“The Publisher may collect and share hashed or anonymized user data with third parties”
“The Publisher may enable third parties to set cookies and/or collect user data directly from the user (e.g. through a cookie, mobile advertising ID such as IDFAs and Android IDs or other technology) for their own use and subject to their own privacy policies”
“The user data may be combined and linked with data from other sources.”
“Collection and Sharing of Location Information”
“In addition to other information described in this policy, we may collect and share with third party ad and data networks precise location information. This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties for purposes related to advertising, analytics, attribution (e.g., measuring ad performance), analytics and market research.
You can remove your consent to having your location data collected by changing the settings on your device. (Certain services may lose functionality as a result.) You can “opt out” of various third party uses of Apple’s and Android’s advertising identifiers through those platforms’ corresponding device settings, as well.”
Location Data Opt-Out
In addition to the above, Provider shall provide End-Users with the ability to opt-out of geo-location data gathering (i.e., through app settings), and, as to any users whose device settings indicate a preference to not be used for ad targeting (“Opted Out Users”), Provider shall either (a) not deliver Apple IDFAs or Android Ad IDs for such Opted Out Users, or (b) upon written consultation with Company, send such Apple IDFAs or Android Ad IDs solely in a manner to signify such Opted Out Users (including a “LMT = 1” flag for location records associated with Opted Out Users).
“To the extent made possible by the App Stores (now or in the future), Provider shall (a) provide disclosures to its users that clearly and prominently inform users (on a separate screen) when, how, and why Location Data is collected, used, and shared by Provider with Company in connection with the Apps and obtain consumer’s’ affirmative express consent before collecting, using, and sharing Location Data. Without limiting the foregoing and solely by way of example, Provider may customize the App Stores’ standard geolocation disclosure to include the following: “This app collects and shares your location information over time for advertising and research purposes.”
Not Legal Advice
Company’s recommendation of any particular language herein, or of any additional recommended language in the future is not legal advice and Provider acknowledges that Provider is solely responsible for and should rely on its own counsel as to its own privacy disclosures.
Include links to DAA, NAI and similar industry opt-out mechanism