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.
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”.
List of affected services
Backup on Google Drive
Beta by Crashlytics
Firebase Cloud Firestore
Firebase Cloud Functions
Firebase Cloud Messaging
Firebase Cloud Storage
Firebase Dynamic Links
Firebase Performance Monitoring
Firebase Realtime Database
Firebase Remote Config
Google Ad Manager Audience Extension
Google Ad Manager
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 App Engine
Google Calendar widget
Google Cloud Storage
Google Drive account access
Google Friend Connect
Google Maps widget
Google Play Beta Testing
Google Site Search with AdSense
Google Site Search
Google Tag Manager
Google Website Optimizer
Google+ +1 button and social widgets
Remarketing with Google Analytics
User ID extension for Google Analytics
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.
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.