Privacy notice under GDPR and CCPA¶
For a product that collects personal data from users in the EU and the US and needs one privacy notice with the EU content and the US state supplements, plus a cookie notice.
Example request¶
Our app is used in Germany and across the US. We collect account data, usage analytics through a US SDK and
heart rate from a connected wearable. We show personalised ads to adults. Please draft our privacy notice and
cookie notice for the EU and the US.
What the skill does¶
- GDPR content. The notice follows Articles 13 and 14: controller and contact, purposes with their legal basis, recipients, transfers, storage periods, the data subject rights and the right to complain. Each purpose gets its own legal basis; the skill does not put several purposes under one.
- Sensitive data. Health-related data such as heart rate is flagged for Article 9 treatment.
- Consent for tracking. Reading or storing information on a user's device needs consent under ยง 25 TDDDG unless an exception applies. Personalised advertising rests on consent, in line with the EDPB guidance the reference files cite.
- California. The CCPA notice at collection and privacy policy content, the opt-out of sale and sharing, and the CalOPPA duties, once the thresholds are known.
- Other US states. Virginia, Colorado, Connecticut and Texas from their own statutes, the remaining state laws from the matrix. Each state is read from its own thresholds and its own consumer definition; a total of US users does not tell the skill how many live in each state, so it asks.
- Children. If children or teenagers are in the audience, the GDPR consent age rules and COPPA come in; if not, they stay out.
Documents¶
Privacy notice with EU core and US state supplements, cookie notice, annotations, open points and an implementation register (consent banner behaviour, opt-out links, records of consent, response process for rights requests).
Related: subscription app terms, SaaS terms for the EU and the US.