Why does blocking personalised ads cause Google to not show the UMP consent form and how to request user consent in this case?

[emberr]

Hi,

To comply with GDPR we must still request permission from users to show basic non-personalised ads.

However I am struggling to understand how this is achieved with UMP.

1) The Admob GDPR interface notes that the user consent message will not display on the app if personalisation is disabled. Does this mean I actually cannot use UMP at all to request user consent for showing basic ads using a form and have to make one myself?

2) I have tested the consent form and if personalisation is enabled in Admob GDPR settings and personalised ads are enabled on my phone/Google account, then the form shows fine since Form Status is "Available". 

However, if personalised ads are disabled on my phone/Google account then the Form Status becomes '"Unavailable" and there is no way to request a form. In this instance, how do I request consent from users to show basic / non-personalised ads if the form is unavailable?

Thanks

[emberr]

Hi I would greatly appreciate some assistance, thanks

[Mobile Ads SDK Forum Advisor]

Hello Ember,

Thank you for reaching out to us.

Kindly check below the answers for your questions.

1) The Admob GDPR interface notes that the user consent message will not display on the app if personalisation is disabled. Does this mean I actually cannot use UMP at all to request user consent for showing basic ads using a form and have to make one myself?

• As per documentation for iOS, UMP SDK provides tools for publishers to request consent for personalized ads. As per my understanding, you can use UMP for personalized ads for tracking.

2) I have tested the consent form and if personalisation is enabled in Admob GDPR settings and personalised ads are enabled on my phone/Google account, then the form shows fine since Form Status is "Available". 

However, if personalised ads are disabled on my phone/Google account then the Form Status becomes '"Unavailable" and there is no way to request a form. In this instance, how do I request consent from users to show basic / non-personalised ads if the form is unavailable?

 - With regard to this, are you referring to requesting again the form if it is become unavailable? If yes, There are 2 ways for you to revoke/reset the consent of your app's users.

• You may to request consent again to trigger the revocation of the previous consent. You may create a method for this, then put an option in your app settings section called 'modify consent' that will run the created method.
• You will need to set the UMPConsentStatus to UNKNOWN first or by resetting the consent by following this guide.

Regards,

Princess Pamela Pineda Mobile Ads SDK Team

ref:_00D1U1174p._5004Q2LU0HJ:ref

[emberr]

Hi, thanks for your response.

1) Sorry but can you please confirm with a yes/no for whether UMP can be used to request a consent form if personalised ads are disabled in the interface?

2) I am not referring to requesting the form again if it has become unavailable, but rather a fresh install of the app where no form has previously been shown. The form is unavailable in this instance if I have personalised ads disabled in my phone/Google account settings (but personalisation is enabled in Admob settings) even with a fresh install. So resetting doesn't help in this instance.

Thanks

[Mobile Ads SDK Forum Advisor]

Hi emberr,

Thank you for responding to us. In regards to your question that answer is, no. If you have disabled personalized ads then there is no need to display the consent form. The forms and all consent are only needed for when you are looking to show personalized ads. So to be compliant with GDPR you just need to have the ability to call the consent and if the person has the phone set to show personalized ads, it will then show them the form.

With the steps that you have mentioned, the behavior looks actually to be correct, if you have chosen to not show personalized ads, then there is no need for the forms.

Regards,

William Pescherine Mobile Ads SDK Team

ref:_00D1U1174p._5004Q2LU0HJ:ref

[emberr]

Hi,

Thanks very much for your response. This is very clear. 

However, to be absolutely completely sure, could you please confirm that the following statements by Google are adhered to for GDPR by simply having the ability to call the UMP consent form, even if the user does not actually view it:

https://www.google.com/intl/en_uk/about/company/user-consent-policy-help/

What if I’m a publisher serving only non-personalised ads to EEA and UK users?

If you do not serve personalised ads to users that visit your site, and visits to your site do not influence the ads served elsewhere, you are still required to obtain consent for the use of cookies or mobile identifiers, where legally required. Consent for cookies or mobile identifiers is still required because non-personalised ads still use cookies or mobile identifiers to combat fraud and abuse, for frequency capping and for aggregated ad reporting.

https://support.google.com/adsense/answer/9007336?hl=en-GB

Non-personalised ads (NPA)

Although non-personalised ads don’t use cookies or mobile ad identifiers for ad targeting, they do still use cookies or mobile ad identifiers for frequency capping, aggregated ad reporting and to combat fraud and abuse. Therefore, you must obtain consent to use cookies or mobile ad identifiers for those purposes where legally required, per the ePrivacy Directive in certain EEA countries.

Thanks

[Mobile Ads SDK Forum Advisor]

Hi there,

I work with William and Pamela, and will assist you. I reproduced this behavior of no consent form showing when device is set not to opt out of personalized ads and raised it with my team. We will get back to you as soon as possible. 

Regarding the image that states that Your account is serving non personalized ads and messages will not display in your apps, I am not familiar with that message as we only assist with integrating the SDK. Could you send us the steps to recreate such a message in an account?

