Mobile App Advertising Guidelines

Download PDF version of Mobile App Advertising Guidelines

Highlights

  • The mobile ecosystem is innovating at a rapid pace, as it continues to evolve it’s important that standards are developed to ensure that the mobile ecosystem can continue to thrive while private user data is accessed and managed appropriately.

  • The Mobile Ad Guidelines hope to establish a set of mutually agreed upon standards and guidelines to help those building and integrating in-app mobile ad technology.

  • At-a-glance, the guidelines cover requirements and suggested best practices around transparency and clarity of data collection, individual control over information collected, ad delivery and display behavior, collection and retention of personal or device-specific data, and secure transport of sensitive data.

  • Implications of these guidelines would require the following of ad providers:

    • Provide comprehensive, readable privacy policies and related FAQs to their app publishing partners, making educated integration easier for app developers

    • Provide a conspicuous notice to users and gain explicitly informed consent from within the mobile app if the ad provider intends to access personal information like phone number, email and name.

    • Provide clear attribution to the host application for ads that appear out-of-app. Ad providers that modify browser settings or add an icon to the mobile desktop must provide conspicuous forms of notice to users and gain explicitly informed consent before such behavior is triggered.

    • Move away from using permanent, unchangeable device identifiers and move towards using independent and/or temporal device identifiers that provide the same level of functionality with respect to targeted advertising.

    • Do not collect device identifiers that are tied to mobile subscriber identities unless the collection of such identifiers enables a demonstrable feature or service for the user.

    • Securely transport personal information, including device identifier data and personal information.

Introduction

Why do we need mobile app advertising guidelines?
Mobile devices – and the apps contained within them – are increasingly “always on,” collecting valuable information such as location, communications records, social circles, and browsing preferences. In many ways, this information is the lifeblood of the mobile ecosystem: not only can it be coalesced to deliver incredibly informative, relevant, and delightful experiences for mobile users, but it can provide value to mobile advertisers to help fuel the mobile economy.

The importance of ad revenue in technological innovation cannot be understated. It fuels search giant Google and makes thousands of free applications and services possible. While this concept is fairly well understood by users of larger, more popular products and services, it’s often less clear that these same relationships exist for large and small businesses alike: up-and-coming mobile App Publishers looking to monetize their apps are often reliant on the same business model that Facebook uses, only without the massive userbase. The result is even more pressure on mobile developers and publishers to make their ads as valuable as possible.

Consequently, some advertisers have begun to experiment with aggressive new techniques for delivering targeted mobile ads or gathering increasing amounts of user data from mobile devices. Given the pace at which the mobile ecosystem is moving, it’s important that standards are developed to ensure that private user data is accessed and managed appropriately, and that controversial behavior is properly highlighted.

The intent of this document is to establish a set of mutually agreed upon guidelines to help those building and integrating in-app mobile ad technology to understand what is acceptable, and what is not. Each of the participants in the mobile ecosystem – Ad Providers, App Publishers and end users – has a role to play in the establishment and enforcement of these guidelines. Our hope is that they will result in a mobile ecosystem that is self-regulatory in nature.

Guidelines Definitions

These guidelines are primarily focused at two major groups in the mobile ecosystem: Ad Providers and App Publishers. The following definitions provide context behind each of these groups.

 

  • App Publishers – Includes the parties responsible for the development, publishing, and maintenance of mobile applications.
  • Ad Providers – Primarily includes ad networks that are commonly embedded in mobile applications to manage ad delivery. Also includes mobile ad mediation layers, which manage the delivery of mobile advertisements across a number of distinct ad networks. This group also encompasses Ad Exchanges / Supply Side Platforms (SSPs) and Demand Side Platforms (DSPs) in cases where such groups collect, use, and retain device- or user-specific information.

Guidelines at a Glance

While many of the specific guidelines and examples within this document have the potential to shift as user expectations evolve within the mobile context, the following principles should be adhered to wherever possible. Many of these recommendations have been particularly well articulated within the Obama Administration’s Consumer Data Privacy Framework, the EFF’s Mobile User Privacy Bill of Rights, and the joint CDT/FPF App Privacy Guidelines.

