As part of various significant updates which were implemented by Google in its Play Store policies for app developers (see our related update here), the new policies require app developers to add a privacy policy to the store listing, as well as in-app privacy disclosures.

In order to provide information as to its enforcement intentions with respect to the updated policies, the company has recently started sending out notices to developers worldwide, whose apps in the Play Store do not have a privacy policy, warning that their apps might eventually be removed if no action is taken.

According to the new enforcement initiative, app developers have until 15 March 2017 to comply with the updated requirements. In this regard, they either have to include a link to a valid privacy policy on the Play Store listing and within the app, or remove any requests for sensitive information or user data. Otherwise, the company warns in its notices that administrative action will be taken to limit the visibility of the app, up to and including removal from the Play Store.

This action demonstrates Google's ongoing enforcement policy against non-compliant apps, and calls upon developers to review their app listings and data collection practices, in order that they do not violate any of the new policies. We would be happy to provide further advice and recommendations concerning the required steps,to ensure compliance with the applicable obligations and their scope.