sensitive personal info

sensitive personal info

Personal and sensitive user data includes, but isn’t limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts SMS and call related data, microphone and camera sensor data, and sensitive device or usage data. If your app handles sensitive user data, then you must:

Limit your collection and use of this data to purposes directly related to providing and improving the features of the app (e.g. user anticipated functionality that is documented and promoted in the app’s description).


Post a privacy policy in both the designated field in the Play Console and within the app itself. The privacy policy must, together with any in-app disclosures, comprehensively disclose how your app collects, uses, and shares user data. Your privacy policy must disclose the type of parties to which any personal or sensitive user data is shared.


Handle all personal or sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).


Prominent Disclosure Requirement

In cases where users may not expect that their personal or sensitive user data will be required to provide or improve the features of your app, you must meet the following requirements:

Your app must provide an in-app disclosure of your data collection and use. The in-app disclosure:

Must be within the app itself, not only in the Play listing or a website;
Must be displayed in the normal usage of the app and not require the user to navigate into a menu or settings;
Must describe the data being collected;
Must explain how the data will be used;
Cannot only be placed in a privacy policy or terms of service; and
Cannot be included with other disclosures unrelated to personal or sensitive data collection.


Your app’s in-app disclosure must include a request for user consent. The app’s request for consent:

Must present the consent dialog in a clear and unambiguous way;
Must require affirmative user action (e.g. tap to accept, tick a check-box, a verbal command, etc.) in order to accept;
Must not begin personal or sensitive data collection prior to obtaining affirmative consent;
Must not consider navigation away from the disclosure (including tapping away or pressing the back or home button) as consent; and
Must not utilize auto-dismissing or expiring messages.
Here are some examples of common violations:


An app that accesses a user’s inventory of installed apps and doesn’t treat this data as personal or sensitive data subject to the Privacy Policy, Secure Transmission, and Prominent Disclosure requirements.


An app that accesses a user’s phone or contact book data and doesn’t treat this data as personal or sensitive data subject to the Privacy Policy, Secure Transmission, and Prominent Disclosure requirements.


Specific Restrictions for Sensitive Data Access

In addition to the requirements above, the table below describes requirements for specific activities.

Activity Requirement
Your app handles financial or payment information or government identification numbers Your app must never publicly disclose any personal or sensitive user data related to financial or payment activities or any government identification numbers.


Your app handles non-public phonebook or contact information We don’t allow unauthorized publishing or disclosure of people’s non-public contacts.


Your app contains anti-virus or security functionality, such as anti-virus, anti-malware, or security-related features Your app must post a privacy policy that, together with any in-app disclosures, explain what user data your app collects and transmits, how it’s used, and the type of parties with whom it’s shared.