I'm afraid most users won't give consent for both type of ads (personalized / non personalized)

[Michal]

Hello,

I have many Android games which are ad supported. Ads income is my only income. There are no paid version of those apps or in game payments.

So, according to this: https://support.google.com/admob/answer/7666366

Even non personalized ads requires consent from users:
"Although these ads don’t use cookies for ads personalization, they do use cookies to allow for frequency capping, aggregated ad reporting, and to combat fraud and abuse. Consent is therefore required to use cookies for those purposes from users in countries to which the ePrivacy Directive’s cookie provisions apply."

And according to this: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=623051

consent must be free

"
The element “free” implies real choice and control for data subjects. As a general rule, the GDPR
prescribes that if the data subject has no real choice, feels compelled to consent or will endure
negative consequences if they do not consent, then consent will not be valid. If consent is bundled
up as a non-negotiable part of terms and conditions it is presumed not to have been freely given.
Accordingly, consent will not be considered to be free if the data subject is unable to refuse or
withdraw his or her consent without detriment. The notion of imbalance between the controller
and the data subject is also taken into consideration by the GDPR
"

So, if consent need to be valid, user has to have choice. So i understand he must be able to deny consent
(so there should be yes / no buttons or smth like that). If he clicks no, he will be having ad free version.

In that case, i can't close app too because "will endure negative consequences if they do not consent".

Also, i can't describe in Google Play that it's ad supported version and user need to give consent for ads or
download paid version instead, because "If consent is bundled
up as a non-negotiable part of terms and conditions it is presumed not to have been freely given"

So, in my opinion basing ad displaying on Consent (which should be free) means that we will loose 90% of income
from EU users. I really doubt players will enable ads if they will have free choice (and choice must be free so consent
can be valid).

What do you think?

[mobileadssdk-a...@google.com]

Hi Michal,

The Consent SDK provides up to three options on the consent dialog, these are:

1) Personalized ads

2) Non-personalized ads

3) Ad free

The first two constitute consent to show ads to the user (personalized or non-personalized as the case may be).

The third option is up to you. A common use case will be to send the user to the store listing for the premium version of your app.

I'm not able to advise what strategy your app should take and whether this constitutes compliance from the point of view of GDPR, I can only advise what options you have with the Consent SDK to help you be compliant.

Regards

Sam

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