Turns out that Google Analytics has a couple of options that you can turn on to enrich your analytics experience as an operator of your sites, which at the same time have some consequences for your privacy disclosures. In another post we highlighted the IP anonymization in Google Analytics via the _anonymizeIp() function and what the ramifications are. This post highlights policy requirements for Display Advertising. In this post you will find the general privacy policy relevant changes required by Google and how you can use iubenda to generate your policy for you.

What is the extension for Display Advertising?

What happens when you update your Google Analytics code to support Display advertising, is that you additionally enable data about your traffic to be collected via the DoubleClick cookie. That enhances GA to include features like Now if you have any of these features installed you are required to update your privacy policy by disclosing these additional capabilities or data collection/merging practices.

What do I add to the privacy policy?

Add the following two facts to your privacy policy. This information below is directly quoted from Google's support sites (emphasis added):
The Google Analytics features you've implemented based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting). Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.
Google also encourages to link to the Google Analytics opt-out browser add-on, which we also certainly think is necessary when you follow European privacy laws. Here's an additional caveat, do inform your users about what is happening via an opt-in method:
You will not facilitate the merging of personally-identifiable information with non-personally identifiable information previously collected from Display Advertising features that is based on the DoubleClick cookie unless you have robust notice of, and the user's prior affirmative (i.e., opt-in) consent to, that merger.

What to add when I use Remarketing with Google Analytics

In this case additionally disclose that:
  • You use Remarketing with Google Analytics to advertise online.
  • Third-party vendors, including Google, show your ads on sites across the Internet.
  • You and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to your website.
--> or use our clause Remarketing through Google Analytics for Display Advertising

What to add when I use the Google Display Network Impression Reporting and the DoubleClick Campaign Manager

In this case additionally disclose that:
  • You and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to your site.
--> or use our clause Display Advertising extension for Google Analytics

What to add when I use the Google Analytics Demographics and Interest Reporting

In this case additionally disclose that:
  • How you use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics.
--> or use our clause Display Advertising extension for Google Analytics

How can iubenda's implementation help?

As you can see above within the various sections, we have a broad range of Google Analytics clauses in iubenda's privacy policy generator that will help you with creating a compliant privacy policy both regarding legal and Google's requirements. Choose our standard clause "Google Analytics" and then add the following clauses depending on your actual use case:
  • Display Advertising extension for Google Analytics
  • DoubleClick for Publishers Audience Extension
  • Remarketing through Google Analytics for Display Advertising
If you have any questions, please don't hesitate to post them in our support forum.   Generate a Privacy Policy for Display Advertising

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