Privacy Policy requirements for Demos and Interests in Google Analytics

[jrae]

I have a client who is activating the Demographics and Interests in Google Analytics, and I need to provide an appropriate privacy policy, per Google's TOS. Can anybody suggest what to state in the privacy policy? Google says: "If you’ve implemented Google Analytics Demographics and Interest Reporting, you must also disclose in your privacy policy: How you use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics."

So, I guess it's advisable to state that the site gathers "3rd-party audience data." Is it enough to say that the info is being used to better understand and communicate with the website visitor?

[Martijn_Scheijbeler]

Hi,

I would say that it's not third party data as the visitors on your own site are definitely not from a third party. But besides that I think you'll be ok with mentioning that user data is collected by Google Analytics to further improve the site.

[jrae]

Thanks, Martijn,

The lawyer that is helping me put together the new privacy policy says I need to use this copy: "We also use third party cookies (such as DoubleClick) to run Google Analytics Demographics and Interest Reporting. These cookies gather website visitor data (such as age, gender, and interests) to optimize website content and marketing and do not collect any personally identifiable information."

I can't find where Google actually explains how the demographics and interests info is determined. The instructions, such as they are, are in the digital advertising section, so it may be possible third-party cookies are involved (?). Ah well, better to err on the side of caution - we can say that they are in use, and not get into trouble if they aren't...but if we do use them and don't say so, then we can get into trouble.

--Janet