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Increasing regulation, consumer demand, and the influence of big tech companies have all required mobile developers and web publishers to prioritize and adopt data privacy compliance and consent management practices. The real driver, however, is your company’s bottom line.

The rise of data protection laws and the requirements they set out mean that consumers are increasingly aware that if they’re not paying to use a product, their data is the real price.

As they’ve become more informed about how their data is collected and used by developers and publishers, consumers are more inclined to walk away from businesses with data privacy practices they don’t trust, understand, or agree with.

The mobile app, game, and web publishing industries have already had to adjust to how they manage consumers’ data privacy expectations over the past few years while also figuring out compliance requirements for new data privacy regulations. There’s no sign that this will change any time soon. Let’s take a look at the challenges developers and publishers are currently facing.

What is data privacy?

Data privacy involves the processes around the collection and use of digital personal information, including data that can be used to identify an individual, and the need to do so responsibly.

For companies, it relates to the policies and processes that enable users to control how their information is collected, used, processed, and shared in line with relevant data privacy laws. It also creates a framework for how companies can access and use personal data, including sharing and transfers to third parties or other countries.

Data privacy for app, game, and web publishers

App, game, and web publishers have to comply with major data privacy regulations like the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) the same as other companies that process personal data do.

The nature of the data collected from mobile app users can be sensitive in nature, including health or financial information. This means app, game, and web publishers must ensure high levels of security and transparency around their data collection and usage practices. When personal data is categorized as sensitive by privacy regulations, extra restrictions on usage and security requirements are levied on entities accessing it.

Biggest challenges for managing sensitive data

Data management presents a variety of complexities for developers and publishers that have to balance user experience, technical performance, data privacy requirements, and monetization demands.

Challenges associated with data privacy

1. Privacy-first mobile app marketing strategies make consent critical

Obtaining user consent for collecting personal data in apps and games has evolved from a mere formality to a central pillar of development and marketing operations.

This is a result of increasing global awareness about the control and protection of data, as well as the growing coverage of protections from privacy regulations. On top of this, pressure from business sources like premium advertisers and platforms like Google is increasing. These players now insist on proof of consent to enable access to high value inventory or their tools, making consent a direct driver of monetization and ongoing revenue.

Privacy by design is especially important in the mobile context, as UI restrictions and user impatience require a seamless consent process to ensure a positive experience. This approach will not only help you to attract and grow a dedicated audience to drive revenue generation, but also help you to avoid regulatory violations while meeting critical partner requirements.

The Digital Markets Act, Google Consent Mode, and consent signaling requirements

The Digital Markets Act (DMA) also brings major changes to European digital markets. It places new data privacy responsibilities on seven designated gatekeeper companies — Alphabet, Amazon, Apple, Booking.com, ByteDance, Meta, and Microsoft — which have billions of mobile users among them.

To achieve DMA compliance, these companies must ensure that third-party advertisers and developers using their platforms also get valid user consent and signal it to the gatekeepers. Google’s updated EU user consent policy and Google Consent Mode v2 are great examples of this.

Consent Mode introduces various consent signaling parameters that control whether user data can be processed via Google tags and used for advertising or personalization. This requires using a Google-certified consent management platform (CMP) into which Consent Mode v2 is integrated. Consent information is collected from users via the CMP, and communicated to Google services via Consent Mode.

The TCF 2.2, Google, and publishers

The IAB’s latest version of the Transparency and Consent Framework, the TCF v2.2, launched in May 2023 and brought a number of changes to mobile advertising.

The update excludes “legitimate interest” as a legal basis for data processing. This means it’s now mandatory for app publishers to capture consent for both cookie use and mobile identifiers in order to deliver personalized and non-personalized ads.

Google now also requires publishers using its products — including Google AdSense, Ad Manager, or AdMob — to use a Google-certified CMP that integrates with TCF v2.2 when serving ads to users in the EU, EEA, UK, and Switzerland.

2. Cross-device and cross-platform tracking for compliance and user experience

Users want seamless, personalized online experiences while also maintaining total control over the data they share and what companies are allowed to do with that data.

One of the biggest challenges here is that it’s increasingly common for users to have multiple devices, engage with apps across all of them, and want these platforms to “talk” to one another so that they don’t have to provide their information or consent multiple times. This also has to be handled securely.

Managing data privacy and consent across devices becomes more complex as more platforms are introduced. Especially since operating systems can change and considering that all of our apps come from different publishers with different technical capabilities and different levels of dedication to data privacy.

App publishers often need to develop sophisticated mechanisms to track users across devices and recognize their consent preferences on all platforms, all while respecting user privacy and the requirements of one or more data privacy regulations.

Under many privacy laws, apps also need to enable users to change or withdraw previously given consent at any point, which must immediately be respected across devices and apps, including by third parties processing data for publishers.

3. Artificial intelligence introduces another layer of complexity

Artificial intelligence (AI) is becoming integral to mobile apps, and the resulting increase in automated decision-making and targeted profiling is raising privacy concerns.

As a result, some data privacy laws require explicit user consent or clear opt-out options around automated decision-making and disallow it to be used on children’s or sensitive personal data.

The EU AI Act, which came into force in June 2024, is an example of this type of regulation. It introduces comprehensive rules for AI usage in the EU and applies to the providers and developers of AI systems that are marketed in the region. It aims to safeguard consumers while still encouraging innovation.

The AI Act categorizes different uses and risk levels posed by AI and prohibits AI practices that pose unacceptable risks — like manipulative techniques or exploiting vulnerable groups — and requires that high-risk applications be registered, documented, and submitted for regular compliance checks.

As a result of the AI Act and other data privacy regulations, publishers must ensure that their EU-based users are fully informed and have control over AI-driven processes in their applications.

This includes communicating transparently with users to inform them whether AI tools or algorithms are being used, what the purposes are, what data they use, the decisions that they might drive, and who might have access to the resulting information.

Publishers must also give users the option to opt out of all AI decision-making, especially when privacy regulations require an opt-in model for the use of AI tools.

4. Tighter controls over third-party data sharing

Historically, publishers could collect extensive user information and engage in data selling without obtaining consent from data subjects. Users typically weren’t aware of who had access to the information that was collected or how it was used.

Even now, although users see notices that request consent to share their information with “trusted partners,” it’s often unclear who these partners are and how they might use the information in question.

