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GP - EU user consent policy

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  • edited September 2015
    @hendrixs: I've already responded to you privately in support, but I thought I'd address your points here as well.

    A bad link should not crash, so I will look into that, however the consent and license agreement dialogs definitely support hyperlinks. Make sure you are using a correct URL that includes the protocol such as "http://" -- we tested that it works when you use a correct URL on several devices before launch.

    As for the EU check not detecting that you're in the EU, I've asked for more information in support in order to investigate that further, but it's possible that the check can determine you're not in the EU even if you are, depending on how your device is configured. For example, if you were using a SIM card from a network provider that states it is outside the EU, or if you were assigned an IP address that is outside the EU (or did not have internet access), or if you have your device configured to use English US as its language, then it may not be able to detect that you are in a country that requires consent.

    It's also possible the EU check was already performed previously, so make sure you clear data for the app before launching it, to correctly test the "first launch" case.

    In order to avoid needing location permissions, the EU check uses the carrier SIM network info if it's a GSM network, or an IP lookup if possible, or the device locale (user language setting). This will not be 100% accurate in all cases, but it should be sufficient.

    Keep in mind that the expectation is that you will do what is commercially feasible in order to comply. We chose this route because adding scary GPS location permissions to all your apps worldwide just so they can accurately decide whether to show a cookie notice that will almost certainly be ignored by anyone who sees it does not seem very commercially feasible. :) It also seems incorrect/ironic that something intending to address the user's right to privacy would need access to their physical location.

  • @sylviathewitch
    It's possible the term "consent" could be interpreted to mean explicit or implied consent. As described in the KB article Darryl linked to, which type of consent you need depends on whether the information being collected is anonymous or could potentially be used to identify the user. This is based on reading through various EU privacy policy documents and guidelines (not just cookiechoices.org which really isn't very helpful at all IMO).

    Of course, it goes without saying that like Google, we cannot offer legal advice in any shape or form; if you are concerned about compliance you may want to consult with a qualified lawyer.

  • Hi guys,

    I have already updates about 80% of my apps.
    EU vs non EU is working fine for me.
    I have tried with VPNs on my devices and friends of mine in the US tried is as well.
    Everything is looking good.

    Also no problems with the link/html in the launch notice.
    My text looks like this:

    We use device identifiers to personalise content and ads, to provide social media features and to analyse our traffic. We also share such identifiers and other information from your device with our social media, advertising and analytics partners. <a href="http://mydomain.com/cookies.html" target="_blank">See Details</a>.


    By the way, I do not really see any decrease in installs or increase in deinstalls from EU users.
    So far so good :-)

    @lorne ... I am going with the "info only" for now. From what I have seen around the web "implied consent" should be good enough. Thanks anyway!
  • @lorne: Thanks for the detailed reply and to super speedy response in support. Also a big shout-out to @colin who responded within minutes. But just as I posted the message on the forum and on support, I packed my laptop and went on a bit longer trip and this is the first time my laptop is powered up again. :) Sorry about that.

    I'll read everything and respond. Thanks!
  • @lorne: I've responded in the support. It's very sleek how you addressed the detection of EU users. It's more advanced that most of the solutions I've seen on the forums. Kudos on that!

    @sylviathewitch: Nice to see you back! :) And good to hear that it did not affect the number of installs. I've installed over 40 apps the other day in Genymotion and I didn't see a single notification yet. And all those apps were recently updated (in the last day or two) and from big publishers. I just wanted to see their version of the message. So far no luck.
  • I am an EU user yet I see no popup with the launch notice when I add it in an app.
    I will keep trying but it might be that my device got no SIM (tablet)?
    Or could it be that the language isnt set to my native but to English?
  • edited September 2015
    @anteos, what country are you in? (Could you open a support ticket so I can ask you some more specific questions?)

    On devices without a GSM network SIM, the location will be determined based on IP address (if internet access is available) or the user's locale setting. If it reaches the locale check and you have it set to English (US) you will not see the launch notice, however if you have it set to English (UK) you will. Note that the check is only on the very first launch of the app, so you will need to Clear Data for the app if you want to change your settings and re-test.

    BTW, I think I've figured out the issue for users in Slovenia and Greece. If anyone in another country is having an issue, please contact us in support so we can investigate it further. Thanks!
  • @lorne: Thanks for the test APK in the support. Now it works flawlessly! :)
  • edited September 2015
    @lorne
    Thanks for the fix too!

    Is there need for an Andromo update or we are good to go now?
  • @anteos
    The fix will go live in the next version of Andromo (4.4.2).
  • @lorne

    OK, wonderful. Thanks!
  • Guys where do you point in the URL?
    You have a site that you link to, and if it is your own what do you have in there?
    Could you please elaborate? Now I feel dumb to delay this thing so much.
  • @anteos: Yes, I put up a privacy policy on my website. This will help for the contents of you PP:

    https://www.freeprivacypolicy.com/ (very good)
    http://www.docracy.com/doc/search?query=mobile+app&s-submit=Submit+Query (some extra ideas)

    Just try to make it as good as you can and that's it.

  • @hendrixs
    Thanks for the help.
    I managed to dig out some PP I had from the Nov 2013 times (when we all got 7 days notifications).
  • edited September 2015
    I have linked my Facebook page in my app.
    A privacy statement for the use of Facebook Plugins is included in my appeal.
    Does anyone of you know, if I still must obtain the consent of the end user separately?
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