You must be transparent in how you handle user data (for example, information collected from or about a user, including device information). That means disclosing the access, collection, use, handling, and sharing of user data from your app, and limiting the use of the data to the policy compliant purposes disclosed. Please be aware that any handling of personal and sensitive user data is also subject to additional requirements in the "Personal and Sensitive User Data" 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 (for example, an SDK) in your app, you must ensure that the third party code used in your app, and that third party’s practices with respect to user data from your app, are compliant with Google Play Developer Program policies, which include use and disclosure requirements. For example, you must ensure that your SDK providers do not sell personal and sensitive user data from your app. This requirement applies regardless of whether user data is transferred after being sent to a server, or by embedding third-party code in your app.
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Personal and Sensitive User Data
Examples of common violations
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, health data, Health Connect 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:
Prominent Disclosure & Consent Requirement
In cases where your app’s access, collection, use, or sharing of personal and sensitive user data may not be within the reasonable expectation of the user of the product or feature in question (for example, if data collection occurs in the background when the user is not engaging with your app), you must meet the following requirements:
Prominent disclosure: You must provide an in-app disclosure of your data access, collection, use, and sharing. The in-app disclosure:
Consent and runtime permissions: Requests for in-app user consent and runtime permission requests must be immediately preceded by an in-app disclosure that meets the requirement of this policy. The app's request for consent:
Apps that rely on other legal bases to process personal and sensitive user data without consent, such as a legitimate interest under the EU GDPR, must comply with all applicable legal requirements and provide appropriate disclosures to the users, including in-app disclosures as required under this policy.
To meet policy requirements, it’s recommended that you reference the following example format for Prominent Disclosure when it’s required:
If your app integrates third party code (for example, an SDK) that is designed to collect personal and sensitive user data by default, you must, within 2 weeks of receipt of a request from Google Play (or, if Google Play’s request provides for a longer time period, within that time period), provide sufficient evidence demonstrating that your app meets the Prominent Disclosure and Consent requirements of this policy, including with regard to the data access, collection, use, or sharing via the third party code.
Refer to this article for more information on the Prominent Disclosure and Consent requirement.
Restrictions for Personal and Sensitive Data Access
In addition to the requirements above, the table below describes requirements for specific activities.
Data safety section
Please refer to this article for additional information on completing the Data safety section.
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.
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:
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 email@example.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.