For example, some companies have hundreds of third-party partners and additional parties are sometimes nested in services like marketing cookies. As a result, they can only be uncovered by deep scanning, which makes them virtually invisible to the average user.

To comply with regulations like the GDPR and CCPA, publishers must now ensure that they have the necessary data processing agreements (DPAs) in place with any third parties that will be able to access the data collected by publishers.

Under most data privacy laws, the controller — the company arranging for the data processing — is responsible for the actions of third-party processors, hence the importance of DPAs to provide a framework for how processing and data protection must be conducted.

As privacy regulations tighten up globally, app and game developers and web publishers will need to become far more careful and strategic about managing consent, but also about which third parties, including advertisers, have access to their users’ data. In the EU and US, authorities have explicitly called out apps as a market that would be experiencing an increase in regulatory scrutiny.

The difficulty for publishers and developers is that these detailed consent requests may deter users from agreeing to tracking, especially if they have to scroll through a long list of companies they’ve never heard of but will then have access to their data.

One solution is to put more rigorous vetting practices in place for third-party partners and advertisers. This might include evaluating their compliance with various regulations and ensuring that their consent policies and mechanisms are detailed enough to meet the “informed” requirement of many laws’ conditions for valid consent.

5. Mobile app privacy compliance goes global

Gartner has predicted that 75% of the world’s population will have data privacy protections by the end of 2024. Data privacy is no longer a niche crusade by a few organizations or governments. Some regions, like in the EU, have multiple laws to protect consumers and their right to privacy.

Data privacy laws usually protect residents of the region where they’re enacted and are extraterritorial. For example, the GDPR puts requirements in place for the handling of EU residents’ data for all businesses, regardless of whether the business is based in the region.

This global reach has enormous potential implications for mobile apps and games. Users can be located anywhere, so developers may need to comply with multiple regulations to stay on the right side of the law.

While tools like geolocation can help developers to display the correct information and consent options to users based on their location, it’s still potentially a piecemeal approach. Robust and flexible data privacy frameworks that can be adapted to regional, national, or industry-specific laws and policies therefore become essential.

These frameworks enable publishers to focus on their core business while being able to adapt their data privacy and consent operations as laws change. This is especially crucial for smaller businesses, which may lack the significant targeted technical or legal expertise required for constantly maintaining data privacy compliance.

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6. User tracking and profiling for personalization

Publishers and developers that want to personalize in-app, in-game, and web experiences will need to leverage user tracking and profiling. This involves collecting data directly from your users, including online behaviors and preferences, to ensure the content they see is tailored to their interests.

However, major data privacy laws significantly impact how you’re able to do this while still respecting user privacy. Here, techniques like behavioral fingerprinting and progressive profiling can help you identify browsing patterns and collect data incrementally to gain valuable insights while adhering to these regulations.

7. Adhering to the Children’s Online Privacy Protection Act (COPPA)

Children are an especially vulnerable population, making their data more sensitive and requiring it to have greater protection than the average app, game, or website user. Pretty much all data privacy laws categorize children’s data as sensitive by default and require prior consent from a parent or guardian before it can be collected.

The age range that defines a child varies by law, so under some laws consent must be obtained by the young person rather than a parent or guardian.

This adds a layer of complexity for developers and publishers, who must obtain verifiable parental consent under the US federal law COPPA when collecting personal information from children under the age of 13.

Some recent enforcement actions highlight the importance of compliance with the Act:

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Biggest data privacy issues to watch out for

Developers and publishers working in the mobile space face some critical data privacy challenges. However, with the right knowledge and tools, you can gather and use data in a way that increases trust with consumers and positively impacts your bottom line.

Privacy-led marketing strategies also enable obtaining high quality data directly from users, helping to ensure consent and build more desired and personalized experiences that boost engagement and revenue long-term.

Staying compliant with privacy laws

Failure to stay up to date with data protection laws’ requirements and security best practices can lead to data breaches and leaks, which can result in lawsuits, hefty financial penalties, and significant damage to brand reputation.

In addition to these direct costs, it’s likely that your company will incur indirect costs such as a decreased revenue due to loss of customer trust and potential business opportunities.

The costs associated with data breaches

Here are some of the global data privacy laws that app, game, and website developers and publishers should keep an eye on and maintain compliance with:

Keeping track of changes to these and other data privacy laws can be difficult and expensive for teams that don’t have the in-house legal and technical expertise required to achieve and maintain compliance.

Using a CMP like Usercentrics CMP can help developers and publishers achieve and maintain privacy compliance by providing tools to manage user consent in a way that aligns with the latest requirements as they come into effect. Displaying a consent banner also demonstrates respect for users’ data privacy to build trust.

Visibility over collection, usage, and sharing of data

Developers and publishers that want to achieve and maintain compliance with data privacy laws need to create visibility around how an app, game, or web platform collects, uses, and shares data.

This can be done by providing users with detailed information about your data collection and data handling practices, which should be communicated via consent notices within your application or game, or on your website.

Access control to personal data

Proper access controls are necessary to protect both employee and consumer data within apps, games, and web platforms.

To adhere to the GDPR and other data privacy laws, companies must implement controls to limit access to authorized personnel only. This includes using role-based access controls and multi-factor authentication, as well as conducting regular access reviews to maintain data security. Such monitoring and technical controls also need to include third parties that may access the data.

Securing data across multiple devices

The rise of remote work has presented some challenges for securing data. Employees now often access company platforms from various devices, increasing the risk of data breaches.

To reduce the risk of leaks and ensure that data subjects’ personal information is safeguarded across all access points, developers and publishers must implement additional security measures, like end-point security solutions and robust monitoring.

Best practices for data privacy in apps, games and web publishers

There are a few key best practices that developers and publishers should follow to ensure that their personal data collection and access practices meet the requirements of data privacy laws.

Key to data privacy for apps, games, and web publishers

Data privacy regulations, user expectations, and business requirements have made user consent a necessity.

Savvy publishers understand that embracing data privacy and consent management can in turn drive acquisition of quality user data, downloads, long-term customer loyalty, monetization strategies, and revenue growth.

Developers and publishers that adopt a privacy-first approach when building their apps, games, and web platforms are protecting their operations from fines and other penalties, now and in the future.

