Mobile Privacy Policy

This is a model Privacy Policy for mobile applications. This policy supplements any website policy. The language and annotations are credited to the MMA Mobile Application Privacy Policy Framework of 2011, available at http://www.mmaglobal.com/whitepaper-request?fil.... If you are building a mobile app, be sure to get at least a privacy policy before you submit it to the app store. Also, keep it updated and be faithful to it!

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PRIVACY POLICY MODEL FOR MOBILE APPLICATIONS

This is a model privacy policy, designed to be as generic as possible. We are not attorneys. We encourage those using this this model to consult a lawyer and have it reviewed by an expert as the language should change according to what your app does.

This privacy policy governs your use of the software application App Name (“Application”) for mobile devices that was created by Developer Company Name. The Application is Basic description of the app (features, functionality and content) 

 

What information does the Application obtain and how is it used?

This section is designed to inform Users of the types of data that the app obtains and how that information is used. You'll find several types of data that are often obtained by apps, but you should provide Users with a clear, illustrative list of the most important data points obtained by your app.

User Provided Information 

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

Alternative language if you don't allow unregistered users: "Registration with us is mandatory in order to be able to use the basic features of the Application." (On the other hand, you might want to specify you don't let user register at all, but still list the information you collect).

Mobile application developers should be aware that certain types of data, for example, medical records and certain types of financial information may be subject to existing privacy law, or any other current or future state, federal law, regulation, restriction, etc. Application developers creating apps that collect potentially sensitive information are encouraged to obtain counsel to ensure that their data collection policies are in line with current law in the jurisdiction(s) where the app may be used. If you collect credit card information, we strongly encourage you seek the advice of a professional to ensure PCI compliance and other specific security requirements. 

When you register with us and use the Application, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) credit card information for purchase and use of the Application, and; (e) information you enter into our system when using the Application, such as contact information and project management information.

This list is not comprehensive. Adjust it according to what your app actually asks for.

We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.

Automatically Collected Information 

If the Application collects information from and/or for social networking platforms (e.g., pulling contact information, friends lists, login information, photos or check-ins) you should ensure that the prior consent of the user is obtained. 

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. 

Again, this list is not comprehensive. Adjust it according to what your app actually asks for.

 

Does the Application collect precise real time location information of the device?

If your app uses geolocation, check out the specific branch of this document https://www.docracy.com/6513/mobile-privacy-policy-geolocated-apps-

This Application does not collect precise information about the location of your mobile device. 

 

Do third parties see and/or have access to information obtained by the Application?

The following language covers anonymized data that third-party analytics services might collect for you, and a few other stardard cases where sharing users' data is fair and justified. Generally, app developers will want to have the right to transfer information collected by the app under certain circumstances. For example, if the app developer sells the app, the developer may want that information collected by the application transferred as part of the sale. While some of the more common examples of data transfer to third parties are provided, you are encouraged to work with counsel and/or privacy professional to determine if other examples should be included in the policy.

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;

  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

  • if Developer Company Name is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

If your app works with advertisers and analytics companies that collect personal data, your policy needs to have an Automatic Data Collection and Advertising section. Check out the specific branch here: https://www.docracy.com/6516/mobile-privacy-policy-ad-sponsored-apps-

 

What are my opt-out rights?

If your app uses geolocation or taps into advertising services, check the appropriate branches linked above.

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at privacy@applicationsite.com.

 

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at privacy@applicationsite.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

 

Children

Your app has to comply with the Children’s Online Privacy Protection Act (COPPA). Developers should pay particular attention to COPPA when creating apps that contain cartoon characters or other features that may cause the app to be perceived as being directed towards children under 13. Consider including language in your Terms of Service that makes users represent they are of age. Application developers creating apps that might be governed under COPPA or similar laws are encouraged to obtain counsel to ensure that their data collection policies are in line with current law in the jurisdiction(s) where the app may be used.

We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@applicationsite.com. We will delete such information from our files within a reasonable time.

 

Security

Application developers should ensure that their security procedures are reasonable, and should provide an overview of their security procedures below.

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

 

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via email or text message. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy by clicking here.

 

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards. 

 

Contact us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at privacy@applicationsite.com.

Document Discussion

Just gave the privacy policies a quick skim... I think they all need an "effective date" Cal. Bus. & Prof. Code §§ 22575(b)(4). Noticed a few other potential problems. Perhaps this calls for a branching?

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