While this is not an exhaustive list of all the absolute requirements for App Publishers or Ad Providers, the items outlined below cover the most salient requirements to consider when handling personal information and exploring new forms of advertising.

The guidelines can be broken down into the following high-level categories:

  • Provide Transparency and Clarity to users about data collected, and present such information in a way that is readily accessible, easily understandable, and actionable by average users. The agreement to mandate specific privacy policy documentation for mobile apps is a start, but to be truly useful these privacy policies must be adapted for a mobile experience. In cases where Personal Information is collected (which can include name, phone number, email address, fine-grained location information, or more), simply providing detailed privacy policies may not be sufficient and requires gathering informed consent from users through the use of conspicuous, clear notification techniques prior to enabling data collection. This guideline has clear implications for App Publishers, but is especially important for Ad Providers, with whom mobile users rarely directly interact knowingly. When integrating with Ad Providers, App Publishers are responsible for ensuring that their users are properly notified of the privacy, security and usability implications that embedded third-party Ad Providers pose.

  • Enable Individual Control – Mobile users must be able to exercise control over what identifying data is collected by Ad Providers, and how it is used. This is tied closely to Transparency & Clarity, in that App Publishers must make it easy for users to understand what tools are available to them by communicating this from within the mobile app itself. In addition, mobile users should have the ability to withdraw consent from Ad Provider data collection and usage through accessible controls.

  • Provide Context and Control when experimenting with new Ad Delivery Behavior. Mobile Ad Providers have recently started to explore new methods of ad delivery, including delivering ads in the system notification bar (also known as “push” notification ads), placing new icons or shortcuts on the mobile desktop, and modifying browser settings such as bookmarks or the default homepage. When an ad is delivered outside the context of an individual application, mobile users have a right to know where the ad came from and how they can take action to control such behavior. More specifically:

    • Ad Providers experimenting with push notification ads must provide clear attribution to the source host application responsible.

    • Ad Providers that modify browser settings or add an icon to the mobile desktop must provide clear, conspicuous notice to users and gain explicit consent prior to doing so.

  • Focused Data Collection – Ad Providers should respect reasonable limits on the collection and retention of data collected from end user devices. The collection, usage, and storage of data that can be used to uniquely identify a user or their device must be performed in ways that are consistent with the context in which users provide that data, and accompanied by methods of user notice that reflect the relative privacy implications of such data. More specifically:

    • Ad Providers should move away from using unchangeable device identifiers and should move towards using independent and/or temporal device identifiers that provide the same level of functionality with respect to targeted advertising.

    • Ad Providers must not collect subscriber-specific identifiers such as MSI or MSISDN, unless the collection of such identifiers enables a demonstrable feature or service for the user (such as carrier-billing).

  • Transport Security – Device or user identifying data must be secured and handled responsibly at all times by both App Publishers and Ad Providers. Common security best practices such as transport layer encryption and forward hashing should be a minimum standard. Mobile users have a right to expect accountability from all members of the mobile ecosystem, including Ad Providers and application developers. More specifically:

    • When collecting unique device identifiers that are permanent and unchangeable by a user, Ad Providers MUST hash such identifiers using a generally accepted secure hashing algorithm and a unique salt.

    • When collecting Personal Information such as email address or phone number, Ad Providers MUST transmit it securely using transport layer security (TLS / SSL).

Guidelines Prioritization Framework

In this document, the key words “MUST”, “MUST NOT”, “REQUIRED”, “SHALL”, “SHALL NOT”, “SHOULD”, “SHOULD NOT”, “RECOMMENDED”, “NOT RECOMMENDED”, “MAY”, and “OPTIONAL” are to be interpreted as described in BCP 14, RFC 2119. They are used to provide an indication of the level of importance of a requirement within the context of the guidelines in general. Overall there are two main priority levels for these guidelines that should be stressed:

  • Absolute Requirements constitute the minimum level of behavior that App Publishers and/or Ad Providers must follow to be in compliance with these guidelines. Largely associated with the key words “MUST”, “MUST NOT”, “REQUIRED”, “SHALL”, and “SHALL NOT”.