What’s more, they understand that this approach can help them streamline operations so they can easily adapt to frequent changes in the technical and legal landscape and continue to generate revenue through advertising, subscriptions, and in-app purchases.

To take a privacy-first approach to collecting and managing user data, turn to Usercentrics CMP. It’s a flexible and scalable platform that helps you manage user consent across websites, apps, and mobile games so you can achieve and maintain data privacy compliance.

In the years since the General Data Protection Regulation (GDPR) came into force in 2018, there have been some dramatic headlines about fines levied on companies for violating its requirements. 

For the most part these headlines have involved influential tech platforms with potentially billions of users. However, organizations of all sizes have been penalized for not adequately obtaining user consent for processing personal data, not meeting the requirements of their chosen legal basis, experiencing a data breach, or other issues.

Apps developers and publishers haven’t been in the news as much, even though our research showed that 90 percent of apps available in the EU that we looked at were not compliant with the GDPR. One exception was France’s data protection authority CNIL, which fined Apple and Voodoo Games in 2023 for using an advertising identifier without users’ consent.

There have been other fines levied by data protection authorities around Europe for apps’ GDPR violations. That regulation and other laws do not distinguish between websites and apps with regards to compliance requirements. We take a look at several examples to explore what happened, what the penalties were, and how to do business compliantly.

The GDPR applies to organizations that process the personal data of EU residents, whether or not the company is located in the EU. That processing could be to enable apps to function, to deliver personalized advertising, or to provide analytics data to improve performance, for example. 

Companies need to abide by “lawfulness of processing”, i.e. meet the requirements of a relevant legal basis to justify their collection and processing of personal data.

Art. 6 GDPR covers these six legal bases:

Consent is a common choice of legal basis, though the GDPR requires user consent to be “freely given, specific, informed and unambiguous”. As we will see, this is where a number of companies have violated the law. 

Organizations are also required to collect, store, and document users’ consent choices securely, and provide important information to users about data processing, their rights, and other factors. 

Meeting these requirements on a website in a way that’s clear, compliant, and user-friendly can be challenging, and managing it in apps on small mobile screens elevates the challenge, especially when companies both need to comply with GDPR requirements and need access to quality data for advertising, analytics, and other purposes. 

Who is responsible for GDPR enforcement?

GDPR enforcement is a collective effort across several authorities within the EU and is mainly in the hands of national Data Protection Authorities (DPA) within each EU member state. These supervisory authorities, established under Chapter 6 GDPR, are independent public authorities. 

They have the power to handle complaints, investigate compliance, and issue fines or other penalties for established violations. DPAs also issue guidelines and provide resources on GDPR compliance.

These groups work together to ensure that the GDPR’s requirements are consistently applied across the EU, and are supported by the European Data Protection Board (EDPB), which increases collaboration and cooperation among DPAs and advises on key matters of data privacy and protection.

What are the fines and penalties for GDPR violations?

Some data privacy laws around the world provide a “cure period” if an organization has been found to have violated the law. This enables them to correct the issue and ensure it won’t happen again while avoiding fines and other penalties.

The GDPR does not require provision of a cure period, though arrangements are at the discretion of EU member countries’ data protection authorities. GDPR enforcement is handled at a national level, and countries can also add their own specific data privacy and protection requirements.

Art. 83 GDPR covers penalties for violations. These include:

Administrative fines are probably the most well known GDPR penalty and what tends to make the headlines. There are two levels of administrative fines, depending on severity of the infraction.

Tier one administrative fines

The first tier of GDPR fines are most commonly used for first time or less severe infractions. They can be up to EUR 10 million or two percent of global annual revenue for the preceding financial year, whichever is higher.

Tier two administration fines

The second tier GDPR fines are generally for repeat violators or more severe infractions. They can be up to EUR 20 million or four percent of global annual revenue for the preceding financial year, whichever is higher.

The smallest GDPR fines have been “three-digit amounts”. To date, as of early 2025, the largest GDPR fine has been levied on Meta, parent company of Facebook, Instagram, and WhatsApp, for EUR 1.2 billion.

GDPR fines for app publishers

Over the past several years, data protection authorities around the world have increasingly turned their attention to mobile apps privacy compliance. The California Attorney General announced increased focus on mobile apps compliance in 2023. In September 2024, France’s CNIL published recommendations to enable better privacy compliance in apps, with increased enforcement beginning in 2025.

Let’s look at some notable enforcement actions that European DPAs have levied on prominent mobile apps and platforms.

Norwegian Data Protection Authority Datatilsynet vs. Grindr

Norway’s Datatilsynet fined social networking and online dating app Grindr approximately EUR 6.5 million in 2021 for disclosing user data to third parties for behavioral advertising without a legal basis. The data shared included:

The DPA also considered that use of Grindr is sensitive personal information, as it strongly indicates the user’s sexual orientation or preferences, which would merit additional protections under the law.

The Norwegian Consumer Council filed a complaint against Grindr in 2020. The company claimed to have collected valid consent information from users to enable sharing their personal data with advertising partners. 

However, the consents were not valid as users did not have consent choices — e.g. to opt out of sharing data with third parties for advertising — and had to accept the privacy policy in its entirety to be able to use the app. Additionally, users were not properly notified about the app’s sharing of personal data. Both of these issues violated the GDPR’s requirements.

Italian Data Protection Authority Garante vs. Clubhouse

In December 2022, Italian DPA Garante fined social audio chat app Clubhouse EUR 2 million for multiple GDPR infractions:

Clubhouse was also required to adopt measures to comply with the GDPR, in addition to being prohibited from further processing of personal data for marketing or profiling purposes without obtaining informed and explicit user consent.

Clubhouse is owned by Alpha Exploration, which is a US company with no EU presence, however, Clubhouse services were available to users in the EU, making the app subject to GDPR compliance.

Irish Data Protection Commission vs. WhatsApp

Ireland’s Data Protection Commission fined instant messaging and VoIP service WhatsApp EUR 5.5 million in 2023. As noted earlier, WhatsApp’s parent company is US-based Meta, which also owns Facebook and Instagram, among other platforms and services. 

WhatsApp Ireland was given six months from when the decision was handed down to bring their data processing operations into compliance with the GDPR.

In advance of the GDPR coming into effect on May 25, 2018, WhatsApp Ireland updated its Terms of Service, forcing users to click “agree and continue “ to accept the new terms to be able to access the app. 

