Question regarding privacy policy.

Hey, i just released my first app to the Google Play Store using Corona SDK and wanted to participate in the “Designed for Families” program, in which i need a privacy policy.

I am not gathering any information with my app, but if i read correctly, Corona Labs does so, so is it ok if i use this privacy policy for my application ? (https://coronalabs.com/privacy-policy/privacy-policy-for-app-users/)

Suggestions or further information welcomed.

Thank you very much.

Daniel M.

Yes, you can use ours, or write your own saying that you don’t collect anything, but we do and link to our privacy policy.

Rob

Thank you.

I am planning on having a policy and will state I do not collect data but will reference Corona’s privacy policy.  But I wasn’t sure how to make the connection.  What is the best way to explain why I would be directing them to the Corona Privacy Policy?    Does Corona have an Opt Out option?

Analytic Data

If I am going to use analytics to understand how the game is being used, how does that data get collected?  Is it collected by Apple and Google?   Would the company collecting the Analytics collect the data?  Would I need to reference their privacy policy?

Google Analytics and AdMob Data

I am including Ads in my games.  I’m using AdMob in my game so will AdMob collect data for advertising campaigns?  Would I need to reference their Privacy Policy?

Thanks

Lori

We do not have a way to opt out.

DISCLAIMER: Corona Labs cannot offer answers to legal questions like this.  If community members (or staff members) respond to this, they are doing so based on their own knowledge and advice.  They are personal opinions and do not represent Corona Labs.

Here is the Privacy policy that I personally use.

http://omnigeekmedia.com/privacy/

That said, I’m not a lawyer. I’m not your lawyer. Your mileage may vary. No warranties expressed or implied. Maybe other people can chime in with their privacy policies and you can find what works for you… or consult a lawyer.

Yes, you can use ours, or write your own saying that you don’t collect anything, but we do and link to our privacy policy.

Rob

Thank you.

None warranties taken and thanks.  Have a great day.

lgalcott:

Does Corona have an Opt Out option?

Rob Miracle:

We do not have a way to opt out.

Corona Lab’s Privacy Policy

Developers may optionally elect to collect certain information from you through their Apps using various features of the Service.

(emphasis added)

This has been a concern for me too.  It’d be nice if there was an simple statement to the effect of:  “if you don’t included analytics, then no analytics are collected by Corona Labs”.  Or, if that is not the case, then a similar statement to the opposite: “apps built with corona always collect the following analytics…, whether you’ve opted in or not”.  Come on, what is it, optional or not?

Remember way back in the day when Flurry was “built in” and in theory you could disable it with launchPad=false in config.lua – except that it still actually continued to send analytics?  (and could be easily witnessed w a network trace, plus you’d see failed network traffic to analytics.coronalabs.com as plaintext in an adb trace when offline)  The removal of Flurry in default bundle was a huge step in the right direction, but I don’t think things are still disclosed to the degree necessary.

I’ll try to get a clarification on launchPad=false, but the term you selected is simply saying you as the developer may have your own anaylitics or data collection that you do that’s not what we do.

Rob

you have to read it in context…

(though I am not a lawyer, nor do I play one on TV, this is also not my first time reading a legal document)

first, the policy is about your (ie Corona Labs, “our” in context) privacy practices, not those of the developer:

Please read the following to learn more about our privacy practices (“Privacy Policy”).

and by services, they mean Corona Lab’s services, not some other analytics service used by the developer:

By using a mobile application that incorporates or utilizes Corona Labs’ services (collectively, the “Services”) you accept the practices outlined in this Privacy Policy.

so remember that word “Services” - it has a specific legal meaning as defined by this context.

third, and incontrovertibly finally, the policy is about the info “that Corona Labs gathers”, not what the developer may (or may not) gather using other means:

This Privacy Policy covers Corona Labs’ treatment of personally identifiable information (“Personal Information”) that Corona Labs gathers when you access or use the Services.

thus when the policy says that developer may optionally collect data using the “Service” (as defined earlier, and note the continued capitalization here), it’s not talking about someone else’s lowercase “service” that the developer might chose to use. (say, for instance, the use of Google Analytics is not covered by this policy)

But all that legal wording aside:  it would suffice just to have a clear statement of whether (or not) there are ANY analytics collected by Corona Labs that CANNOT be disabled by the developer.

