Technology & eCommerce Regulation in the Spotlight

Google has recently announced significant changes to the Google Play policies aimed to bolster user and children protection, control, privacy, and security. These updates will require developers to adhere to a fair amount of new requirements, which will take effect gradually starting 1 September, 2021. Below are detailed the key updates:

User transparency and data protection:

• User Data Policy: Starting 1 April, 2020, Google will add a new data privacy and security section to the user data policy, requiring developers to accurately disclose information related to personal or sensitive user data that is collected and used by the app. In addition, developers will be required to post their privacy policy in both the app and the Google Play console.

Google will also prohibit linking persistent device identifiers to personal and sensitive user data or resettable device identifiers, with the exception of pre-approved cases. This change will become effective on 28 October, 2021.

• Ads Policy: Effective 4 October, 2021, when users opt out of interest-based advertising or ad personalization, their advertising ID will be removed and replaced with a string of zeros.

In addition, under the Family Policy requirements, apps that are primarily directed to children, will be prohibited from transmitting identifiers (e.g. Advertising ID). Apps directed to both children and adults, we have to avoid transmitting identifiers connected to their child users.

On a similar topic, Google recently announced that in the upcoming months it will no longer allow ad targeting of children based on their age, gender or interests.

• Permissions Policy: Starting 15 October 2021, all apps using the AccessibilityService API and the IsAccessibilityTool, which are meant to provide with an accessible and secure user experience, will be required to disclose the data they access and its purpose in Google Play Console and obtain the users’ approval.

Content restrictions:

• Inappropriate Content policy: the new Inappropriate Content policy (Effective 1 September, 2021), institutes new restrictions on sexual content, including prohibition on compensated sexual relationships. Although Google did not provide an explicit explanation, the changes seem to fall in line with the FOSTA-SESTA, which are the U.S. Senate and House bills against online sex trafficking.

• Financial Services Policy: the updated Financial Services policy clarifies the definition of the total cost of the loan and ensures that all personal loan apps are properly tagged under the Google Play “Finance” category. The policy update, that will become effective 4 October, 2021, also presents new requirements for personal loan apps operating in India and Indonesia.

Developers’ tools and methods:

• App set ID: Starting 1 September, 2021, Google will enable developers to use the app set ID for essential use cases such as analytics or fraud prevention. The app set ID is a unique ID that, on a given device, allows developers to correlate usage or actions across a set of apps owned by them. According to Google the ID shall not be used for ad personalization and measurement, and will automatically reset once all the developers’ apps on the device are uninstalled or dormant for over a year.

• Device and Network Abuse Policy: under the clarifications made to the Device and Network Policy (Effective 15 October 2021), apps or SDKs with interpreted languages (e.g. JavaScript, Python) are prohibited from violating any Google Play policies, and the updating and replacement of apps from any source other than Google Play will be prohibited.

• Store Listing and Promotion Policy:. Effective 4 October, 2021 the Store Listing and promotion policy will prohibit the use of spam text and graphics in app titles, icons and developer names.

These policy changes will require developers to review their existing and new apps distributed via Google Play, and to address and remedy various compliance aspects. Feel free to contact us if you have any questions regarding the compliance of your aps with the constantly updated app stores’ policies.

Kind regards,

Ariel Yosefi, Partner 
Head of Technology & eCommerce Regulation