Users were forced to accept the terms in whole and consent to processing of their personal data for security and service improvement purposes. They had no granular consent options. Declining the terms prevented users from accessing the app’s services entirely. The initial complaint was filed by a German WhatsApp user.

WhatsApp also didn’t provide users with adequate information about the legal basis for data processing, preventing clear understanding of how their personal data was being used or shared, or for what purposes. 

WhatsApp had considered users’ acceptance of the updated Terms of Service to be entering into a contract with the company. Fulfilling a contract is an acceptable legal basis under the GDPR, and the company took the position that processing users’ personal data for delivering its services was necessary to perform that contract. 

The complaint, however, argued that by requiring users’ acceptance of the updated Terms of Service, the company was forcing user consent, and thus consent was their legal basis, not contract fulfillment. However, the conditions of the consent invalidated it under the GDPR, as it was not adequately informed or voluntary.

Usercentrics helps you stay GDPR-compliant and growing monetization

Increased GDPR enforcement for apps compliance and ever more savvy users mean that it’s not worth risking trying to get around data privacy requirements. Especially since there are robust, user-friendly tools like Usercentrics App CMP that streamline consent management. Collect consent compliantly on your apps and get the data you need to grow your monetization, without getting in your users’ way. 

Usercentrics delivers an SDK that enables fast setup. Access over 2,200 pre-built legal templates for your data processing services, and use the App Scanner to seamlessly detect and integrate your vendors, SSPs, and SDKs. Our expert team is also here for you every step of the way with expert guidance and detailed documentation.

Learn more about how Usercentrics can help grow your business. Check out our case study with Homa Games and how they achieved a 10% increase in Ad LTV with user consent and achieved and maintained privacy compliance.

Safeguarding personal information online has become more critical than ever as data privacy laws expand and consumers’ expectations grow. One of the most effective strategies for protecting data is through data minimization.

This principle, enshrined in various data protection and privacy laws like the General Data Protection Regulation (GDPR) and the California Privacy Rights Act (CPRA), emphasizes the importance of collecting, processing, and storing only the minimum amount of personal data necessary for a specific purpose, and retaining it only as long as needed to fulfill the stated purpose.

But what exactly is data minimization, how does it work, and how can your company implement measures to limit its data collection in beneficial ways? Let’s delve into it.

What is data minimization?

Data minimization is a fundamental principle in data protection and privacy laws like the General Data Protection Regulation (GDPR).

Data minimization refers to collecting, processing, and storing only the minimum amount of personal information necessary for a specific purpose, and retaining it only as long as needed to fulfill that purpose.

This approach aims to reduce risks associated with companies’ potential privacy overreach, data breaches, and other misuse while helping to ensure compliance with various data protection regulations. It also shows respect for customers by demonstrably limiting data collection and use to only what’s needed, communicated, and consented to.

Organizations implementing data minimization strategies only collect relevant data and retain it for the shortest time possible. They also regularly review, delete, or anonymize unnecessary information.

By adhering to this principle, companies can better protect individual privacy, enhance data security, improve data management efficiency, meet legal requirements, and improve customer experience.

 

Data minimization and GDPR

Data minimization is a key principle of the GDPR. It requires organizations to collect and process only the personal data that is necessary for their specified purposes. It explicitly addresses data minimization in Article 5(1)(c) GDPR, which states that personal data shall be: “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’).”

This principle is further reinforced by Article 25 GDPR, which requires that data minimization be applied by default to each specific purpose of data processing. These articles mean that website owners and businesses must identify the minimum amount of personal data required to fulfill their purpose and collect and hold only that information.

To comply with data minimization requirements, organizations should regularly review their data collection mechanisms, like website cookies, what data they collect, and for what purposes. Then they should also review what data they currently store and use, and if the purposes for which the data was collected are still valid. Finally, they should delete or anonymize data that is no longer needed.

By adhering to this principle, organizations can demonstrate accountability and reduce their risk of noncompliance with the GDPR.

Data minimization and CPRA

The California Privacy Rights Act (CPRA) also introduces data minimization as a key principle for businesses handling consumer personal information.

Under the CPRA, businesses are required to collect, use, retain, and share personal information only to the reasonably necessary extent and proportionate to achieve the specific purposes for which it was collected or processed.

Therefore, businesses must clearly define and disclose the purposes for data collection and ensure that the data is not used beyond these purposes without additional consumer notification and consent where required. In addition, the law requires businesses to implement data retention schedules and delete or anonymize (depending on the law or relevant policies) personal information once it is no longer necessary for disclosed processing purposes.

What is an example of data minimization?

Data minimization doesn’t have to be a complicated affair. For example, let’s look at data minimization in action in the context of an ecommerce website’s checkout process.

Instead of collecting extensive personal information from customers, the website could request only the necessary details for completing the transaction and shipping the product. This might include the customer’s email address, to send a receipt and order confirmation; name and shipping address, to send the order; and payment information. The company also receives various data just as part of the ordering process, like that from website cookies that track the customer’s shopping process, and order specifics like which product, size, and color.

In this example, there is no real need to ask for additional data, such as the customer’s date of birth, gender, or occupation, which are not essential for processing the order, even if these details would provide the company with more demographic information about the customer.

By limiting data collection to only what is required, the ecommerce site reduces its data liability and enhances customer privacy, while still effectively fulfilling its primary function of selling and delivering products.

Read about GDPR email marketing now

Benefits of data minimization

Many website owners and companies prefer to collect a lot of data. After all, more data helps you understand your target audience and optimize marketing campaigns. However, this is a poor practice in the age of digital privacy.

While privacy laws like the GDPR and CPRA require businesses to implement data minimization practices, the benefits go beyond regulatory compliance. Additional benefits of data minimization include:

The principles of data minimization

Data minimization is a key principle of data privacy regulation, along with closely related ones like maintaining accuracy and purpose limitation. It’s meant to guide organizations in collecting, processing, and storing personal data to fulfill specific purposes, from ecommerce sales to marketing campaigns to product development.

Here are key principles that website owners should follow to reduce their privacy noncompliance risk.

By following these principles, website owners can reduce privacy risks, enhance data security, improve regulatory compliance, roll out more precise marketing initiatives, and build trust with their customers.

