BY INSTALLING THE APPS/GAMES ON YOUR MOBILE DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING, AND/OR USING THE GAMES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY. PLEASE NOTE: IF YOU OR, AS APPLICABLE, YOUR LEGAL GUARDIAN, DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT INSTALL, ACCESS, AND/OR USE THE GAMES AND YOU ARE REQUESTED TO PROMPTLY ERASE THEM, AND ANY PART THEREOF, FROM YOUR MOBILE DEVICE.

What features we use

Our Apps features provided by mobile device, and don't collect any information from user.

Links to third-party websites and services

The Games may contain links to other websites and online services, including third-party advertisements. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that websites or service, and not to this Privacy Policy. We do not share your data with third-party websites or services, and the fact that a link to such website or service does not appear in the Apps. You agree that our application will have no liability for any matters relating to a third-party website or service that you provide information to, including their collection and handling of that information.

From the Developer Console Help: 

Adding a privacy policy to your app’s store listing helps provide transparency about how you treat sensitive user and device data.

The privacy policy must, together with any in-app disclosures, comprehensively disclose how your app collects, uses and shares user data, including the types of parties with whom it’s shared. Google is unable to provide you with legal advice and you should consult your own legal representative.

  • For apps that request access to sensitive permissions or data (as defined in the user data policies): You must link to a privacy policy on your app’s store listing page and within your app. Make sure your privacy policy is available on an active URL, applies to your app, and specifically covers user privacy.

  • For apps in the Designed for Families program: You must link to a privacy policy on your app’s store listing page and within your app, regardless of your app’s access to sensitive permissions or data. Make sure your privacy policy is available on an active URL, applies to your app, and specifically covers user privacy.

  • For other apps: You’re not required to post a privacy policy.

In other words, it is very unlikely that you are not covered by any of the requirements set out either by the Platform (Play Store), third party service providers or any of the privacy regulations. How do you add and edit that privacy policy on the Play Store?

3) How do I add/edit my privacy policy on the Play store? (source)


  1. Log into your Google Play Developer Console

  2. Next, select All Applications and select the application whose privacy policy you’d like to edit.

  3. After that, select Store Listing.

  4. Then, scroll to the section marked Privacy Policy and enter the URL where you have the privacy policy hosted online – generate your privacy policy here.

  5. Lastly, be sure to click Save or update.

4) What if I don’t want to add a privacy policy at this time?

If you do not want to add a privacy policy at the moment very first moment you create the app, you can check the box next to Not submitting a privacy policy URL at this time (see screenshot above) on the Store Listings screen of your application in the Follow the instructions above to view that screen.

5) What if I’m using sensitive/dangerous Android permissions?

Google has started to enforce proper privacy policy disclosures for sensitive permissions in apps (or also if your app makes use of any user data at all, for instance using Admob). A good example of a data type are location permissions that allow accessing the device location such as follows:


Design pattern supplied by the Permissions Pattern Library

You might be using other dangerous/sensitive permissions like access to the camera, contacts, audio, accounts and phone state. In this case you are required to have your privacy policy in place properly and also incorporate text disclosing your use of these permissions.

If any of the following permissions look familiar to you, check out the guide for incorporating these permissions into your privacy policy:

  • READ_CALENDAR

  • WRITE_CALENDAR

  • CAMERA

  • READ_CONTACTS

  • WRITE_CONTACTS

  • GET_ACCOUNTS

  • ACCESS_FINE_LOCATION

  • ACCESS_COARSE_LOCATION

  • RECORD_AUDIO

  • READ_PHONE_STATE

  • CALL_PHONE

  • READ_CALL_LOG

  • WRITE_CALL_LOG

  • ADD_VOICEMAIL

  • USE_SIP

  • PROCESS_OUTGOING_CALLS

  • BODY_SENSORS

  • SEND_SMS

  • RECEIVE_SMS

  • READ_SMS

  • RECEIVE_WAP_PUSH

  • RECEIVE_MMS

  • READ_EXTERNAL_STORAGE

  • WRITE_EXTERNAL_STORAGE

Of course, do not forget that these sensitive permissions aren’t the only trigger for a privacy policy requirement.

6) About Prominent Disclosure requirements

This part in Google’s User Data policy is key: “If your app collects and transmits personal or sensitive user data unrelated to functionality described prominently in the app’s listing on Google Play or in the app interface, then prior to the collection and transmission, it must prominently highlight how the user data will be used and have the user provide affirmative consent for such use.“

If you collect and transmit personal or sensitive user data unrelated to functionality described prominently in the app’s listing on Google Play or in the app interface with your app, then you need add prominent disclosures. You can read more about prominent disclosures it here.


8) How to actually write a privacy policy for your Android Google Play app

Since iubenda and mobile apps are international practically by definition, let us take some hints from two relevant diverse entities far apart from each other:

“Privacy on the Go” by the Attorney General of California and the “Orientierungshilfe zu den Datenschutzanforderungen an App-Entwickler und App-Anbieter” the document produced by the German data protection agencies (which we’ll summarize in English).

From Privacy on the Go:

  • “Make the privacy policy clear and understandable by using plain language and a format that is readable on a mobile device”

  • “One format is a layered notice that highlights the most relevant privacy issues.”

  • “Another format is a grid or “nutrition label for privacy” that displays your privacy practices by data type.”

  • “Graphics or icons can help users to easily recognize privacy practices and settings.”

  • “Privacy icons will be most effective if they are widely used and consumer comprehension is supported by an awareness campaign.”

The most important takeaway is, that it is ok, even encouraged, to be creative. Don’t forget to back the creativity up with the actual readable full version of your policy.

Questions And Feedback

We welcome your questions, comments, and concerns about privacy. Please contact us by email at androdigitaldreams@gmail.com

Comments

Post a Comment