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Tims quick guide to Adsense privacy policy

ventureskills
Wed 19 March 2008, 10:14 am GMT +0100
It's time for another Tim guide I think as always please remember I'm not a lawyer! If you want an overview of what information you should have in generic policies not just legal documents try my Guide to Affiliate site Legal Notices

Adsense Privacy policy
As from the end of February 2008 Google Adsense all website owners to provide a transparent privacy policy for those of us in the EU this is nothing new we have been required to have privacy policy on any "commercial site" for a while now. Many will however be caught out, as usual it would appear Google has provided a grace period and as of 19/3/08 no one has had their account suspended for lack of policy. However expect this to change in the coming months.

What is a privacy policy?
So what is a privacy policy and how does it effect your site? Put simply its a statement on your site explaining how you handle information and in this case who you are providing information to. A privacy policy does not need to be a comprehensive document explaining every piece of information and how its collected, used etc just a generic document.

What do I need to collect before I start
Most privacy policy generators and sample Adsense privacy policies I have seen are hashed out rubbish which would not stand up in a light breeze. It is therefore in our interest to create a more water tight policy which we can use on all our sites. Given that many people here have more then 1 site I will presume this policy is for a network.

For each site you will need it URL, Name if different, its Host, The Name Registered on the WHOIS
You will also need which Stats package you are using, Payment Processor (Paypal for example) and finally advertisers.

If you use widgets such as Blog Catalog and MyBlogLog make a note we have to deal with them separately. Note if you installed MyBlogLog then it is both a Widget and a Stats collection package.

Make it Global
Most people have a main site and several satellite sites each using the same set of tools it makes sense to group them together. Before you do a word of warning each site will be obviously linked via the privacy policy if you run a series of web development blogs and a series of Proxies you might want to separate them into two groups.

Sample Policy
/*We will be using a modified and simplified version of http://www.webdigity.com/index.php/topic,6132.0.Privacy+and+You%21.html */

-----------------------------
Global Privacy Policy for [Insert Group Name]
/*Indicate each site by NAME, URL, WHOIS OWNERS NAME */
[NAME](URL) owned by [WHOIS],[NAME] (URL) owned by [WHOIS],...

The above named sites are governed by all the rules and regulation of the country of [YOUR COUNTRY AND HOST COUNTRY]. The site is owned and maintained by [YOUR NAME/COMPANY NAME] and any enquires regarding privacy should in the first instance be directed to [PRIVACY EMAIL].
Please note we hold all data for the minimum period of time prescribed by law for our country of origin any personal data that is held in a public facing part of the site can be removed if request in writing is made to the address below, please note a small administration charge may be applied.

Tracking of data
The above named sites use the following tracking services
/* Identify your stat trackers so Google Analytics (Google,USA), MyBlogLog (Yahoo, USA), Wordpress.com stats (Automatic, USA) */
[STAT PACKAGE] ([OWNER], [COUNTRY data resides]), [STAT PACKAGE] ([OWNER], [COUNTRY data resides]) ...
to help analyse how users use the sites. These analytical tools can uses 'cookies', which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including your IP address) is transmitted to Statistic providers. This information is then used to evaluate visitors use of the website and to compile statistical reports on website activity.

We will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our sites. We will not associate any data gathered from these sites with any personally identifying information from any source as part of our use of any statistical analytics tool. Our Statistic providers will not associate your IP address with any other data held by them. Neither the us nor our statisitcal providers will link, or seek to link, an IP address with the identity of a computer user.

3rd party tracking
/* Mybloglog, Blog Catalog, Blog Rush */
Some of our sites are part of [INSERT WIDGETs] programs which track and collect information of users signed in to their service over a series of web sites. These services are covered by their own privacy policy as detailed on their site and only track users signed into their services.

Advertising
Some of our sites are supported through sponsorship and contextual advertising our current advertising partners are;
/* NAME, LOCATION, TYPE of advertiser Google Adsense (USA) Contextual, Joe Blogs (UK) Static */
NAME (LOCATION) TYPE, NAME (LOCATION) TYPE, NAME (LOCATION) TYPE

Some of these advertisers may use technology such as cookies and web beacons when they advertise on our site, which will also send these advertisers information including your IP address, your ISP , the browser you used to visit our site, and in some cases conditions of your browser such as the inclusion of Flash. Many Advertisers use Geo-targeting technology (using your IP address to provide a location) to allow them to provide targeted offers as well as providing adverts tailored to the content this is referred to as contextual advertising.