 

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Data minimization and risk mitigation

Data minimization is a powerful strategy for reducing risks when handling personal information.

By collecting and keeping only essential personal data and cookies, website owners can significantly lessen the impact of potential breaches. This approach simplifies data protection efforts, as there’s less information to safeguard.

From a legal perspective, holding less data means fewer chances of violating privacy laws. This is particularly important given strict regulations like the GDPR. Data minimization brings companies one step closer to complying with these laws, avoiding hefty fines, reputational damage, and legal complications.

There’s also a financial advantage to this approach. Storing and managing large amounts of information can be costly, from both a financial and resource perspective. By cutting down on unnecessary data, companies can save on storage and processing expenses. Not to mention the work of maintaining or expunging it, or finding all of it to fulfill a data subject access request, for example.

In the event of a data issue, having less information to sort through enables quicker response times and a higher likelihood of accuracy. This rapid action can help limit damage and preserve customer trust.

Moreover, data minimization demonstrates respect for customer privacy. By only requesting and retaining necessary information, businesses can build stronger, more trusting relationships with their clients. This practice not only protects the company but also enhances its reputation in an increasingly privacy-conscious market.

How to implement data minimization measures

Data minimization may sound simple, but in practice, companies must consider how they collect, use, store, and dispose of customer data. In addition to being prepared to do the work to update policies, processes, and the management of the data itself.

Thus, if your company is considering implementing a data minimization policy, there are certain steps you need to follow.

  1. Assess your current data practices: Evaluate how your organization currently collects, retains, and manages access to personally identifiable information. This involves:
    1. identifying what types of data are being collected
    2. determining how long the organization has had the data
    3. determining why each piece of data is being collected
    4. evaluating if the collected data is necessary for the stated purpose
    5. reviewing who has access to data (e.g. third-party vendors) and what they may be doing with it
    6. review where data is stored (e.g. in various departments) and who has access
  2. Implement proportional data collection: Only collect data that is proportional and relevant to the purposes for which you are collecting it. Justify why you collect, process, or store consumer data and ensure these purposes align with your current business and data privacy objectives.
  3. Establish needs-based retention: Develop a strict data retention policy that ensures your business only retains data needed for specific purposes and only for as long as necessary. Once these purposes are met or the required retention period has passed, the data should be deleted.
  4. Use data anonymization techniques: When possible, anonymize data to protect individual privacy while still allowing for necessary data processing.
  5. Control data access: Implement a system that enables secure management of data access privileges across your organization. This ensures that only specific applications or individuals have access to the data fields required for their business processes.
  6. Regularly review data and delete unnecessary information: Establish procedures to periodically review the data your organization processes and the purposes for it, and remove anything that is no longer necessary to fulfill its original purpose. Consider implementing an automated solution that deletes certain data at predefined intervals.
  7. Define data retention schedules: Set specific retention periods for each type of data your website and company processes. This should be part of your overall data map and governance strategy.
  8. Streamline data collection processes: Review your data collection methods and forms to ensure you’re only asking for essential information. For example, if you only need a customer’s email for communication, don’t ask for their phone number or physical address.

By following these steps, website owners can effectively implement data minimization, enhance protection, reduce risks, and build customer trust.

Collect less to build consumer trust

Data minimization is not just a regulatory requirement, but a fundamental practice that can transform how organizations handle personal information.

By collecting only what is necessary, website owners can visibly demonstrate dedication to data security, user privacy, and respect for users’ rights under privacy regulations. The principles of data minimization, as outlined in regulations like GDPR and CPRA, offer a clear framework for organizations to follow, helping companies achieve and maintain compliance.

As digital privacy concerns continue to grow, adopting data minimization practices will be crucial for any organization aiming to maintain its reputation and safeguard its stakeholders’ information.

Google is phasing out third-party cookies in Chrome, marking a significant shift in the digital marketing landscape. Our in-depth session explores what this means for marketers, advertisers, publishers, and users. We address the challenges ahead and provide actionable solutions.

During this webinar, we cover the impact on personalized advertising, delve into alternative tracking technologies, and share strategies to maintain user privacy while achieving marketing goals.

What You’ll Learn:

Who Should Watch:

Stay ahead of the curve and ensure your marketing efforts succeed in a cookieless future. Register now to watch the recording!

There’s no viable and sustainable path to app growth without user consent. Stronger app privacy regulations mean consent and compliance should be a top priority for mobile application developers, publishers, and marketers to get right.

In this article, we’ll share key context and information about user consent, privacy compliance, and the regulations governing mobile app privacy.

We’ll also cover best practices for creating your mobile app privacy policy, as well as helping to ensure compliance with tracking and data processing consent requirements. Lastly, you’ll learn how the Usercentrics consent management SDK can help automate the entire process with an easy to use, highly customizable, and industry-leading solution.

Apps and privacy

The mobile application market is stronger than ever, with in-app spending set to reach USD 233 billion by 2026, according to a Sensor Tower report.

Yet many app developers and marketers feel the ground shifting, as data privacy regulations and industry changes (like Apple’s ATT) disrupt established user acquisition tactics, such as ad buying on self-attributing networks (SANs).

Data privacy regulations that require user consent for any type of personal data processing are a major cause of this disruption.

“The global landscape of data privacy regulations is increasingly stringent, with frameworks like the EU’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) setting the tone for what is becoming a global standard. These laws are not just legal hurdles; they represent a shift towards greater transparency and user control over personal information, which is crucial in the digital age,” says Adrienne Fischer, Founder and Attorney at Basecamp Legal.

As user consent requirements are here to stay, and noncompliance poses huge risks to the bottom line and customer base, the digital ecosystem is accepting this and adapting accordingly.

For example, Google has committed to ending third-party cookie use in Chrome, while server-side tagging is a growing alternative to third-party ad tech reliance. Additionally, more digital property owners are implementing user consent policies in compliance with laws like the EU’s General Data Protection Regulation (GDPR).

But when it comes to data privacy, the mobile application market has fallen behind, with 90% of popular apps in the EU in 2022 failing to respect user consent.

Future-proofing data strategies around user consent is vital for long-term business growth, especially for those with mobile apps.

In Liftoft’s 2024 App Marketer Survey, user privacy continues to be a top industry challenge and a pressing issue for apps. As such, user consent and data privacy are top of mind for many in the mobile app industry.

