There are two sides to this question from a legal perspective. But actually only one answer: YES.
- There is the legal side of it: Depending on where you are you may fall under European, American (Californian) or Australian privacy laws. The list could go on since most countries have some sort of privacy regulations that extend onto the web and mobile apps – and hefty penalties for non-compliance.
Most countries’ privacy laws require you to include the following information:
- What kind of personal data is collected;
- Describe how this information will be used by the company;
- Describe how this information will be transferred to third party companies;
- Provide instructions on how users can modify or delete their personal information;
- Provide instructions on how users can opt-out of future communications;
More information by Google taken from the AdSense policies:
“You must disclose clearly any data collection, sharing and usage that takes place on any site, app or other property as a consequence of your use of any Google advertising service. To comply with this disclosure obligation with respect to Google’s use of data, you have the option to display a prominent link to How Google uses data when you use our partners’ sites or apps.”
Children’s Online Privacy Protection Act (COPPA):
“If you implement any Google advertising service on a site or section of a site that is covered by the Children’s Online Privacy Protection Act (COPPA), (a) you must notify Google of those sites or sections of sites covered by COPPA using the tools found here: https://www.google.com/webmasters/tools/coppa, or the method for apps described here: https://developers.google.com/admob/android/targeting, and (b) you must not use interest-based advertising (including remarketing) to target: (i) past or current activity by users known by you to be under the age of 13 years or (ii) past or current activity on sites directed at users under the age of 13 years.”
Ideally you would tell the users what the service does in general and how you are using it.
What do you do now? You can either hire a lawyer, write your own policy or use iubenda’s generator right away to make your policy. The AdMob clause is a PRO service that you can easily access with a premium account. The Google Analytics clause falls under our free limits.
- Define the services and categories of data collection your app is making use of.
- Add the services (and categories of data collection like “have a contact form”) you are using to your policy. iubenda now takes care of your policy and generates it for you.
- You can either link to your policy or embed the text into your app.