect any personal and sensitive data until the user consents. The app's request for consent:

  • Must present the consent dialog clearly and unambiguously;
  • Must require affirmative user action (e.g., tap to accept, tick a check-box);
  • Must not interpret navigation away from the disclosure (including tapping away or pressing the back or home button) as consent; and
  • Must not use auto-dismissing or expiring messages as a means of obtaining user consent.

 

Examples of common violations
  • An app that accesses a user's inventory of installed apps and doesn't treat this data as personal or sensitive data subject to the above Privacy Policy, data handling, and Prominent Disclosure and Consent requirements.
  • An app that accesses a user's phone or contact book data and doesn't treat this data as personal or sensitive data subject to the above Privacy Policy, data handling, and Prominent Disclosure and Consent requirements.
  • An app that records a user’s screen and doesn't treat this data as personal or sensitive data subject to this policy.
  • An app that collects device location and does not comprehensively disclose its use and obtain consent in accordance with the above requirements
  • An app that collects restricted permissions in the background of the app including for tracking, research, or marketing purposes and does not comprehensively disclose its use and obtain consent in accordance with the above requirements. 

Restrictions for Personal and Sensitive Data Access

In addition to the requirements above, the table below describes requirements for specific activities.

Activity  Requirement
Your app handles financial or payment information or government identification numbers Your app must never publicly disclose any personal and sensitive user data related to financial or payment activities or any government identification numbers.
Your app handles non-public phonebook or contact information We don't allow unauthorized publishing or disclosure of people's non-public contacts.
Your app contains anti-virus or security functionality, such as anti-virus, anti-malware, or security-related features Your app must post a privacy policy that, together with any in-app disclosures, explain what user data your app collects and transmits, how it's used, and the type of parties with whom it's shared.
Your app targets children Your app must not include an SDK that is not approved for use in child-directed services. See Designing Apps for Children and Families for full policy language and requirements. 
Your app collects or links persistent device identifiers (e.g., IMEI, IMSI, SIM Serial #, etc.)

Persistent device identifiers may not be linked to other personal and sensitive user data or resettable device identifiers except for the purposes of 

  • Telephony linked to a SIM identity (e.g., wifi calling linked to a carrier account), and
  • Enterprise device management apps using device owner mode.

These uses must be prominently disclosed to users as specified in the User Data Policy.

Please consult this resource for alternative unique identifiers.

Please read the Ads policy for additional guidelines for Android Advertising ID.

 

Data Safety section

All developers must complete a clear and accurate Data Safety section for every app detailing collection, use, and sharing of personal and sensitive user data. The developer is responsible for the accuracy of the Data Safety section and keeping this information up-to-date. Where relevant, the Data Safety section must be consistent with the disclosures made in the app’s privacy policy. 

Privacy Policy

All apps must post a privacy policy in both the designated field in Play Console and within the app itself. The privacy policy must, together with any in-app disclosures, comprehensively disclose how your app accesses, collects, uses, and shares user data, not limited by the data disclosed in the Data Safety section. This must include: 

  • developer information and a privacy point of contact or a mechanism to submit inquiries
  • disclosing the types of personal and sensitive data your app accesses, collects, uses, and shares; and any parties with which any personal or sensitive user data is shared
  • secure data handling procedures for personal and sensitive user data
  • the developer’s data retention and deletion policy
  • clear labeling as a privacy policy (e.g., listed as “privacy policy” in title)

The entity (e.g., developer, company) named in the app’s Google Play listing must appear in the privacy policy or the app must be named in the privacy policy. Apps that do not access any personal and sensitive user data must still submit a privacy policy. 

Please make sure your privacy policy is available on an active URL (no PDFs) and is non-editable.

 

 

Usage of App Set ID

Android will introduce a new ID to support essential use cases such as analytics and fraud prevention. Terms for the use of this ID are below.

  • Usage: App set ID must not be used for ads personalization and ads measurement. 
  • Association with personally-identifiable information or other identifiers: App set ID may not be connected to any Android identifiers (e.g., AAID) or any personal and sensitive data for advertising purposes.
  • Transparency and consent: The collection and use of the app set ID and commitment to these terms must be disclosed to users in a legally adequate privacy notification, including your privacy policy. You must obtain users’ legally valid consent where required. To learn more about our privacy standards, please review our User Data policy.

 

 

EU-U.S., Swiss Privacy Shield

If you access, use, or process personal information made available by Google that directly or indirectly identifies an individual and that originated in the European Union or Switzerland (“EU Personal Information”), then you must:

  • Comply with all applicable privacy, data security, and data protection laws, directives, regulations, and rules;
  • Access, use or process EU Personal Information only for purposes that are consistent with the consent obtained from the individual to whom the EU Personal Information relates;
  • Implement appropriate organizational and technical measures to protect EU Personal Information against loss, misuse, and unauthorized or unlawful access, disclosure, alteration and destruction; and
  • Provide the same level of protection as is required by the Privacy Shield Principles.

You must monitor your compliance with these conditions on a regular basis. If, at any time, you cannot meet these conditions (or if there is a significant risk that you will not be able to meet them), you must immediately notify us by email to data-protection-office@google.com and immediately either stop processing EU Personal Information or take reasonable and appropriate steps to restore an adequate level of protection.

As of July 16, 2020, Google no longer relies on the EU-U.S. Privacy Shield to transfer personal data that originated in the European Economic Area or the UK to the United States. (Learn More.)  More information is set forth in Section 9 of the DDA.

 

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