Post-graduate law degree, CIPP/E from the International Association of Privacy Professionals (IAPP). Privacy and Data Protection Research Writer at TermsFeed.
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At Step 1, select the Website option or App option or both.
Answer some questions about your website or app.
Answer some questions about your business.
There are many types of personal information you might collect via your website, including:
- Email addresses
- Shipping addresses
- Payment card info
- Technical data collected via cookies and similar technologies
A note on that last point: Under most privacy laws, personal information can include "technical" data such as IP addresses, cookie IDs, and browsing history.
The following regions have privacy laws that consider personal information to include these types of technical data:
- European Union: General Data Protection Regulation (GDPR)
- United Kingdom: Data Protection Act 2018
- Canada: Personal Information Protection and Electronic Documents Act (PIPEDA)
- India: Personal Data Protection Bill (PDPB) (not yet in force)
- South Africa: Protection of Personal Information Act (POPI Act) (not yet in force)
The rules around collecting technical data also apply to mobile apps. Information collected via analytics and advertising tools qualifies as personal information, including device IDs, advertising IDs, IP addresses, app usage data, etc.
For example, here's an excerpt from the Google Analytics for Firebase Terms:
Do I Need Separate Privacy Policies For My Website and Mobile App?
Let's take a look at a few examples.
- What types of personal information the company collects
- How it collects personal information
- Its purposes for collecting personal information
- How it shares personal information
- How users can access their personal information
Each of these sections can include information about a company's website and app.
Here's an example from Bemit that addresses both:
Here's another example from Gauss Surgical:
Gauss Surgical identifies "registration information" as a sub-type of the broader category of "information you provide to us." The company then explains that registration information is collected via its website and its app.
Separate Privacy Policies
While there is no requirement to do so, you may prefer to create separate Privacy Policies for your website and your mobile application.
This brings us to an important point. If you are planning to create separate Privacy Policies for your website and mobile app, you must make sure that they reference each other.
If you really want to have separate Privacy Policies for both your website and app, it's important that your users can find all the information they need within either of the documents, and are aware that two separate policies exist.
If you do create two separate agreements, make sure to link them both to one another, and make both available on the respective platform.