  • Recommended Requirements constitute general best practices that App Publishers and/or Ad Providers should follow wherever possible. Associated with the key words “RECOMMENDED”, “NOT RECOMMENDED”, “MAY”, and “OPTIONAL.”

Target Audience for Guidelines

While this document does contain a selection of guidelines for mobile application developers, it is not intended to serve as a comprehensive reference for that audience, and there is a large set of guidelines that application publishers should consider, such as those provided by the Application Developers Alliance.

Due to the complex interdependencies between App Publishers and Ad Providers, a number of guidelines and best practices within this document are only applicable to specific parties. Wherever possible we have made an effort to make this distinction clear.

Transparency and Clarity

First and foremost, App Publishers must provide straightforward information regarding data collection, use, disclosure and retention that is easily accessible from within their application. Such statements must also encompass the same information for any included analytics or advertising SDKs – including Ad Providers – and should be phrased in plain language understandable by the average consumer. Done properly, this type of disclosure should help mobile users understand what data is collected, who collects it, how it is collected, and how it is used (or shared).

Notice of Third-Party Data Collection

It’s common for App Publishers to integrate third-party code such as Ad Provider or ad analytics SDKs without providing any relevant context for how that code may affect user data collection and privacy. Some Ad Providers mandate the inclusion of specific copy within an application’s market description. While making the app deployment process easier for App Publishers (developers), this is often as ineffective as standard, long-form privacy policies, as the majority of mobile users do not take the time to read length app market descriptions. Data collection and usage that falls outside the reasonable expected context of an application – especially third-party data collection – should be signaled in an even more conspicuous manner that facilitates user understanding. In Focused Data Collection, we outline what data metrics are considered reasonable to collect from users, and what metrics require additional clarification for users and App Publishers alike.

Often, insufficient or inaccurate descriptions of third-party code within an application can be the result of an app publisher not fully understanding the implications of a given library or SDK. To this end, Ad Providers should provide a clear statement of data gathered and gating criteria (e.g. permissions required in the Android declarative permission model) with the goal of providing clarity to App Publishers regarding the additional impact that including their code may have on the privacy posture of their applications. While it is incumbent on developers to include this information and in user disclosures of data collection and usage practices when integrating these SDKs into an application, Ad Providers should take a proactive approach to assisting developers in this endeavor.

Notice of Ad Delivery Behavior

In cases where third party libraries enable the delivery of non-standard or unexpected mobile ads (reference Ad Delivery Behavior for specific types of ads), App Publishers must follow similar practices of providing clear, conspicuous notice of such practices to users.

Examples of Transparency and Clarity

Startapp Notice

Startapp, a mobile Ad Provider that uses non-standard ad delivery methods to monetize applications through advertising, provides one of the best examples of transparent and clear notice to users about their practices to properly set user expectations. This includes mandating clear notification within an application’s description as well via a clear License Agreement on initial run of the app. Relevant information about non-standard ad delivery via desktop icons is presented above the fold for most device types, in clearly bulleted format.

Mobile App Ad Guidelines
Figure 1. Startapp notice of non-standard monetization methods

TRUSTe Privacy Policy Template

The mobile privacy policy template offered by TRUSTe provides a clear, digestible framework for presenting an accurate view of privacy implications for mobile users. It segments privacy concerns into information buckets that are most relevant for mobile users – including location services, tracking and ads, and security. In addition, it provides a clear mechanism to directly address the collection and use of identifying information.


Figure 2. TRUSTe mobile privacy policy example

Guidelines for Transparency and Clarity

Absolute Requirements

App Publishers (developers)

  • App Publishers MUST provide clearly visible, understandable information regarding data collection, use, disclosure and retention that is easily accessible from a mobile context.