Regarding whether consent is needed for non personalized ads in the EU, please note that this forum can only assist integrating the Mobile Ads SDK into apps and you are asking a policy question. I can only advise you to go to the AdMob Forum for policy related issues.

With that being said, AdMob & AdSense program policies Publisher integration with the IAB TCF v2.0 from that forum does state that 

If the consent requirements for personalized ads are not met, Google will serve non-personalized ads when all of the following criteria are met:

• The end user grants Google consent to:
  • Store and/or access information on a device (Purpose 1)
• Legitimate interest (or consent, where a publisher configures their CMP to request it) is established for Google to:
  • Select basic ads (Purpose 2)
  • Measure ad performance (Purpose 7)
  • Apply market research to generate audience insights (Purpose 9)
  • Develop and improve products (Purpose 10)

You may also be interested in Limited ads.
Regards,

Aryeh Baker Mobile Ads SDK Team

 

ref:_00D1U1174p._5004Q2LU0HJ:ref

[emberr]

Hi,

Thanks very much for your response.

To recreate the message:

• Go to the Privacy and messaging tab in Admob https://apps.admob.com/v2/privacymessaging
• Click on GDPR https://apps.admob.com/v2/privacymessaging/gdpr
• Click on Settings
• Under 'Choose the type of ads you want to show' choose 'Non-personalized ads'
• Click Save
• Click on 'Messages' and it shows that message

Regarding the advice to go to the AdMob forum for this, I am only responding to your team's advice in the comment above:

Thank you for responding to us. In regards to your question that answer is, no. If you have disabled personalized ads then there is no need to display the consent form. The forms and all consent are only needed for when you are looking to show personalized ads. So to be compliant with GDPR you just need to have the ability to call the consent and if the person has the phone set to show personalized ads, it will then show them the form.

With the steps that you have mentioned, the behavior looks actually to be correct, if you have chosen to not show personalized ads, then there is no need for the forms.

This is legal advice that your team is already giving me, so why can't you answer the question which is to please confirm that the advice you have already given me is correct according to your own policy? This is a question about the Admob SDK and how it should be implemented because you are telling me that the SDK can be implemented in a certain way to be compliant with GDPR law. Your reference to the AdMob & AdSense program policies Publisher integration with the IAB TCF v2.0 does not answer the question as to whether your own solution is compliant with the law, it simply states how non-personalized ads are served. In fact the URL you have provided gives the same information I have previously mentioned in this thread:

For non-personalized ads, consent for cookies or mobile identifiers is still required because non-personalized ads still use cookies or mobile identifiers to combat fraud and abuse, for frequency capping, and for aggregated ad reporting.

The Limited ads link is partially helpful but why should that be needed at all if the UMP consent form is supposed to gather consent from users in first place? That should not be needed if the consent form actually works. I want to know how do I implement the UMP consent form to be compliant, and if it is in fact not compliant will you make changes to the consent form based on what is mentioned here? Otherwise it was a total waste of time for me to integrate in the first place.

Thanks

[Mobile Ads SDK Forum Advisor]

Hi there,

Thank you for getting back to us with the steps to see that message, I reproduced the message and sent it to my team.

The GMA SDK provides tools to help publishers comply with regulations. It is up to the publisher to consult with their own lawyers or decide their own risk. Legal issues are beyond the scope of this forum, we can only assist you implement the tools we provide to help you be in compliance. 

As we speak, my team is going over the discrepancies you found. We will get back to you as soon as possible.

[Neil D]

Hello,

this is the exact issue I am also trying to work out.

From what I have found, if your Admob account is set to only show 'Non-Personlised Ads', then the UMP Consent Form in not shown to the user, but the message response from the UMP consent form that we receive within the app code is "Obtained", so I am assuming that the consent from the user to show non-personalised ads has been given, somehow through googles terms maybe?

There's seems to be some confusion around the questions we are asking and the responses we are getting from the Admob team.

Regards

Neil

[Mobile Ads SDK Forum Advisor]

Hi Neil,

This thread will be the one where we will get back to you on why the UMP SDK doesn't show a form when either the device is set to not show personalized ads or your account is set to not show personalized ads when our documentation,
 AdMob & AdSense program policies Publisher integration with the IAB TCF v2.0  states: 

If the consent requirements for personalized ads are not met, Google will serve non-personalized ads when all of the following criteria are met:

• The end user grants Google consent to:
  • Store and/or access information on a device (Purpose 1)
• Legitimate interest (or consent, where a publisher configures their CMP to request it) is established for Google to:
  • Select basic ads (Purpose 2)
  • Measure ad performance (Purpose 7)
  • Apply market research to generate audience insights (Purpose 9)
  • Develop and improve products (Purpose 10)

[Mobile Ads SDK Forum Advisor]

Hi All,

I hope you're doing well.

I just want to circle back on this. The team mentioned that this current behavior of UMP is expected. But the team are still thinking on how to support this use case on the future. You may monitor our blog for future updates.

Regards,

Princess Pamela Pineda Mobile Ads SDK Team

ref:_00D1U1174p._5004Q2LU0HJ:ref