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Things to know

  • Canadian privacy laws apply to the collection, use and disclosure of personal information through mobile apps
  • Privacy regulators have issued detailed guidance on how they expect app developers to overcome the challenges of small mobile device screens and the speed of the mobile app development cycle
  • Mobile app developers have been targeted in compliance sweeps by regulators

Things to do

  • Build privacy (including compliance with regulatory guidance) into the design of your app
  • Use layered, just-in-time notices, and avoid relying on disclosures in your privacy policy
  • Tell potential users what personal information will be collected and why, where it will be stored (on the device or elsewhere), who it will be shared with and why, how long you will keep it, and any other issues that will affect user privacy
  • Avoid collecting location information without express consent
  • Avoid collecting unique device identifiers not essential to the functioning of the app
  • Review the use of cross-app identifiers for compliance with online advertising requirements
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