  • App Publishers MUST include data collected by third parties such as Ad Providers within the scope of data collected by their application.

  • App Publishers MUST keep such notice up-to-date with functional changes to external libraries or SDKs.

  • In circumstances where third party libraries collect Personal Information (reference Focused Data Collection below) or deliver non-standard or unexpected advertisements (reference Ad Delivery Behavior), App Publishers MUST provided conspicuous notice and gain end user consent to such behavior prior to performing data collection.

  • App Publishers creating applications directed at children MUST provide clear notice of information collection behaviors of any external third party libraries and MUST gain consent from parents before such behaviors are enabled.

Ad Providers

  • Ad Providers MUST have clearly visible, understandable information regarding data collection, use, disclosure and retention that is easily accessible by consumers and App Publishers on their website.

  • Ad Providers MUST provide clear and proactive notifications to publishers on impact of changes to their SDKs

Recommended Best Practices

App Publishers

  • App Publishers SHOULD display information related to data collection by third parties or unexpected non-app publisher sources in a manner that makes this distinction clear and obvious.

Ad Providers

  • Ad Providers SHOULD provide guidance to App Publishers around privacy implications of their capabilities, preferably in a format that makes it easy for App Publishers to consume and re-use, such as a privacy policy template.

Enable Individual Control

Beyond including straightforward, communicative information regarding data collection and use, it is essential that Ad Providers enable user controls over data collection and usage. Such controls should include – but not be limited to – the following:

  • User-friendly controls to select targeted / interest-based advertising preferences, including the ability to opt-out of such targeting

  • Mechanisms to withdraw consent to use personal or device specific information that has previously been collected

  • We understand that there may not be a way to effect a withdrawal of consent in the event that an Ad Provider does not retain exclusive control over data collected, or if the data collected cannot reasonably be associated with an individual.

Such controls should be made available to users through means and level of access that are roughly equivalent to those used to originally obtain or gain consent, preferably through straightforward, single-touch actions on a mobile form-factor.

Relevant Example of Enabling Individual Control

The TRUSTe Mobile Ads program is one of the most straightforward and fully-functional tools providing these user controls. Through the use of a consistent ‘AdChoices’ icon across partner advertisements, it provides a simple page where users can opt-out of collection and targeting from an individual network, or from all of TRUSTe’s partners. Those preferences are then remembered and enforced across all partners.


Figure 3. Example of good communication mechanism for to users: TRUSTe Mobile Ads ‘AdChoices’ preferences

Guidelines for Enabling Individual Control

Absolute Requirements

Ad Providers

  • Ad Providers MUST provide readily available opt-out mechanisms that allow users to control third party collection of Personal Information (reference Focused Data Collection below).

  • Ad Providers MUST provide readily accessible materials that clearly outline the presence and effect of any available user data controls, including opt-in/-out capabilities, as they relate to data collection, use, disclosure and retention, or non-standard ad delivery.

  • Ad Providers MUST gain additional consent from users in instances where data is used for purposes that differ from those it was originally collected for.

Recommended Best Practices

Ad Providers

  • Ad Providers SHOULD provide readily available mechanisms that allow users to control third party collection of device specific information.

  • Ad Providers SHOULD respect the context of mobile and ensure that any control mechanisms they provide are fully accessible and configurable from mobile devices.

  • Ad Providers SHOULD respect the context of mobile and ensure that any control mechanisms they provide are fully accessible and configurable from mobile devices.

  • Ad Providers SHOULD work towards the development of a single cross-network interface to allow users centralized management of their mobile ad preferences across a variety of Ad Providers.

  • Ad Providers SHOULD begin to work towards developing a cross-provider persistent opt-out mechanism for both mobile web and mobile application-based advertising.

Ad Delivery Behavior

As the smartphone app model has evolved, advertising has continued to be a solid source of revenue for mobile developers seeking to offer free applications. For the vast majority of these applications, advertisements have been constrained to appear solely within the confines of an individual application’s context. Recently, new and aggressive ad delivery techniques have emerged that include but are not limited to the following:

  • Delivering ads within the standard device notification bar (also known as “push” notification ads)

  • Inserting new icons or shortcuts on the mobile desktop

  • Modifying browser settings like bookmarks or the default mobile homepage.