We’ll examine the data privacy regulations affecting your app and share how the Usercentrics SDK can help you automate privacy compliance and optimize consent rates via providing transparency to your users.

In short, there’s no way around data privacy compliance for any app business, and companies shouldn’t be avoiding it, especially when there are real financial benefits to privacy compliance. Here’s a quick overview of the most important regulations and their key requirements for apps.

Mobile app privacy laws and regulations

Data privacy regulations typically address consent via one of two models: opt in and opt out. Around the world, the opt in or prior consent model is most common. The opt out model is the one currently used in state-level privacy laws in the United States.

Consent on apps

The European Union’s General Data Protection Regulation (GDPR) is a data privacy regulation that applies to any app that collects personal data from users based in the European Union. Art. 6 GDPR outlines six possible legal bases for data processing, of which consent is the first, and Art. 7 GDPR outlines the conditions for consent to be valid.

The GDPR’s key requirement when using that legal basis — which many apps need to — is that if your app tracks personal data from EU users, you first need their consent to do so.

European data privacy regulations and guidelines (GDPR/ePD) put the responsibility of compliance on the “data controller”, i.e. the app owner/publisher.

This means that if your app processes any personal data from EU users, you are responsible for obtaining prior consent to do so. To date, as noted, many app publishers have been lax about doing so, but data protection authorities in Europe and the US have started increased enforcement in app markets.

Many third-party app SDKs track different types of data from users, like IP addresses, which are considered personal data under the EU’s GDPR). Yet these third-party providers would not be held fully responsible if users are denied their right to prior consent or data processing is otherwise done noncompliantly. That rests with you, the data controller.

Consent-based requirements in data privacy regulations that affect apps are not limited to the European Economic Area. A number of other GDPR-influenced data privacy laws have also taken effect around the world. Brazil’s General Data Protection Law (LGPD) and South Africa’s Protection of Personal Information Act (POPIA), for example, both require user consent before data processing.

Cookie consent for apps

For apps that collect data from EU customers, complying with cookie consent requirements is essential. Apps now need to establish a cookie policy that is transparent and informative. (While “cookies” is a term more commonly used for website tracking, apps absolutely do track users and collect data from and about their actions.)

Additionally, apps consent management should provide customizable cookie preferences, so users have the power to manage access to their data. This approach helps to ensure legal compliance, andestablishing clear and user-friendly consent mechanisms is also a critical step in respecting user privacy and securing data needed for marketing operations.

Opt-out on apps

While EU data privacy laws often require users to opt in, current state-level privacy laws in the U.S. typically follow the opt-out model.

These laws allow apps to collect data in many cases without requiring user consent first, but require businesses to provide a clear and straightforward way for users to opt out or revoke their consent. This opt out can be for data collection and use, sale, sharing, targeted advertising, or profiling, depending on the law.

Infographic CCPA

Every data privacy regulation is distinct and applies differently, so be sure to review the specific regulations that apply to your data handling operations and where you do business.

Broadly speaking, the world’s strongest data privacy regulations have set a standard that’s had an enormous impact on the app market, especially for app marketers.

What are the key data privacy regulation requirements for apps?

Again, it depends somewhat on what data your app tracks/processes and where your user base is located, but online, customers can be anywhere, especially with mobile apps. So here are best practices to keep in mind when developing your app privacy compliance strategy and implementation.

Obtaining and managing valid user consent

Apps with users in many regions globally must collect and securely store consent from every user before processing their personal data and must provide an easy way to change their consent choice (e.g. if you have users from the EU, Brazil, or South Africa). Consent banners must enable freely given, unambiguous, explicit consent from each user. Pre-ticked checkboxes, for instance, are not allowed in most consent-based laws.

Enabling users to opt out of data processing

If you have users in the U.S., enable them to opt out of data processing and respect their choices. A designated link or button must make it easy for users to opt out of data collection and sharing, e.g. through a Do Not Sell Or Share My Personal Information link, as is required by the CCPA and CPRA in California.

Even for European app users who may have given consent, the GDPR requires that they be able to change or withdraw it at any time as easily as they gave it.

Comprehensive privacy notice and/or policy

Provide a clear, easy to access privacy policy for full transparency into your app’s data processing, including the trackers in use, purposes of collection, method of processing, and which third parties you share this data with. This type of notification is a requirement in most data privacy laws around the world.

Mobile apps need data protection regulation compliance just like websites, and risk the same financial penalties. Heavy fines (e.g. up to EUR 20 million or up to 4 percent of annual global turnover, whichever is higher, under the EU’s GDPR) and loss of customer trust and active users are among the biggest risks for any app that doesn’t respect user consent and violates compliance.

However, with the industry moving away from third-party cookies towards server-side tagging, app companies that don’t update their data strategies for consent and compliance face additional risks.

As data privacy regulations have cemented consent as the industry paradigm, the ad tech industry is restructuring accordingly. For example, many advertisers are only buying ad space on apps that can prove valid user consent has been collected.

As dependence on third-party tracking declines across digital marketing operations, user consent is vital for establishing sustainable, data-driven marketing strategies. For apps to keep up with this change, and to capitalize on its opportunities, implementing proper and compliant consent policies must be a top priority.

Mobile app privacy policy best practices

For your mobile app to maintain compliance with data privacy regulations, you’ll need to create a detailed privacy policy that clearly and comprehensively details your company’s approach to user data. Here are best practices to consider when crafting your mobile app privacy policy.

While a mobile app privacy policy can be written by anyone from scratch, doing so can be resource intensive and risks potential gaps that lead to noncompliance. Privacy policy generators can save time and provide the right level of detail, but you still need to be careful to customize it correctly for your business and relevant regulations. Consulting qualified legal counsel and/or a data privacy expert with mobile apps expertise is strongly recommended.

What are the benefits of app privacy compliance?

Mobile app publishers and marketers are all too familiar with the challenges that come with data privacy regulatory enforcement for apps. According to a Sensor Tower report, 2022 was the first year on record where app store growth slowed to a halt, with Apple’s ATT framework being seen as the biggest influence. (The ATT framework was launched and enforcement began part way through 2021.)

Some of the challenges mobile marketers face include users declining to share personal data, resulting in a loss of data for marketing needs, and more imprecise performance evaluations.

