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Place of Processing Customisation for Google Services

As of January 22nd, 2019, Google has updated the contracting party for all their services from Google LLC to Google Ireland Limited for all instances where End-users are based in the the European Economic Area (EEA) or Switzerland.

Below you’ll find highlighted portions of the notification email sent by Google.

Hello Administrator,

This email is to inform you about changes in our end-user facing Terms of Service and Privacy Policy for your users in the European Economic Area (EEA) or Switzerland that may affect and be noticed by users in your domain [redacted] as they access some of the Google Additional Services . . . For users in your domain that are based in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or Switzerland, starting January 22, 2019, services offered under the end-user facing Terms of Service will be offered by Google Ireland Limited instead of Google LLC. . . we’re also updating Google’s Privacy Policy for the Additional Services. The new policy specifies that Google Ireland Limited will be the data controller responsible for these users’ information and for complying with applicable privacy laws (unless otherwise stated in a service-specific privacy notice).

You can read Google’s updated Terms here.

Do these changes affect you?

These changes may be applicable to you if you or any of your Users are based in the European Economic Area (EEA) or Switzerland.

Here some examples of when this change may apply to you:
  • You’re based in the European Economic Area (EEA) or Switzerland and have EEA or Switzerland-based users.
  • All your users are based in the European Economic Area (EEA) or Switzerland, regardless of where you are based.
  • You’re based outside the European Economic Area (EEA) or Switzerland, e.g the US, and your users are based both in the US and the European Economic Area (EEA) or Switzerland.

*If you’re not sure if you may have EEA or Switzerland based users, it’s best to err on the side of caution and assume that it applies to you as well.

As quoted above, Google’s changes automatically apply to all your EEA and Switzerland-based end-users, regardless of where you are based.

What do you need to do?

Because you’re legally required to correctly identify third-party processors, we strongly suggest that you update the clauses in your policies that are related to affected Google services to include “Google Ireland Limited”.

  • AdMob
  • Android Pay
  • Backup on Google Drive
  • Beta by Crashlytics
  • Blogger
  • Crashlytics
  • Fabric Answers
  • FeedBurner
  • Firebase Authentication
  • Firebase Cloud Firestore
  • Firebase Cloud Functions
  • Firebase Cloud Messaging
  • Firebase Cloud Storage
  • Firebase Dynamic Links
  • Firebase Hosting
  • Firebase Invites
  • Firebase Notifications
  • Firebase Performance Monitoring
  • Firebase Realtime Database
  • Firebase Remote Config
  • Google Ad Manager Audience Extension
  • Google Ad Manager
  • Google AdSense
  • Google Ads Remarketing
  • Google Ads Similar Audiences
  • Google Ads conversion tracking
  • Google Analytics Advertising Reporting Features
  • Google Analytics Demographics and Interests Reports
  • Google Analytics for Firebase
  • Google Analytics with anonymized IP
  • Google Analytics
  • Google App Engine
  • Google Calendar widget
  • Google Cloud Storage
  • Google Drive account access
  • Google Fonts
  • Google Friend Connect
  • Google Maps widget
  • Google OAuth
  • Google Pay
  • Google Play Beta Testing
  • Google Signals
  • Google Site Search with AdSense
  • Google Site Search
  • Google Tag Manager
  • Google Website Optimizer
  • Google reCAPTCHA
  • Google+ +1 button and social widgets
  • Remarketing with Google Analytics
  • User ID extension for Google Analytics
  • YouTube OAuth
  • YouTube button and social widgets
  • YouTube video widget without cookies
  • YouTube video widget

If you’re based outside Europe and have users from both outside and within the EEA and Switzerland, you should consider adding both “Google Ireland Limited” and “Google LLC” using the method detailed below.

Changes to your Privacy Policy

To edit, simply go to the relevant site area in your iubenda dashboard and click on the “Edit” button for your privacy policy.

Next, click the pencil icon on the service you’d like to edit and simply click inside the “Select the region” field in order to update the information.

Click on “Save and Close” and you’re done.

Changes to your Cookie Policy

If you’re using a cookie policy generated by iubenda (pro feature), your cookie policy will be automatically updated to reflect the changes made in your privacy policy.

If you’re using an externally prepared cookie policy, you may need to seek legal assistance in order to manually update the relevant information.