Data Collection and User Consent
When portable electronic devices collect, process, or disclose information that can identify or infer a user's precise location—such as through GPS, Wi-Fi, or cellular data—specific obligations apply. Companies must clearly disclose how this data will be used, which may include advertising personalization, analytics, or attribution. This disclosure should be provided through interstitial or instant notifications, and explicit user consent must be obtained before any data collection occurs. Additionally, all such information must be transmitted to partners like Google in encrypted form, and privacy policies must fully describe the methods of collection, processing, and sharing.
Compliance with the Children’s Online Privacy Protection Act (COPPA)
For devices or applications subject to COPPA, additional rules apply. If a product is directed at children under 13 or knowingly collects data from users in this age group, it must be appropriately labeled. This can be done via Google Search Console, by adding tags in AdMob SDK requests, or by marking the content as child-directed. Importantly, interest-based advertising services, including remarketing, cannot target past or current activities of users under 13, or activities on sites aimed at children in this age group.
Advertising and Content Standards
Portable electronic devices that display ads must adhere to several standards to maintain compliance. Ads should not appear on pages that violate Google’s web search spam policies or present misleading experiences. Screens showing ads must be free of malware or unwanted software, such as viruses, ransomware, or spyware. Furthermore, ad experiences should align with the Better Ads Standards; non-compliant formats can lead to restrictions. For domains using ads.txt files, the seller must be authorized in those files, and parent companies in partner setups should ensure child domains are correctly listed.
Sanctions and Restricted Regions
It is important to note that Google enforces compliance with U.S. sanctions laws. As a result, publishers from certain regions—including Crimea, Cuba, Iran, North Korea, and Syria—are restricted from using Google publisher products. Companies operating portable electronic devices should verify that their business activities do not involve these sanctioned areas.
Privacy Disclosures and Policy Requirements
Any use of Google advertising services requires that publishers maintain a transparent privacy policy. This policy must disclose all data collection, sharing, and usage practices resulting from the use of Google products, including details on technologies like cookies, web beacons, and IP addresses. If personalized ads are displayed, advertisers must include a notice that the ads are based on user interests, and all parties should follow industry guidelines such as those from the Digital Advertising Alliance.
| Category | Requirement | Key Actions | Notes |
|---|
| Location Data | Obtain consent, encrypt data, disclose usage | Use clear notifications; get opt-in consent | Applies to GPS, Wi-Fi, and cell-based location |
| COPPA Compliance | No interest-based ads for under-13s | Label content as child-directed; use appropriate SDK tags | Applies to apps/sites targeting children |
| Ad Quality | Follow Better Ads Standards; avoid spam/malware | Review ad placements; check for misleading experiences | Non-compliant ads may be restricted |
| Sanctions | Avoid business in embargoed regions | Screen partners and users for sanctioned connections | Includes Crimea, Cuba, Iran, North Korea, Syria |
| Privacy Policy | Disclose data practices clearly | Update policy to include cookie use, data sharing | Required for all using Google ad services |
In summary, manufacturers and developers of portable electronic devices in the US must prioritize user privacy, adhere to advertising standards, and follow applicable laws like COPPA. By implementing clear consent mechanisms, maintaining robust privacy policies, and ensuring ad content quality, businesses can foster trust and avoid compliance issues. Regular reviews of data practices and partner agreements are recommended to stay aligned with evolving regulations.
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