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Privacy Policy for Google Ads Remarketing

Google Ads Remarketing is a powerful tool that allows you to further enhance your marketing efforts by giving you the ability to reach people who previously visited your website or app. However, using this feature also comes with its specific privacy-related responsibilities.

Under the vast majority of global legislations you must explicitly inform your users of the fact that you gather information for these purposes on your website.

In addition to the legal requirements, Google also expressly requires that you disclose any remarketing activity to your end users.

In Google’s words:

When you use the remarketing 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.

So what does this mean in practical terms? What do you have to do?

If you want to ensure that you comply with Google’s terms ( and with the law) you’ll need to:

  1. Create a legally compliant privacy policy. Read the specifics below.
  2. Ensure that the privacy policy includes clauses specific to the processing activities handled via Google Ads Remarketing.
  3. Include a cookie policy. From the quote above, you’ll note that in addition to the general privacy policy requirement, Google further requires that you include notice of your use of cookies as well.
  4. Handle cookies and consent to cookies in a legally compliant way. This generally means informing users of the use of cookies (as mentioned in the previous point), obtaining consent to the use of cookies and maintaining proof of that consent. One Analytics feature that may help with the consent requirement here is the IP Anonymization feature, however, you’re still required to inform users in a conspicuous and detailed way, about the use of even these cookies. Furthermore, the use of cookies may be considered “monitoring behavior” under the GDPR, even where those cookies are anonymized statistical cookies. Therefore, it is recommended that you block cookies prior to obtaining express consent, by default.
Google Consent Mode

To help advertisers manage cookies for analytics and advertising purposes, Google has introduced Consent Mode, a feature that allows you to avoid prior blocking for Google Analytics and Google Ads (including Google Ads Conversion Tracking and Remarketing).

Learn how to implement it with our Cookie Solution.

Generally, the national/regional laws of your base of operations will apply, as well as (in many cases), the laws governing the regions in which your users are based. This can be quite tricky online, as, unless you’re actively blocking some regions, you may need to address requirements across geographical boundaries and legal jurisdictions.

For this reason, it’s always the best idea to handle these activities with the strictest applicable regulations in mind (currently European Law, mainly the GDPR and Cookie Law).

Example outline of a privacy policy for Google Ads Remarketing

While the exact required contents of a privacy policy will vary depending on the law applicable to you and all your specific processing activities, in general, a compliant privacy policy that’s also valid for Google Ads Remarketing activities should contain:

  • site/app owner details;
  • description of what data is being collected; 
  • the Legal basis for the collection (GDPR-specific but may likely apply to you);
  • which third-party have access to the data (include Google here);
  • for which specific purposes are the data collected — including third-party purposes (e.g analytics, marketing activities such as remarketing);
  • user rights in regards to their data;
  • information related to cross-border data transfer (if applicable);
  • your notification process for policy changes;
  • the effective date of the privacy policy; and
  • a cookie-related section (also known as the “cookie policy”).

See our post on the Elements of a Privacy Policy for a more detailed list of basic privacy policy requirements.

Important

The exact required contents of your privacy policy depends heavily on your processing activities, law of reference and may even need to address requirements across geographical boundaries and legal jurisdictions.

You can read more about determining your law of reference here or read our in-depth Legal Overview Guide here.

How to create a privacy policy for Google Ads Remarketing

Because a valid privacy policy must always be up-to-date and specific to your own particular situation, it can be a both legally and technologically difficult to write a compliant policy yourself.  Here’s where our Privacy and Cookie Policy Generator comes in very handy: with hundreds of available clauses, our privacy policies contain all elements commonly required across many regions and third-party services (including Google products), while applying the strictest standards by default – giving you the option to fully customize as needed.

Our policies are created by lawyers, monitored by our lawyers and hosted on our servers to ensure that they are always up-to-date with the latest legal changes and third-party requirements.

Creating a privacy policy for Google Ads Remarketing is straightforward and intuitive:

  • Enter the name of your website or app and start generating
  • Add any service you may be using. In this case, it will be “Google Ads Remarketing
    Add 'Google Ads Remarketing' service
  • Fill out your web/app owner and contact details
  • Add the iubenda Privacy Policy to your site (a best practice is to link to your privacy policy from your footer, where your users or visitors can find it at any given time)
Note

Analytics services use various techniques to track user behavior and must be mentioned in the privacy policy. Add “Google Ads conversion tracking” clause if you use this analytics service. Conversion tracking services are useful for understanding the impact of your advertising spend on a given network.

For more guidance on selecting services or  how to structure your privacy policy read How to Generate a Privacy Policy.

Create a privacy policy for Google Ads Remarketing

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See also