UMP Sdk and compliance with Swiss laws

[Michael K]

Dear community,

I am in the process of implementing Google's CMP along with the UMP Sdk, as required by AdMob starting 16th January 2024. I understood that the consent form will only be shown, and the consent information applied, to users in the EEA (European Economic Area) and the UK.

Now to my question: As far as I know Switzerland is not part of the EEA, but has very similar laws to the EU's GDPR and thus also require consent from the users to show ads, store cookies, and so on. Is Google's CMP and UPM Sdk also extended to Switzerland, or do I need to separately request consent form users in Switzerland?

Thanks,

Michael

[Mobile Ads SDK Forum Advisor]

Hi,

Thank you for reaching out to us.

With regard to your concern, you may check this article (https://support.google.com/admob/answer/10833943?hl=en&sjid=3102670726744599599-AP). It mentioned that,  you can select non-personalized ads on the ad requests originating in the EEA, the UK, and Switzerland by tagging the ad request as non-personalized or by setting your account to non-personalized ads in the GDPR settings in Privacy & messaging. 

This message is in relation to case "ref:_00D1U1174p._5004Q2om2qw:ref"

Thanks,
 

Mobile Ads SDK Team

[Michael K]

Hi,

thank you for your reply, which is appreciated.

Do I understand this correctly then: Google soon requires publishers to implement a Google-approved CMP if they serve users in the EEA and UK, suggesting to use Google's own CMP and UMP SDK. However, when it comes to Switzerland (which has very similar privacy laws, but is not part of the EEA), the publisher still needs to implements its own consent request and manually implement the consent logic for ads. Thus two separate approaches must now be implemented.

To summarize:

• If the user is in the EEA and UK, the UMP SDK will show the consent notification, and implement the consent logic for any ads. The developer, apart from implementing the UMP SDK and CMP, does not need to interfere manually.
• If the user is in Switzerland, the consent request is not triggered by the UMP SDK. The publisher must implement a logic which detects the location as Switzerland, show a custom consent request manually, and must implement an ads-personalization logic manually (e.g. setTagForUnderAgeOfConsent(true) or similar)
• If the user is outwith the the EEA, UK or Switzerland, the UMP SDK does not trigger the consent request and no further action must be taken.

Did I understand this correctly?

Thanks,

Michael

[Mobile Ads SDK Forum Advisor]

Hello,

To answer your concerns:

• If the user is in the EEA and UK, the UMP SDK will show the consent notification, and implement the consent logic for any ads. The developer, apart from implementing the UMP SDK and CMP, does not need to interfere manually.

• • Correct. No action is needed as the UMP SDK will handle this.

• If the user is in Switzerland, the consent request is not triggered by the UMP SDK. The publisher must implement a logic which detects the location as Switzerland, show a custom consent request manually, and must implement an ads-personalization logic manually (e.g. setTagForUnderAgeOfConsent(true) or similar)

• • You may achieve this implementation by checking the status of the consent form. You do not have to detect the location of the user. You can refer to the following documents: 
    • https://developers.google.com/admob/ios/privacy/api/reference/Enums/UMPConsentStatus
    • https://developers.google.com/admob/android/privacy/api/reference/com/google/android/ump/ConsentInformation.ConsentStatus

• If the user is outwith the the EEA, UK or Switzerland, the UMP SDK does not trigger the consent request and no further action must be taken.

• • Yes. This is correct

[Julian Neil]

The OPs question about users in Switzerland still stands.  Does the form automatically get triggered for Swiss users?  If the consent form isn't triggered, checking the status of the form will not help in any way.

regards,

Julian

[Michael K]

Hi,

I have tested the UMP Sdk (2.1.0) using a Swiss IP address and the consent message did not show up, which contradicts the previous statement.

Will Google fix this and start showing the consent notification to Swiss users too?

Thanks,

Michael

Mobile Ads SDK Forum Advisor schrieb am Mittwoch, 4. Oktober 2023 um 16:07:38 UTC+2:

Hi, 

Thank you for getting back to us.

Yes, the consent form automatically gets triggered for Swiss users also.

[Mobile Ads SDK Forum Advisor]

Hi,

Thank you for contacting the Mobile Ads SDK Support team.

I will check with our team regarding your query and one of my team members will reach out to you once we have an update on this. Meanwhile, your patience is highly appreciated. 
 

This message is in relation to case "ref:!00D1U01174p.!5004Q02om2qw:ref"

Thanks,
 

Mobile Ads SDK Team

[Mobile Ads SDK Forum Advisor]

Hi Michael,

GDPR form requirements applies to countries in the EEA and UK. The country of Switzerland is not a part of this area. The UMP SDK handles the presentation of the consent form automatically and will show or not show the consent form if it is required per GDPR.

Thanks,
Justin

ref:!00D1U01174p.!5004Q02om2qw:ref

[Michael K]

Hi Justin,

thanks for your reply, so now it is clear: no consent form is shown to Swiss users.

The reason I came up with this question is because the consent form by the UMP Sdk is shown not only to EEA users (where the GDPR applies), but also to UK users, which technically are not subject to the GDPR, but a very similar "Data Protection Act 2018".

Now, Switzerland has also a very similar data protection law aligned to the GDPR (named revDPA), so I thought Google has included Switzerland as well in their geographic scope for prompting the consent form.

Thanks for the clarification.

Kind regards,

Michael

[Suraj Kumar G R]

I'm getting consent popup when connected to USA ?
How to avoid this ?

Regards,

Suraj

[Mobile Ads SDK Forum Advisor]

Hi Suraj,

What does "Connected to USA" mean?

Few things to consider:

• Have you set the DebugGeography to EEA?
• Does the consentStatus value = REQUIRED?
• Have you followed our implementation guide?

If you're using a VPN to connect to USA that likely will not work as expected. If you want to to simulate being in the USA you can set DebugGeography to NOT_EEA.