What’s going on?

Since May 2021, Google has been sharing details about their plans regarding the introduction of the Data safety section on Google Play (May, July and October) similar to the App Privacy section that Apple introduced on their App Store  back in December 2020. Google also colors this as a means to give users more information about what data developers collect about them and how they process that data, share it and handle it in general

This section is already visible on the Play Store - you can see here what that looks like for Clash of Clans by Supercell. However, starting 20th July 2022 this section will be mandatory - in other words, developers need to fill out the questionnaire available on Google Play Console. From Google’s announcement:

Developers will be asked to provide collection, sharing, and other practices for a range of user data types, as well as the purposes for which you use that data. You can tell us about your app’s privacy and security practices in the Data safety form on the App content page in Play Console. After July 20, 2022, all apps will be required to have completed an accurate Data safety form that discloses their data collection and sharing practices (including apps that do not collect any user data).

Why is this relevant for Ad Monetization Managers?

To quote Google again: By July 20, 2022, all developers must declare how they collect and handle user data for the apps they publish on Google Play, and provide details about how they protect this data through security practices like encryption. This includes data collected and handled through any third-party libraries or SDKs used in their apps. 

So the final answer that the developer needs to provide to Google (“yes” or “no” for each data point) should be decided based on internal data collection, sharing and processing practices as well as data collection, sharing and processing practices from third parties, in this case, ad networks.

Depending on how you handle things at your own company, it might be your duty to collect input from all ad networks and then share that internally so that those practices can be taken into consideration when answering Google’s questionnaire. Fun part of the role, right? 😊 

Anyways, we at GameBiz did this for more than a dozen clients and we want to share some of our work as well as impressions of the entire process and hopefully make things easier for fellow colleagues out there that still have this task ahead of them. 

How does the questionnaire work?

In theory, answers for each game will be unique, depending on what data you collect internally and which networks are used for that game. 

We collected answers from most major networks in the market. This was one of the most tiring parts of the process because many networks weren’t proactive in this regard and pretty much found out about this once we reached out with an inquiry. We collected input from 16 different networks, and the level of support they provided was very different depending on the network. A few examples, from no support to full support are listed below.

• AdColony and Fyber, as part of DigitalTribune, are under an internal restructuring process which for developers translates into zero guidelines on how they handle data from their users. Even to this day, they did not provide any input nor even a timeline when this might be available. At the time of publishing this article, it’s less than two weeks before these requirements become mandatory. Since they did not provide any input whatsoever, we resorted to the guidance they provided for Apple’s questionnaire a year and a half ago and their Privacy Policies as the next best alternative. This idea was further reinforced because Meta Audience Network couldn’t be bothered to update their guidelines either so we were simply referred to their very vague article they shared back in October 2020, for Apple’s requirements.
• Networks that provide in-game native ads did slightly better and they simply referred us to their Privacy Policies which we then had to read through and interpret on our own.
• Networks such as UnityAds, ironSource, Applovin, Vungle, Pangle, etc. did pretty well and provided documentation that was easy to understand.
• Full support in my book would mean that networks prepared the inputs and shared them proactively with their clients. It’s a little bit embarrassing to conclude this list by saying that not a single network falls into this category.

As previously mentioned, the answers networks provided ranged from very vague (came in the form of some general text or Privacy Policy) to very precise. Either way, it will be up to you to interpret their guidelines and come up with the answers needed for the questionnaire which then feeds into the final answer for the question that Google asks (for all networks combined).

The questionnaire is available in Google Play Console: Policy >> App Content.

So, where to find the answers?

You can refer to the links shown in the table below for the following 16 networks, in alphabetical order.

How do data collection practices compare between the networks?

I’m no data expert so I’ll keep this rather short. In my personal opinion, by looking into answers from every single network, I was under the impression that HyprMX collects more data points than other networks in the market. That is mostly due to the nature of their campaigns (brand only and in particular, specific types of brand campaigns) and it's only applicable if the user gives those answers willingly. Apart from them, Applovin was standing out in some cases but not substantially.

Now, how to create a single answer?

This is a tricky part because apart from a simple yes/no (on the question whether you collect a piece of data or not) you also need to answer the follow-up questions. Specifically, for the data you collect you also need to specify if it is:

• Shared
• Ephemeral
• Required
• + What is the purpose of collecting it

Now, we did compile final answers for many combinations of individual networks from the previous section listed above. I say many combinations because we repeated this exercise several dozens of times for all the games our clients have in their portfolio. The reason why we did this is that even if all networks that you have say “No” to a particular question but one single network says “Yes” then the final answer should be “Yes”.

So, since the answer depends on the particular combination of networks that you are using, we figured it doesn’t make much sense to share more here. However, if you need help on this topic, feel free to reach out directly. 😊 

In the end, I’d like to make our lawyers happy as well. There. 😊 

Nothing in this post or the follow-up comments or follow-up conversations constitutes legal advice and is solely provided for informational purposes only, and should not be construed as legal advice on any subject matter 

By Božo Janković, Head of Ad Monetization at GameBiz Consulting

The above article is a guest article for Gamesforum