I am planning on having a policy and will state I do not collect data but will reference Corona’s privacy policy.  But I wasn’t sure how to make the connection.  What is the best way to explain why I would be directing them to the Corona Privacy Policy?    Does Corona have an Opt Out option?

Analytic Data

If I am going to use analytics to understand how the game is being used, how does that data get collected?  Is it collected by Apple and Google?   Would the company collecting the Analytics collect the data?  Would I need to reference their privacy policy?

Google Analytics and AdMob Data

I am including Ads in my games.  I’m using AdMob in my game so will AdMob collect data for advertising campaigns?  Would I need to reference their Privacy Policy?

Thanks

Lori

We do not have a way to opt out.

DISCLAIMER: Corona Labs cannot offer answers to legal questions like this.  If community members (or staff members) respond to this, they are doing so based on their own knowledge and advice.  They are personal opinions and do not represent Corona Labs.

Here is the Privacy policy that I personally use.

http://omnigeekmedia.com/privacy/

That said, I’m not a lawyer. I’m not your lawyer. Your mileage may vary. No warranties expressed or implied. Maybe other people can chime in with their privacy policies and you can find what works for you… or consult a lawyer.

None warranties taken and thanks.  Have a great day.

lgalcott:

Does Corona have an Opt Out option?

Rob Miracle:

We do not have a way to opt out.

Corona Lab’s Privacy Policy

Developers may optionally elect to collect certain information from you through their Apps using various features of the Service.

(emphasis added)

This has been a concern for me too.  It’d be nice if there was an simple statement to the effect of:  “if you don’t included analytics, then no analytics are collected by Corona Labs”.  Or, if that is not the case, then a similar statement to the opposite: “apps built with corona always collect the following analytics…, whether you’ve opted in or not”.  Come on, what is it, optional or not?

Remember way back in the day when Flurry was “built in” and in theory you could disable it with launchPad=false in config.lua – except that it still actually continued to send analytics?  (and could be easily witnessed w a network trace, plus you’d see failed network traffic to analytics.coronalabs.com as plaintext in an adb trace when offline)  The removal of Flurry in default bundle was a huge step in the right direction, but I don’t think things are still disclosed to the degree necessary.

I’ll try to get a clarification on launchPad=false, but the term you selected is simply saying you as the developer may have your own anaylitics or data collection that you do that’s not what we do.

Rob

you have to read it in context…

(though I am not a lawyer, nor do I play one on TV, this is also not my first time reading a legal document)

first, the policy is about your (ie Corona Labs, “our” in context) privacy practices, not those of the developer:

Please read the following to learn more about our privacy practices (“Privacy Policy”).

and by services, they mean Corona Lab’s services, not some other analytics service used by the developer:

By using a mobile application that incorporates or utilizes Corona Labs’ services (collectively, the “Services”) you accept the practices outlined in this Privacy Policy.

so remember that word “Services” - it has a specific legal meaning as defined by this context.

third, and incontrovertibly finally, the policy is about the info “that Corona Labs gathers”, not what the developer may (or may not) gather using other means:

This Privacy Policy covers Corona Labs’ treatment of personally identifiable information (“Personal Information”) that Corona Labs gathers when you access or use the Services.

thus when the policy says that developer may optionally collect data using the “Service” (as defined earlier, and note the continued capitalization here), it’s not talking about someone else’s lowercase “service” that the developer might chose to use. (say, for instance, the use of Google Analytics is not covered by this policy)

But all that legal wording aside:  it would suffice just to have a clear statement of whether (or not) there are ANY analytics collected by Corona Labs that CANNOT be disabled by the developer.