In addition, many Ad Providers are deploying new types of functionality linked to ad touch actions, including triggering of outgoing phone calls, text messages, or creation of calendar events.

These new tactics can often perform at better rates than traditional in-app display ads and can create new options for monetization. As a result they have increased in prevalence.

Application Coupling

The guidelines below distinguish between advertising access points that are coupled with a specific application, and access points that are not. This distinction has important consequences related to the expected user experience specifically related to the removal of such access points.

  • Coupled Access Points use a specific hosting application to access the web. The removal of the application will directly influence ad serving or stop it completely. This category includes techniques such as notification ads.

  • Decoupled Access Points do not rely on a specific hosting application to function properly. The removal of the application that created such access points will not affect ad serving. This category includes techniques such as icon ads or browser modifications.

Transparency

Each of these delivery techniques occurs outside the context of any individual application, making it difficult for a user to identify the specific application responsible or take action to permanently disable ad serving. As an example, the average user has no contextual basis for advertisements that are delivered through their notification bar apart from the content contained within the ad itself. We’ve seen that such lack of attribution increasingly results in user confusion and / or frustration.

If these methods of mobile advertising are to become broadly accepted within the mobile ecosystem, it is crucial that any advertising that is done outside of an app contains significant additional methods of transparency for users.

  • Coupled Access Points (such as push notification ads) are directly dependent on a host application to function. Such advertising methods must provide clear attribution to the host application to enable user controls.

  • Decoupled Access Points (such as search shortcuts or icons) are independent of a host application. As such it is essential for such advertising methods to provide clear opportunities for informed consent to users upon application installation and runtime. Providing clear instructions on how to remove decoupled access points is also important.

User Controls

Done right, transparency provides a user with a clearly defined set of actions to take if and when they wish to remove any specific advertising access point. While simply removing an application or advertising access point is one option for users, another option is to control delivery behavior through specific settings or controls.

Guidelines for Ad Delivery Behavior

Absolute Requirements

Ad Providers

  • Advertisements delivered outside the context of an individual application via coupled access points MUST provide clear attribution to the host application. It is incumbent upon Ad Providers to work closely with its app publishing partners to enable conspicuous notice to users, gain appropriate consent, and provide attribution in such cases.

  • Ad Providers serving advertisements delivered outside the context of an individual application via de-coupled access points MUST provide clear indication of such behavior and gain informed consent from users prior to ad delivery.

  • Ad behavior that modifies device settings or desktop MUST be clearly communicated and strictly opt-in.

  • Ad Providers that deliver advertisements outside the context of an individual application MUST provide an opt-in / opt-out mechanism for mobile users that is accessible from a mobile context.

  • Ad Providers MUST ensure that advertisements that direct to out of band processes (such as touch-to-call or touch-to-sms ads) have clear notice of their behavior and require affirmative user action before the resulting process occurs (e.g. modal confirmation dialog before phone call is placed).

  • In instances where opt-out mechanisms cannot automatically remove advertising access points, Ad Providers MUST provide conspicuous, simple, readable guidance to users regarding how to remove them.

Recommended Best Practices


App Publishers

  • App Publishers integrating with Ad Providers that deliver advertisements outside the context of an individual application SHOULD provide advertisement opt-in/-out mechanisms that are accessible from the app itself.

Ad Providers

  • Ad Providers that deliver advertisements outside the context of an individual application SHOULD provide an option for users to stop receiving advertisements that is independent of the hosted application.

  • Ad Providers SHOULD ensure that advertisements that direct to out of band processes (such as placing phone calls or sending SMS) do so through clear, individual opt-in consent each time a user clicks them. While it is reasonable for such consent to be applied across an individual application as a one-time acceptance, Ad Providers SHOULD NOT apply such consent across application contexts.

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