Documentation

How to Update Your Privacy Policy for Google Analytics’ Enhanced Advertising Features

Using Google Analytics requires you to maintain an updated Privacy Policy which is on par with the applicable law and which also meets Google’s requirements.

Here’s an overview of what Google had to say:

If you’ve enabled any Google Analytics Advertising features, you are required to notify your visitors by disclosing the following information in your privacy policy: the Google Analytics Advertising Features you’ve implemented; How you and third-party vendors use first-party cookies; How visitors can opt-out of the Google Analytics Advertising Features you use; . . . We also encourage you to point users to Google Analytics’ currently available opt-outs for the web.

When using Google Analytics Advertising Features, you must also comply with the European Union User Consent Policy.

If you’ve enabled interest-based advertising, including Remarketing, with Google Analytics in connection with other Google services, you must follow the policies applicable to those Google services (like the Google Ads Policy for Personalized advertising and its sensitive category restrictions, and the Platform Program Policies). If you use Google Analytics to collect sensitive information about your visitors, as described in the Google Ads sensitive category restrictions, you may not use Google Analytics to collect data for the purpose of interest based advertising.

There are, however, specific additional requirements which apply when using Google Analytics’ enhanced advertising features such as Remarketing; Google Display Network Impression Reporting; Demographics and Interest Reporting; integrated services that require Google Analytics to collect data for advertising purposes (including the collection of data via advertising cookies and identifiers); and the User-ID feature.

The following are are practical suggestions for making your website or app compliant when using advanced Google Analytics features.

Adding clauses to cover Google Analytics advertising features

iubenda’s privacy and cookie policy generator makes the following standard services available to meet the individual disclosure requirements of the various Google Analytics advertising features:

  • Display Advertising extension for Google Analytics” – in which you outline that you’ve activated display advertiser features such as the use of demographics and interest data for your analytics reports.

  • Remarketing through Google Analytics for Display Advertising” – in which you outline that you connect tracking activity performed by Google Analytics and its cookies with the Google Ads network.

  • Google Ads Remarketing” – in which you outline that traffic on your site gets connected to the Google Ads network for remarketing purposes.

  • Google Ad Manager Audience Extension” – in which you outline that the traffic on your site gets connected to the Google Ad Manager network for remarketing purposes.

  • User ID extension for Google Analytics” – a feature used for associating multiple sessions with a unique ID.

Example

For example, if you define your remarketing lists via Google Analytics and run the campaign via Google Ads, you would add “Display Advertising extension for Google Analytics”, “Remarketing through Google Analytics for Display Advertising” and “Google Ads Remarketing” to your iubenda privacy policy.

Meeting the Requirements of Google’s “EU user consent policy”

Once you’ve added the clauses on Google Analytics advertising features, we suggest that you also take a look at Google’s European Union User Consent Policy. This Google policy lists additional requirements specific to how you must handle data and consents of end users based in the European Economic Area, and compliance with it is vital. Google states:

If your agreement with Google incorporates this policy, or you otherwise use a Google product that incorporates this policy, you must ensure that certain disclosures are given to, and consents obtained from, end users in the European Economic Area. If you fail to comply with this policy, we may limit or suspend your use of the Google product and/or terminate your agreement.

How you can meet these requirements

Meeting the requirements of Google’s EU Consent Policy and the related EU regulations is a simple two-part process involving both the Privacy and Cookie Policy Generator and the Cookie Solution.

Privacy and Cookie Policy Generator

Firstly, you’ll need to make additional disclosures specifically related to your use of cookies. These disclosures are done via a dedicated section of your privacy policy known as the cookie policy.

With our Privacy and Cookie Policy Generator, you can add a cookie policy containing the relevant disclosures in a single click. The cookie policy is automatically generated from the information already provided in the privacy policy and automatically integrates into the Cookie Solution.

Cookie Solution

Once installed and configured, the Cookie Solution then:

  • displays a notification banner and integrates a cookie policy to properly inform users as required;
  • blocks the installation of cookies until user consent is obtained;
  • allows you to demonstrate proof of consent; and
  • allows you to ‘remember’ user consent for up to 12 months.

You can read more about the Cookie Solution here or click here get started with the Cookie Solution.

See also

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