/* Payment Processing - Delete if you don't handle payments on sites please note this is valid only if you do not store credit card information! if you do contact a lawyer */
Payments
All payments are handled by the following payment processors
/* NAME LOCATION Paypal US, Paypal UK, Google Checkout US */
NAME (LOCATION), NAME (LOCATION),
Each payment processor is goverened by their own Privacy Policy and we do not record or keep personal financial information such as Credit Card, addresses on our sites.

Disputes
If you require information or believe an error has been made within this document you should in the first instance contact [EMAIL] or via a letter to
Address
[ADDRESS]
We take your privacy seriously and do not sell or use your data in a way that could be considered inappropriate both morally and in the eyes of the governing laws.

-------------------

So there you go fill it in, put it on your main site, for each of your satellite sites link to it with the anchor text "Privacy Policy" and don't forget to nofollow those links, otherwise you will see your privacy policy ranking in the SERPs which would be a bit silly also I tend to prefer not to draw attention to such things after all you are announcing all this info to potential competitors. A few other things to think about.

Individual pages
If you have a site that is using an advertising, stats, or payment processor that is different then the above you don't have to change the global policy, simply add a privacy policy to that page with the following at the top.
----------
This privacy policy is in addition to the Full global policy outline on [FULL URL] for [COMPANY NAME] this additional policy is specific for [CURRENT SITE] which resides on [HOST]

Additional Policy Information....
----------
Additional Policies
While your organising a global Privacy policy you might also want to create a few other global policies such as Comments (for blogs), Accessibility (Required in EU), and perhaps a Link Policy. One thing I have found to work well is a network home. Where you list all the sites within a network a little bit of an about page a central location to offer advertising over the network and the various policies.

Any questions let me know, I should add a few resources so here is Jensense idea of a privacy policy  and a Wordpress plugin I would reiterate always do these things by hand and the plugin is for reference only

olaf
Wed 19 March 2008, 07:13 pm GMT +0100
check this information too:

http://adsense.blogspot.com/2008/03/terms-and-conditions-clarification.html

Nikolas
Wed 19 March 2008, 07:27 pm GMT +0100
Tim thanks for the useful information :)

I am still have no time - and to be honest I am a little bored - to add privacy policy to my sites, but I guess I will add one soon :)

vbignacio
Fri 21 March 2008, 10:51 am GMT +0100
i have seven sites and two more to go and im done.

olaf
Fri 21 March 2008, 10:59 am GMT +0100
i have seven sites and two more to go and im done.

:) you're a hard worker...

GiorgosK
Fri 21 March 2008, 05:50 pm GMT +0100
Tim
I didn't see your privacy policy on your blog ?
did you create one ?
Is the 25 march a real deadline ?
I have not seen it anywhere !!

ventureskills
Fri 21 March 2008, 07:41 pm GMT +0100
I said as of the date I wrote the post no one had been banned for not having one, I didn't say that was a magic date, just covering bases in case some one reads this in 5 months time and some one had been banned by then.  Both venture skills, paymentblogger.com and timnash have privacy policies though none of them have adsense on them as do all my adsense based site which I do not publicise for obvious reasons

GiorgosK
Sat 22 March 2008, 09:23 am GMT +0100
Duh
you are right !!
timnash.co.uk does not have adsense on it !!!
Thanks for the answer !!

ventureskills
Sat 22 March 2008, 11:27 am GMT +0100
The sites where I do not have adsense or a real need for people to see such policy i.e its not being manually reviewed or potentially reviewed, I tend to hide my privacy policies deep in the about section. Though I could follow my own advice and at least organise my personal sites into a global policy.

ventureskills
Mon 14 April 2008, 02:24 pm GMT +0200
Just to let people know I have added a lot more information on creating generic legal notices on Payment Blogger http://paymentblogger.com/2008/04/14/legal-notices/

Nikolas
Mon 14 April 2008, 09:36 pm GMT +0200
Nice job Tim, thanks :)

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