Data Platform Policies

Your provision of Data to Google is governed by these Data Platform Policies and the agreement between you and Google referencing these policies (a “Data Platform Agreement”). Google reserves the right to modify these policies at any time. Modifications will not be retroactive and will be effective immediately upon posting. You are responsible for ensuring that both you and your Data Partners comply with these Data Platform Policies.

Definitions

• “Data” means information you provide to Google subject to a Data Platform Agreement.
• “Data Partner” means any third party that you utilize in connection with the collection or transmission of Data, including without limitation the owners of websites or other properties from which you collect Data and technology service providers that you use to collect Data.
• "User" means a unique instance of a web browser, application, or similar technology.

Identifying Users and Obtaining User Consent

You must not pass Data to Google that:

• Google could use or recognize as personally identifiable information;
• permanently identifies a particular device (such as a mobile phone’s unique device identifier if such an identifier cannot be reset); or
• identifies less than 100 Users in a segment.

You must not use Google’s Data Platform (as defined in your Data Platform Agreement) to facilitate the merging of personally identifiable information with information previously collected as non-personally identifiable information without robust notice of, and the User’s prior affirmative (i.e., opt-in) consent to, that merger.

You must comply with the EU User Consent Policy.

Data Guidelines

You must have all rights necessary to provide Data to Google.

You must comply with (a) applicable laws and (b) applicable Internet advertising industry guidelines (e.g., the Network Advertising Initiative Code of Conduct or the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance).

Data must not be based on:

• past or current activity by Users known by you to be under the age of 13 years;
• past or current activity by Users on sites or apps or areas of sites or apps directed at children under the age of 13 years;
• past or current activity by Users on adult, gambling, or government agency sites or apps; or
• other inferred or actual sensitive information, including, without limitation:
  • health or medical history or information, such as from sites or apps that market to a specific health-related group,
  • negative financial status or other detailed information pertaining to a person's finances, such as information indicating a user has a low credit rating or high debt load,
  • racial or ethnic origins, such as from sites or apps that collect affirmative racial or ethnic identification from visitors,
  • religious beliefs or other beliefs of a similar nature, such as from sites or apps that collect people’s affirmative information on religion or religious beliefs,
  • the commission or alleged commission of any crime, such as information indicating that a user has a criminal record,
  • political affiliation, such as information indicating a user’s political opinion or political ideology,
  • trade union membership, such as a user’s visit to a trade union’s site or app, and
  • sexual behavior or orientation, such as sexual orientation inferred from a user’s visit to a particular website.

If you make your Data available for interest-based advertising through a Google product, your Data must comply with that product's policies for interest-based advertising.

User Notice and Choice

You must ensure that Data collection, sharing, and use is clearly and prominently disclosed on your website and on any site, app, or other property from which Data is collected. This disclosure must:

• describe the types of information collected (such as your use of cookies, web beacons, IP Address, or other identifiers), the methods used to collect it, how it is used (including to provide advertisements targeted to the User), and that it is shared with third parties; and
• provide the User with the ability to stop the collection of Data about the User for the purpose of delivering targeted advertisements (an “Opt-out”).

You grant Google all rights necessary for Google to:

• comply with applicable laws and Internet advertising industry guidelines; and
• inform a User of its inclusion in Data and provide it with a link to your privacy policy and Opt-out.

Offline Data: If Data is collected from offline sources, the same disclosure and Opt-out requirements apply to the online source where offline data is associated with an online identifier. Any offline sources of Data associated with an individual User must disclose their association of User data with third-party advertising or marketing activities, unless that Data is derived from publicly available governmental sources.

Location Data: If in collecting or compiling Data you or any of your Data Partners collect, process, or disclose information that identifies or can be used to infer a User’s precise geographic location, such as GPS, wifi, or cell-tower data, then:

• you or your Data Partner, as applicable, must obtain express (i.e., opt-in) consent from Users;
• all applicable privacy policies must disclose such information collection, processing, or disclosure; and
• you will only send such information to Google in an encrypted state or via an encrypted channel.

Policy last updated: 14 Feb 2025