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I prepared an app to be distributed on Google Play. The app doesn't have any kind of login system and I don't store users' data. Camera and Microphone are disabled and I don't even get anything from that.

I only attached AdMobFree plugin to the app. I've noticed that I need a privacy policy the same, because my AndroidManifest.xml uses

<uses-permission android:name="android.permission.GET_ACCOUNTS" />

Play Console said that I need a mandatory Privacy Policy so I generated this one http://codegz.altervista.org/QuotesWorld_privacyPolicy.html

Is that enough? What could I do to avoid this situation?

Thanks in advice.

EDIT:

I use SocialSharing plugin to share some app data. Is that the problem?

Gozus19
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2 Answers2

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If you use AdMob to show banners ads throughout your app, you need to disclose so in your generated Privacy Policy. Advertising SDKs can collect certain personal information from users, including information to run behavioral advertising.

You can see the requirements from AdMob in AdSense program requirements page here:

AdMob Requirements screenshot via TermsFeed

Your Privacy Policy should let users know that:

  • You use AdMob for advertising purposes
  • These third parties (AdMob) collect some information about the users' habits and/or devices, and
  • The Privacy Policies of these third parties (AdMob) are available for review through a link you provide in your own Privacy Policy.

As an example, see the Privacy Policy page of FrogMind.

FrogMind Privacy Policy screenshot via TermsFeed

TermsFeed
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  • I uploaded it now following your suggestion: http://codegz.altervista.org/QuotesWorld_privacyPolicy.html is it good in your opinion? Thanks in advice! – Gozus19 Dec 27 '17 at 14:39
  • @ManuelGozzi It's much better than your previous one. Also, maybe our article on this topic can help you as an example of policy structure https://termsfeed.com/blog/mobile-app-privacy-policy-sample/#What_to_Include_in_a_Mobile_App_Privacy_Policy – TermsFeed Dec 27 '17 at 14:56
  • Thank you a lot! I don't collect any kind of informations from users. I don't even use a DB except Local Storage. I only use AdMob plugin and Social Sharing plugin. Do I have to add extra features? – Gozus19 Dec 27 '17 at 14:59
  • @ManuelGozzi If the Social Sharing plugin doesn't collect any personal information, and you don't collect information yourself, then you only need to disclose about those third parties that do (in your case, AdMob). – TermsFeed Dec 27 '17 at 16:23
  • Thanks again @TermsFeed I added, just for be secure, the Social Sharing paragraph, please check it out http://codegz.altervista.org/QuotesWorld_privacyPolicy.html I think to be ready now. Sorry for these questions, I am a bit afraid about this kind of things... – Gozus19 Dec 27 '17 at 16:46
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This is Andrea from iubenda.com. We have a partnership with altervista, your provider, and you can get a privacy policy included with your account. Here an article in Italian from their website: https://blog.altervista.org/it/pubblica-gratis-la-cookie-policy-sul-tuo-sito/

As of Android apps, they're required to disclose how they're using device permissions. If you want to learn more about the topic, here's a full guide: https://www.iubenda.com/blog/privacy-policy-for-android-app/

Andrea Giannangelo
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