Google AdMob and Google Analytics for Firebase GDPR Compliance.

[Jamie Corkhill]

Hello.

I have been building a mobile game in Unity, and I am almost ready to release it to the Play Store and the App Store.

I have created a privacy policy with Iubenda, and now I need to focus on advertising and analytics. Since children could be using the application, I thought I would provide a one-time dialog box that asks whether the user will consent to personalized advertising, non-personalized advertising, or wish to use the premium version of the game. Users may withdraw consent at any time, and this dialog box will also provide a link to the privacy policy. Also, how does meditation fit into this flow?

In terms of Google Analytics for Firebase, I was unsure about whether I have to explicitly ask the user for consent, or if I can just tell the user that I am employing Firebase Analytics, and provide opt-out features in settings. I'm worried that explicitly asking the user for consent will lead to most people choosing not to, which will lead to me having little to no data in the Firebase Console.

My problems are not only with Unity. I am a 16-year-old developer, I don't have all the resources in the world for legal counsel, and I have multiple full stack web and mobile applications I am planning to release through the next year, but I can't seem to find any good information on maintaining ColPPA, COPPA, and GDPR compliance. Google Firebase and AdMob documentation do not seem to discuss concrete implementation guidelines in Java, Swift, or C# for specific platforms.

Are any other developers facing similar hindrances?

Thank you for your time, and any help would be greatly appreciated.

Jamie

[Ewan Benfield]

Hi

I spent a couple of days reading about privacy policies, GDPR etc and decided to write my own policy rather

than rely on a policy generator.

My conclusion (I'm not a lawyer and this is not a recommendation) was to continue to use a sign-in

dialog on the first open of the app which links to privacy and terms and explicitly requires user opt-in. I

haven't tracked how many users reject the terms and abort installation and haven't received any

feedback about it. You can soften the blow with welcoming the user etc!

I added an obvious option to open the privacy policy from Settings and also made sure that the

privacy policy clearly alerts EU users that their data may (almost certainly will)  leave the EU when they

use the app. I also link to the relevant Firebase T&C from the policy and to Google's catch-all 

indemnification page.

You can read the policy on the listing here: https://play.google.com/store/apps/details?id=uk.co.telesense.tm.free

Hope that helps.

Ewan

[Jamie Corkhill]

Thanks for your help. Perhaps writing my own privacy policy is the way to go then. That way I don't have to pay a yearly subscription to Iubenda.

I assume, if you are the UK, that an Ltd is similar to LLC in the United States. Is Deductive Systems your company, and do you use the Ltd to limit liability toward your assets in the event of lawsuits, etc.?

Do you display your consent dialog across all users in all locations, or do you limit it to users in the EEA? Since you are working with Android and Java, I believe the Google Consent SDK has such a feature.

My main problem is that I am trying not to overwhelm users with a long on-boarding process. 

Thank you for your response,

Jamie

[Ewan Benfield]

No problem, I wouldn't worry too much, just put together T&C and a privacy policy and try not to infringe any obvious trademarks in your app title.  When you make it to #1 you can pay a smart lawyer for a legal health check!

Best of luck with your app.

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