In other words, mobile app marketers may struggle with a “blindness” when it comes to creating retargeting campaigns and optimizing user experience for better retention and customer lifetime value (CLV).

Besides the challenges to user acquisition and attribution, a recent case study from Blinkist shows the steep potential consequences of an incorrect setup of consent banners.

“Contrary to the common focus on the challenges of privacy compliance, we see significant benefits. Adhering to these standards not only reduces legal risks but also signals to users that an app prioritizes their data security, fostering user trust and loyalty in a competitive market,” says Yekta Ozcomert, COO of MobileAction.co.

It’s time for a change of perspective. Consent is not an obstacle to a thriving app business, it’s a necessity and an opportunity. Increasingly, premium advertisers are requiring proof of consent to unlock desirable inventory. For apps, data privacy can be a boon to revenue growth.

1. Outcome-based marketing

Mobile marketing is trending towards outcome-based marketing, which means working backward from desired customer behaviors to build and optimize the factors that drive those behaviors. User privacy is the key factor for this strategy, as it relies on accurate behavioral and identity data.

2. Brand loyalty

Enhancing brand loyalty with a positive privacy experience can increase your app’s brand preference by 43 percent, according to a 2022 Google and Ipsos study. Furthermore, users are twice as likely to share their personal data with a brand they trust.

3. CRM and lifecycle management

CRM and lifecycle tactics are more important than ever, with an increased focus on user retention and remarketing campaigns. The aforementioned study clearly shows that consent is key to user acquisition and retention, as it helps build customer trust, avoid fines and reputational damage, and helps ensure ongoing compliance with data privacy regulations.

In other words, prioritizing consent offers a clear competitive advantage. Those who migrate first and draw up better data strategies for their companies will profit in the long run. Google’s Consent Mode is a good example of this.

“From my perspective, the benefits of app privacy compliance are manifold. Firstly, compliance fosters trust between users and applications, which is foundational in building and maintaining a user base. Secondly, it encourages developers to design with privacy in mind, leading to more secure and user-friendly apps,” says Adrienne Fischer, Founder and Attorney at Basecamp Legal.

A privacy by design approach means consent management is integrated into the core of products. Having a robust consent solution that enables full compliance for your app is also likely to result in higher acceptance rates from users (i.e. more consent and data), in addition to other benefits. Also critically important is a consent solution that is customizable and flexible to ensure seamless user experience that doesn’t get in app users’ way.

“For instance, implementing privacy by design principles can help minimize the risk of data breaches, protecting both the user and the application from potential harm.” For app owners looking to protect user privacy, a comprehensive approach is crucial. This includes conducting regular privacy impact assessments, ensuring clear and accessible privacy policies, and implementing technical measures like encryption and anonymization to safeguard data.” Adrienne Fischer, Founder and Attorney at Basecamp Legal

However, navigating the complexities of the regulatory landscape can be difficult for mobile app developers and marketers, especially as sole proprietors or in small companies with limited resources.

This is where a consent management SDK can be easily integrated to automate the entire process.

What is a consent management SDK?

SDK App privacy guide

A consent management software development kit (SDK) is a tool designed to automate data privacy compliance within apps, and simplify the process of obtaining and managing user consent. Here are a few key benefits.

Efficiency: Automating consent management significantly reduces the manual workload for developers and marketers, so they can focus on other core business activities.

Enhanced marketing: Consent management SDKs enable more effective marketing campaigns by helping to ensure that all user data used is legally obtained, in compliance with relevant privacy regulations, and, increasingly, requirements of business partners.

Fosters user trust: These SDKs increase user adoption and retention by fostering trust through transparent handling and use of their data. This is enhanced when the texts and UI are optimized for clarity and user-friendliness.

Benefits of the Usercentrics Consent Management SDK

The Usercentrics Consent Management SDK is designed to address complex compliance requirements automatically, so your app can continue thriving with data protection peace of mind. Here are some key benefits:

Plug-and-play

Our SDK is designed to be ready to enable privacy compliance out of the box once you configure the CMP to your business needs and relevant regulatory requirements. Integration and maintenance efforts are minimal, just present the privacy banner when needed in your user flow, and our automated compliance technology helps take care of the rest.

Tailor-made fit

We value great user experience, and for a CMP this means maximizing transparency while minimizing intrusiveness. We want users to have a seamless experience when using your app. Our SDK offers several levels of customization that will help you adapt our privacy banner to your design and messaging, as well as roll out advanced features such as Dark Mode and A/B Testing.

Geotargeting for global compliance

Thanks to our remote configuration setup and location awareness, the same SDK integration can address your privacy compliance needs whether your users are in Europe (GDPR), U.S. (CCPA/CPRA), Brazil (LGPD) or other countries with comprehensive data privacy regulations.

Data-driven optimization

Whether your priority is to maximize your monetization strategy or provide a personalized experience to your users, you will need user insights. For this reason, optimizing your opt-in rates can make a vital business difference. The Usercentrics Consent Management SDK gives you robustanalytics with multiple levels of granularity, so you can track how changes to the banner influence interaction and opt-in rates.

Broad support

With support for iOS, Android, Flutter, React Native, and Unity, the Usercentrics Consent Management SDK offers a flexible approach to solving data privacy compliance for mobile apps — and can be integrated with your app in less than an hour.

“A prominent part of the user experience is the ‘privacy experience’ (i.e. ATT permissions, GDPR permissions, etc.) which should also be seamlessly integrated in the journey. Having permission pop ups and banners randomly breaking your experience is becoming a no-go.”
— Valerio Sudrio, Global Director, Apps Solutions, Usercentrics

Stay ahead with mobile app privacy

The mobile apps market is thriving, but ignoring user consent and privacy compliance continues to grow as a liability as the technology industry centers on data privacy and user engagement in response to growing regulatory coverage and the demands of influential tech platforms and business partners.

Integrating a consent management SDK on your app can help future-proof your data-driven business: boosting transparency and trust, smarter data strategies, and better remarketing campaigns.

If you want to continue leveraging user data to build high-performing campaigns, you need user consent. There’s no way around it.

The Usercentrics App CMP SDK brings industry-leading compliance technology to your app. Get in touch with one of our experts to learn more about how the Usercentrics SDK can help automate consent and compliance on your app.

Data privacy and user consent are vital when developing and operating a mobile app or game. Without it, you risk breaking trust and breaching legislation.

