Data Safety Form (sharing, and deletion)

[Sergio]

Hello.

We have 2 concrete questions to ask about the Google Play Data Safety Form when using AdMob SDK:

1. I understand that the data is collected, right? But, is the data shared as well? As I read here, data is not considered as shared when it's transferred to a service provider, or when the data is anonymous. Is AdMob considered a service provider, or is the data anonymous? 
2. Seeing in the app store listing that users cannot request their data deletion is not a good thing. I would like to allow them, but I don't know how. I read here and here that revoking consent is the same as data deletion for AdMob, right? As I'm not using UMP SDK (I'm using a custom dialog), how can I allow the user revoking consent? Is there any way we (developers) can tell the users how can they remove their data (or revoke their consent)?

We would be very grateful if you could help us with these 2 questions.

Thank you, and best regards,

Sergio.

[Mobile Ads SDK Forum Advisor]

Hi Sergio,

Thank you for reaching out to us.

As per our documentation for Google Play's data, the Google Mobile Ads SDK collects and shares the following data types automatically for advertising, analytics, and fraud prevention purposes. You may check the list on this link for the data collected and shared automatically. Kindly note that, all of the user data collected by Google Mobile Ads SDK is encrypted in transit using the Transport Layer Security (TLS) protocol.

Then for the revoking of consent, you've mentioned that you're not using UMP SDK, can you confirm if you're using Funding Choices with custom dialog? If yes, you may check this article as it mentioned about the revoking of consent. In addition to that, you may reach out to the Product Support Team to assist you better on this. 

Regards,

Princess Pamela Mobile Ads SDK Team

 

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[Sergio]

Hello,

Thank you for your fast reply.

We read the documentation you linked, and we understand that AdMob collects and shares data. But, the question is: Is AdMob considered a service provider, or is the data anonymous? Because if the answer is yes, as per Google documentation, then we do not need to disclose it as “sharing”.

About revoking consent, we are not using Funding Choices. We are using the consent library to detect if the user is in EEA, and then we are requesting consent using a custom dialog. 

Anyway, we don't understand what revoking consent is. I mean: at app start we obtain the user consent, and then, if the user wants to revoke it: what we should do? Is there any method in the SDK that we can call to revoke the consent? Does revoking consent delete the data associated to the user?

Please, we would like to know the answers so we can use your SDK correctly.

Best regards,

Sergio.

[Mobile Ads SDK Forum Advisor]

Hi Sergio,

Thank you for getting back to us. Allow me to assist you in this.

Google considers ads to be personalized when they are based on previously collected or historical data to determine or influence ad selection, including a user's previous search queries, activity, visits to sites or apps, demographic information, or location. Specifically, this would include, for example: demographic targeting, interest category targeting, remarketing, targeting Customer Match lists, and targeting audience lists uploaded in DoubleClick Bid Manager or Campaign Manager. If your agreement with Google incorporates this policy, or you otherwise use a Google product that incorporates this policy (In your case, using our product - Mobile Ads SDK), Given this, AdMob considered a service provider and you must ensure that certain disclosures are given to, and consents obtained from, end users in the European Economic Area along with the UK.

We would recommend to view the following documents below:

• https://www.google.com/about/company/user-consent-policy/
• https://www.google.com/about/company/user-consent-policy-help/
• This linked article contains information regarding personalized and non-personalized ads and provides the details of which data is used in the two different scenarios. The data is used for ad serving. 
• https://support.google.com/ads/answer/1660762?visit_id=638007479701042647-3454676820&rd=1

Regards,

Teejay Wennie Mobile Ads SDK Team

 

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[Sergio]

Thank you for your reply.

So, AdMob is considered a Service Provider, right? Then, as per Google documentation, data is not considered as shared.

About the other question, the option for revoking consent (this is offering only non-personalized ads by sending "npa" in the request to your SDK) is considered data deletion, right?

Best regards,

Sergio.

[Mobile Ads SDK Forum Advisor]

Hi Sergio,

If you're referring to resetting consent state, then yes. It is considered as deletion.

[Sergio]

Thank you for your answer.

Last question: If I am not using UMP, resetting consent is the same as not allowing personalized ads, right? This is, sending "npa" with the request.

Best regards,

Sergio.

[Mobile Ads SDK Forum Advisor]

Hi Sergio,

Yes, you're correct.

[Sergio]

Thank you very much for answer my questions. Have a nice day!

Best regards,

Sergio.

[markus.w...@gmail.com]

So calling consentInformation.reset() would be considered as deletion of the collected data, do I understand this correctly? And we could answer the question "Do you provide a way for users to request that their data is deleted?" in the consent form with yes, correct?

Let me also note that the documentation states that reset() is intended to be used for testing purposes only. Are you saying that we should use it in production for this purpose? The documentation does not state that any data gets deleted, so is your answer that resetting consent state is considered as deletion even accurate and authoritative?

Also, you (Google AdMob) share the user information with dozens, if not hundreds, of other companies. Will this shared information also get deleted by calling this method?

Regards,

Markus

[H D]

Yes

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[Mobile Ads SDK Forum Advisor]

Hi Markus,

Thank you for contacting us.

Kindly note that consentInformation.reset() resets the ConsentInformation to initialized status. The document only provides that by calling reset - it resets the consent status, which sets the ConsentStatus as 0(UNKNOWN) from the current state. canRequestAds holds the value of False until the following steps have been done. Hence resetting will trigger the application to display the consent form again as Consent status set to 0.

Kindly follow ConsentInformation.ConsentStatus article for further information regarding consent status.
 

This message is in relation to case "ref:!00D1U01174p.!5004Q02f2ZuH:ref" (ADR-00152524)

Thanks,
 

Mobile Ads SDK Team