User Data

Changes are coming to this policy!

See the upcoming User Data policy here, which goes into effect on December 16, 2020.

 

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 or 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.

COLLAPSE ALL EXPAND ALL

 

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, microphone, camera, and other sensitive device or usage data. If your app handles sensitive user data, then you must:

  • Limit your access, collection, use, and sharing of personal or sensitive 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 in the Play Store). Apps that extend usage of this data for serving advertising must be in compliance with our Ads Policy.
  • Post a privacy policy in both the designated field in the 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. Your privacy policy must disclose the types of personal and sensitive data your app accesses, collects, uses, and shares and the types of parties with which any personal or sensitive user data is shared.
  • Handle all personal or 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 or sensitive user data.

Prominent Disclosure & Consent Requirement

In cases where users may not reasonably expect that their personal or 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 or sensitive 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 or 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 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 or 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.

 

EU-U.S. 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.

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