Since Google’s privacy policy has come under scrutiny by various governments lately (and that has been fairly well publicized) I thought I might write a little piece about a slightly related topic:

google_analytics_privacy_policy

How many of you do actually effectively comply with Google’s terms for the use of their various products, mainly in regards to the inclusion of legally adequate privacy notices?

One of the most interesting facts I’ve come across researching the privacy policy landscape at iubenda is that a lot of web services require you to have a privacy policy in order to use their service. It other words, if you don’t have a privacy policy (conspicuously) posted on your site, you are violating their terms of service and may be at risk of having at least your account suspended.

If you are like most people you don’t read most of what the terms of service documents outline prior to actually using the service (here’s a little thing I found). Mostly that isn’t much of a problem since these ToS are standard, following common sense and they don’t actively require you to do anything to be able/eligible to use their service.

I found a post from a while back that has researched a similar question based on Google Analytics, AdSense and AdWords and what it found was that:

  • More than 90% were breaking at least one of Google’s policies
  • More than 65% were breaking at least two of Google’s policies
  • More than 40% were breaking at least three of Google’s policies

Most people on the web rely on some service provided by Google, but many ultimately fail to comply with Google’s terms for those services: they do not have a privacy policy and those who do regularly fail to bundle the relevant information into it. Below is an overview over some of Google’s popular web products that you probably use and the exact section in their ToS detailing the requirements for you to use a privacy policy.

Google Products that Require a Privacy Policy

Here’s a list of Google products for the web (and mobile apps) that require you to make use of some sort of privacy notice:

Google Analytics requires a Privacy Policy

7. Privacy.

You will not (and will not allow any third party to) use the Service to track, collect or upload any data that personally identifies an individual (such as a name, email address or billing information), or other data which can be reasonably linked to such information by Google. You will have and abide by an appropriate Privacy Policy and will comply with all applicable laws and regulations relating to the collection of information from Visitors. You must post a Privacy Policy and that Privacy Policy must provide notice of Your use of cookies that are used to collect traffic data, and You must not circumvent any privacy features (e.g., an opt-out) that are part of the Service.
You may participate in an integrated version of Google Analytics and any DoubleClick product or service or any other Google display ads product or service (“Google Analytics for Display Advertisers”). If You use Google Analytics for Display Advertisers, You will comply with the Google Analytics for Display Advertisers Policy (available at http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409 ) and, as set forth in the policy, disclose in Your Privacy Policy (i) Your use of Google Analytics for Display Advertisers and its features You use, and (ii) how Visitors can opt-out from Google Analytics for Display Advertisers. Your access to and use of any DoubleClick or Google display ads data is subject to the applicable terms between You and Google.

Link to Google Analytics terms.

Google AdWords requires a Privacy Policy

The remarketing or similar audiences feature in AdWords allows you to reach people who previously visited your website, and match the right people with the right message. While remarketing can be a great way to attract past visitors back to your site, you should inform these people that you gather information for remarketing or similar audiences on your website.

When you use the remarketing or similar audiences feature in your website, you’re required to have the following information in your website’s privacy policy:

  • An appropriate description of how you’re using remarketing or similar audiences to advertise online.
  • A message about how third-party vendors, including Google, show your ads on sites across the Internet.
  • A message about how third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to your website.
  • Information about how your visitors can opt out of Google’s use of cookies by visiting Google’s Ads Settings.
  • Alternatively, you can point your visitors to opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt out page.

Link to AdWords terms/information

Google Cloud Storage requires a Privacy Policy

4.2 Privacy. Customer will protect the privacy and legal rights of its End Users under all applicable laws and regulations, which includes a legally adequate privacy notice communicated from Customer. Customer may have the ability to access, monitor, use, or disclose Customer Data submitted by End Users through the Services. Customer will obtain and maintain any required consents from End Users to allow Customer’s access, monitoring, use and disclosure of Customer Data. Further, Customer will notify its End Users that any Customer Data provided as part of the Services will be made available to a third party as part of Google providing the Services.

Link to Google Cloud Storage terms.

Google App Engine requires a Privacy Policy

4.2 Privacy. Customer will protect the privacy and legal rights of its End Users under all applicable laws and regulations, which includes a legally adequate privacy notice communicated from Customer. Customer may have the ability to access, monitor, use, or disclose Customer Data submitted by End Users through the Service. Customer will obtain and maintain any required consents from End Users to allow Customer’s access, monitoring, use and disclosure of Customer Data. Further, Customer will notify its End Users that any Customer Data provided as part of the Service will be made available to a third party as part of Google providing the Service.

Link to Google App Engine terms.

Google AdSense requires a Privacy Policy

8. Privacy
Our privacy policy explains how we treat your personal data and protect your privacy when you use our Services. By using our Services, you agree that Google can use such data in accordance with our privacy policy.
You will ensure that at all times you use the Services, the Properties have a clearly labeled and easily accessible privacy policy that provides end users with clear and comprehensive information about cookies, device-specific information, location information and other information stored on, accessed on, or collected from end users’ devices in connection with the Services, including, as applicable, information about end users’ options for cookie management. You will use commercially reasonable efforts to ensure that an end user gives consent to the storing and accessing of cookies, device-specific information, location information or other information on the end user’s device in connection with the Services where such consent is required by law.

Link to AdSense terms.

Google AdMob requires a Privacy Policy

YOUR PRIVACY POLICY. If User is a publisher, User will have and abide by a privacy policy that discloses that third parties may be using cookies, web beacons, and other technologies to collect information as a result of ad serving through User’s Mobile Properties. If User collects, processes, or discloses location-based information in connection with the Services, User must follow a legal and appropriate method for obtaining explicit consent from User’s end users and make appropriate disclosures in User’s privacy policy.

Link to AdMob terms.

Google Maps API requires a Privacy Policy

3.3 Your Privacy Policy. You must post and abide by an appropriate privacy policy in, and will comply with all applicable laws relating to the collection of information from visitors to, Your Maps API Implementation in accordance with the specific requirements of Section 9.3 (End User Terms and Privacy Policy) below.

Link to Google Maps API terms.

How iubenda Can Help

Since iubenda’s inception more than a year ago we’ve helped create close to 70k privacy policies for websites and apps alike and have amassed over 130 pre-written clauses. Not surprisingly many of Google’s products have found their way in there.

Having said that, you can just create an account and add in Google AdSense, Google Analytics and AdMob clauses to your privacy policy. Then generate and publish the privacy policy with your Google clauses on your site, it’s as easy as that.

Generate privacy policy for Google products


Privacy Policy for AdWords RemarketingGoogle Analytics Remarketing Privacy PolicyPrivacy Policy for Google Analytics

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