Many mobile apps have already been penalized for not meeting the requirements of global data regulations like the California Consumer Privacy Act (CCPA), Brazilian General Data Protection Law (LGPD), ePrivacy, and the EU’s General Data Protection Regulation (GDPR).

GDPR came into effect in 2018, giving individuals control over their personal data and setting the pace for similar regulations around the world. It requires app owners to seek explicit consent from customers before they’re allowed to collect, use, or sell any personal data.

This means you need mobile app consent for data such as location, name, address, telephone number, biometrics, health, or financial data. It also covers cookie consent and any data that can identify an individual, like IP address.

Mobile apps and games have important reasons for gathering this data — often to improve functionality and deliver a better app experience. We’ll share five best practices for obtaining and managing mobile app consent.

Mobile app consent involves asking for explicit permission before accessing or using a client’s personal data.

Along with being a regulatory requirement, this is a cornerstone of building trust and loyalty with app users and mobile gamers. By clearly outlining what data is being collected and the purpose behind it — such as a personalized app experience, improved service delivery or access to special features — individuals can make informed decisions about their privacy.

Read about mobile app CMP now

Mobile app consent typically works by presenting clear, easily understandable choices regarding customer data.

This often includes a clear way to opt in or opt out of data collection for certain features, along with a detailed explanation of how data will be used and what security measures are in place to protect customer information.

Here are five proven strategies to navigate mobile app consent, so you can deliver an outstanding app experience while ensuring compliance.

Following these best practices will help you communicate with clarity, offer meaningful choices and respect customer preferences — to ultimately build a solid foundation of trust and transparency with your users.

1. Timing is everything: present disclosure at the point of request

Easily manage app consent and data privacy compliance with Usercentric’s app consent management platform (CMP).
Easily manage app consent and data privacy compliance with Usercentric’s app consent management platform (CMP).

An app user is far more likely to grant you permission to use their data if they understand exactly what you’re asking for and why you’re asking for it. They’ll be even more likely to do so if you make it clear what’s in it for them if they grant permission.

It’s recommended — and often legally required — to present disclosure when you request to use an individual’s data.

For example, let’s say your app is for a fashion retailer, and you offer a free home delivery service. If you ask a customer for consent to use their location data while they’re browsing men’s shirts, it likely won’t be clear why you need that data.

However, if you present that same consent request while the customer is checking out and arranging the delivery, your request will make better sense; you need their location data to provide the delivery service.

Being upfront, transparent and clear about the data you need — what’s in it for your users — helps to build trust and ensures your customers can make informed decisions.

2. Give the consumer the choice to decline consent

Mobile apps are required to offer users choices around what data they share with you. Usercentrics streamlines the consent process for app developers.
Mobile apps are required to offer users choices around what data they share with you. Usercentrics streamlines the consent process for app developers.

While we all want our mobile app users to grant consent, it’s important to provide a clear and simple way for them to decline. It should also be easy for individuals to change their mobile app consent preferences at a later date, as this is a legal requirement of some privacy laws.

And it’s a violation of GDPR to make consent a condition of use. If a consumer declines consent and that data is necessary to power a certain feature, then degrading that feature on your app is a better approach than denying full access.

Using the example from before, if a consumer declines your request to use location data and then realizes that they can’t see where their delivery driver is, they may want to change their mind and grant consent. Make this as easy for them as possible.

Under GDPR, mobile app consent must be explicitly stated, so be clear and transparent with your requests and offer both “accept” and “decline” options equally.

3. Request explicit consent for each use case in clear, friendly language

View of CMP first banner

Usercentrics is engineered with a deep understanding of the unique requirements and challenges of native apps. We do all the hard work, so you don’t have to.

In the early days of the GDPR, some apps tried to gain user consent by writing vague or confusing consent messages. This is not a viable tactic.

Not only has enforcement ramped up, but consumers are far more knowledgeable about what data might form a part of any mobile app consent process — and what their rights are.

Being explicit, clear and transparent will help to build trust while giving your app users the best chance to make an informed decision.

When you use clear language that makes sense to your customers, they’re more likely to grant you consent to use their data. Google recommends writing your mobile app consent messages to the reading age of a 13-year-old. (Under many laws, 13 is the age when individuals can legally provide consent, rather than requiring a parent or guardian.)

Read about in-game consent now

4. Use disclosure prompts that look like your app and not like the operating system (OS) notifications

Your disclosure prompts shouldn’t look like OS notifications, as this may confuse your consumers. You want your customers to be clear that it’s your app — rather than Apple or Google — that’s asking to use their data.

Let’s refer back to the example of a fashion retailer mobile app. If a mobile app user understands that you, the shopping app, are asking for consent to use location data to track deliveries, there’s a good chance that consent will be given.

By comparison, if a user mistakenly believes that the OS is asking for consent for the use of location data, they may think they’re giving permission for all apps to use their location data, and decline.

To help clarify this, customize your user interface with a seamless look and feel — including fonts and colors that match your app. Then optimize your user experience and place your consent request where it makes contextual sense. Both will be possible with a good consent management solution.

5. Be transparent, clear and specific with your consent requests

View of CMP settings

Consumers are increasingly educated about their data rights, so trying to distract or confuse them is a risky business — both for user trust and regulatory compliance.

To build long-term, trusting relationships with your customers, be transparent, clear and specific in your consent request. The GDPR requires consent to be “freely given, specific, informed and unambiguous.”

Write in clear and simple language that’s easy to understand, as your mobile app users often won’t spend much time deciding to accept or decline consent. If your audience is global, being able to present information and requests in multiple languages is also valuable.

Be clear what users get out of the transaction in return for granting consent. People want to know what’s in it for them, so make sure all cards are on the table.

Manage mobile app consent management with Usercentrics

Effective consent practices include asking for consent at the right time, allowing users to say no, using clear language for each request, making sure consent prompts match your app’s style, and being transparent and specific with your requests.

Also remember to use simple language that a 13-year-old could understand, as suggested by Google. While it’s good to keep things brief, detailed explanations are better if they help readers understand. Plus, if you’re sharing data with third parties, explain who they are and why they need the data.

Achieving privacy compliance need not be a headache. A CMP, such as the one offered by Usercentrics, can help you manage the processes of obtaining, managing and optimizing mobile app and website consent.