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Help with the EU user consent policy

Why does this policy exist and where does it apply?

The policy reflects certain requirements of two European privacy laws: the General Data Protection Regulation (GDPR) and the ePrivacy Directive, as well as any equivalent UK laws. This policy applies to end users located in the EEA, the UK and Switzerland. The EEA comprises the EU Member States and Iceland, Liechtenstein, and Norway.

The original version of this policy was introduced in 2015 and was updated on 25 May 2018 when the General Data Protection Regulation came into effect. The policy was last updated on 31 July 2024 to apply to users located in Switzerland.

Do I need to follow this policy for all users if I’m an EEA, UK or Swiss-based publisher or advertiser?

Google’s EU User Consent Policy applies only to end users located in the EEA, the UK, or Switzerland.

How will Google ensure compliance with this policy?

Our approach to compliance is to conduct periodic audits of websites and apps that use our advertising services, as we have done since the Policy was introduced in 2015. Our reviewers visit a website or app as a user would visit it, and we look at the information provided and the consents obtained.

Our first priority will always be to work with our partners to get compliance right. If we find that a partner is not following our policy, our first step will be to contact the partner to indicate an issue, and we will then try to work with them to achieve compliance.

As has been the case since 2015, we give websites and apps a reasonable timeframe to make any necessary changes; but if the partner fails to engage with us or fails to demonstrate a good faith effort to achieve compliance within a reasonable time frame, this might result in action on the account(s) in scope, including suspension of audience functionalities including ad personalisation (e.g. remarketing) and conversion measurement capabilities for advertisers; for publishers only Limited Ad/ programmatic limited ads will be eligible to serve (if programmatic limited ads are enabled).

In addition to conducting audits of websites and apps, we require publishers to adopt a Certified CMP when serving ads to users in the EEA, the UK, and Switzerland in order to comply with this policy. Google will continue to run audits on our publisher partner sites and apps where a Certified CMP has been adopted.

For advertisers with EEA traffic, if a user from the EEA is using your website or app and you measure user behavior with Google tags or SDKs and/ or you leverage audience functionality/ad personalisation functionality , you need to pass through end-user consent choices to Google (e.g. via consent mode or TCF). If you load the Google tag and haven’t implemented the latest version of consent mode we recommend working with a CMP in the Google CMP Partner Program. This list is not exhaustive of all CMPs available and Google does not require advertisers to use a CMP from the partner Program.

What disclosures to end users do I need to make?

Our policy requires identification of each party that receives end users’ personal data as a consequence of using a Google product. It also requires prominent and easily accessible information about the use of end users’ personal data. We have published information about Google’s uses of information. To comply with the disclosure obligations with respect to Google's use of data, publishers and advertisers are required to link to that page. We are also asking other ad technology providers with which Google’s products integrate to make available information about their own uses of personal data.

App developers should encourage users to download the most recent version of their app for the most up-to date user disclosures.

What are Limited Ads?

If you are a publisher, when you monetize impressions only with Limited Ads, in addition to disabling the collection, sharing, and use of personal data for personalisation of ads, Google disables features that require use of a local identifier like frequency capping. Only when Programmatic Limited Ads are turned on, invalid traffic detection-only cookies & local storage will be used to help defend against fraud and abuse. Note that ad-serving technologies (our JavaScript tags and/or our SDK code) will still be cached or installed as part of the normal operation of users' browsers and mobile operating systems. You should assess for yourself your compliance obligations, including required notice and consent, based on local law in your jurisdiction. See the Ad Manager, AdMob and Adsense Help Centers for more details on this feature.

What are the other Google products that incorporate this policy?

In addition to ads and measurement products, this policy is referenced in other Google products such as the Google Maps Platform Terms of Service, the YouTube API Services Terms of Service, the reCAPTCHA Terms of Service, and in Blogger.

What types of ads are considered “personalised” for purposes of this policy?

Personalised advertising provides an improved experience for users (i.e. improves advertising relevance) and advertisers/ publishers alike. Google considers ads to be personalised when they are based on previously collected or historical data to determine or influence ad selection, including a user's previous search queries, activity, visits to sites or apps, demographic information or location. Specifically, this would include, for example: demographic targeting, interest category targeting, remarketing, targeting Customer Match lists and targeting audience lists uploaded in Google Marketing Platform. Further information can be found here.

What if I’m an advertiser using Google’s products on my website/app?

If you use tags for advertising products like Google Ads, or Google Marketing Platform on your pages/app, you’ll need to obtain consent from your EEA, UK and Swiss users to comply with Google’s EU User Consent Policy. Our policy requires consent for cookies, mobile identifiers or other local storage where legally required, and consent for the use of personal data for personalised ads – for instance if you have remarketing tags on your pages/app.

What other parties collect end users’ personal data, and how should I identify these third parties?

Many advertisers and publishers using Google’s advertising systems use third parties to serve ads and measure the efficacy of their ad campaigns on websites and in apps. The policy requires you to clearly identify each party, in addition to Google, that may collect, receive, and/or use end users’ personal data as a result of your use of Google products.

My website/app is not based in Europe. Does this policy apply to me?

Yes, if you use Google products that incorporate the policy. The Policy applies only to end users located in the EEA, the UK, and Switzerland.

What about using click trackers?

Where advertisers choose to use third-party click-tracking technologies (i.e. where an ad click directs the user’s browser to a third-party measurement vendor en route to the advertiser’s landing page), they must do so in compliance with applicable law. Google’s vendor controls for publishers are not designed to cover click- tracking technologies.

What records do I need to keep?

Our policy requires that customers retain records of consent. At a minimum, these should include the text and choices presented to users as part of a consent mechanism and a record of the date and time of the user’s affirmative consent.

Why has my publisher CMP been deemed as non compliant, I use a Certified CMP which has also been certified by the IAB?

Adopting a Certified CMP does not guarantee compliance with Google’s EU user consent policy, as this depends on the implementation of the CMP and the specific consent message presented to users (for more guidance on this, please refer to the question above 'Checklist for partners to avoid common mistakes when implementing a consent mechanism').

Why has my website/app been deemed as non compliant, I use a Google Partner CMP?

For advertiser partners, the CMP partner program was created to assist advertisers in building and configuring consent banners on web/app and can support with consent mode integration. Working with any of these CMPs does not guarantee compliance with Google’s EU user consent policy, as this depends on the implementation of the CMP and the specific consent message presented to users (for more guidance on this, please refer to the question above 'Checklist for partners to avoid common mistakes when implementing a consent mechanism').

Do I need to follow this policy if I am using products that are using Privacy Sandbox APIs?

Yes. When using Privacy Sandbox APIs (including Topics, Protected Audience and Attribution Reporting) you will be accessing local storage. Since ePrivacy laws do not differentiate between personal and non-personal data, you will need to obtain consent regardless of your assessment on the nature of the data. The EU User Consent Policy requires you to obtain valid user consent for these actions in the same way as you rely on consent today for ads personalisation and the use of non-essential local storage to the extent legally required. More information on the Privacy Sandbox.

Updates to this policy

Google’s original EU User Consent Policy was updated on 25 May 2018. To reflect the UK’s evolving relationship with the European Union, minor changes were made on 31 October 2019.

In July 2024, we updated and expanded the EU User Consent Policy to include Switzerland.

No further changes to the policy are anticipated at this time but, as noted above, we will continue to evaluate the law and industry practice and update our recommendations and requirements accordingly.