Privacy Policy

1) Do I have to include a privacy policy when I use Google AdSense?

There are two sides to this question from a legal perspective. But actually only one answer: YES.

  • There is the legal side of it: Depending on where you are you may fall under European, American (Californian) or Australian privacy laws. The list could go on since most countries have some sort of privacy regulations that extend onto the web – and penalties for non-compliance.
  • For advertisement services in general: advertisement services collect some sort of personally identifiable information as a rule of thumb to make sure they are able to track the effectivity of their ads or to increase their reach and impact, which is why you have to disclose this fact to people via something like a privacy policy: More information about the legal framework can be found here.
  • There is the company policy side to it as well: Does Google require me in their terms to have a privacy policy when I use their service? See the answer in the next paragraph (2).

2) Am I required by Google to post a privacy policy for AdSense?

Yes. Google requires users of Google AdSense to use a privacy policy. When you sign up for Google AdSense, you consent to their terms that state under “8. Privacy”:

You will ensure that at all times you use the Services, the Properties have a clearly labeled and easily accessible privacy policy that provides end users with clear and comprehensive information about cookies, device-specific information, location information and other information stored on, accessed on, or collected from end users’ devices in connection with the Services, including, as applicable, information about end users’ options for cookie management.  You will use commercially reasonable efforts to ensure that an end user gives consent to the storing and accessing of cookies, device-specific information, location information or other information on the end user’s device in connection with the Services where such consent is required by law..

The most important part in these terms regarding the privacy policy: “have a clearly labeled and easily accessible privacy policy that provides end users with (…)“.

3) How do I add a privacy policy for AdSense?

Usually, to make a privacy policy legally effective and compliant, it has to be easily found. A best practice is to link to your privacy policy from your footer where your users or visitors can find it at any given time. It should also not be modified to look like you want to hide it (smaller type, light colors that make it literally indistinguishable from the background).

4) An example privacy policy for Google Analytics?

A lot of people ask for sample privacy policies for their websites & Google AdSense. In reality those samples don’t do anyone much good because they’re far too generic. Let’s start with an enumeration of what needs to go into a privacy policy. Most countries’ privacy laws require you to include the following information:

– What kind of personal data is collected
– Describe how this information will be used by the company.
– Describe how this information will be transferred to third party companies.
– Provide instructions on how users can modify or delete their personal information.
– Provide instructions on how users can opt-out of future communications.
– Identify its effective date and outline how you notify people of material changes to your privacy policy.

Here is a sample privacy policy clause for Google AdSense:

Google AdSense is an advertising service provided by Google. uses the “Doubleclick” Cookie, which tracks use of and user behavior concerning ads, products and the services we offer.
You may decide to disable all the Doubleclick Cookies by clicking on:

Personal Data collected: Cookie and Usage Data. Place of processing: USA. You can find the AdSense Privacy Policy here.

Ideally you would tell the users what the service does in general and how you are using it. Note that the above example text is taken out of context. This will not yet be an effective privacy policy on its own.

What do I do now?

You can either hire a lawyer, write your own policy or use iubenda’s generator right away to make your policy. The AdSense clause is a PRO service that you can easily access with a premium account. The Google Analytics clause falls under our free limits.

Our Approach of Generating a Google AdSense Privacy Policy

So here’s where iubenda’s privacy policy generator will come in very handy:

  1. Define the services and categories of data collection your app/site is making use of.
  2. Add the services (and categories of data collection like “have a contact form”) you are using to your policy. iubenda now takes care of your policy and generates it for you.
  3. You can either link to your policy or embed the text into your app/site.