Location, location, location

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Does your app collect users’ locations? Is that happening even when they’re not using the app?  Savvy developers understand the importance of giving consumers a clear picture of what’s going on. The FTC has advice on making your practices more transparent.

Consumers get that an app giving driving directions will have to know their location to offer the best route. But they may not be aware that an app may be collecting that data when they’re not using it. Companies have different reasons for collecting location information when the app isn’t in use. A weather app may track where users are so it can pull up the local forecast in an instant. Or a shopping app may send a push notification when the user is near a store having a sale.

It’s unwise to assume that users understand what’s happening behind the scenes. Consumers using devices that run Apple’s iOS8 operating system will get system-level disclosures with some information about this type of collection after they install your app, but consumers using the current version of the Android operating system won’t.  Here are some tips on ways to explain your practices and offer choices to consumers.

  • If a consumer downloads your app through the iOS8 system, the app can’t access location when it’s not in use unless the consumer affirmatively allows it in response to a system-level prompt. The dialog box for this prompt includes space for details. That’s a good place to clearly explain why you want to access this information, how you will use it, and if you share it.
  • What if your app is available through an operating system that doesn’t provide system-level disclosures and choices about this type of location collection? You can use the app itself to explain your practices and offer choices. For example, before you start collecting location data when the app isn’t in use, give users an in-app notification that explains why you want to access the information and gives them opportunity to opt in.
  • Regardless of what platform consumers use to get your app, your privacy disclosures and other information pages offer another place to spell out your practices. Ditch the legalese and tech jargon. Explain in language people will understand whether you collect their location when they’re not using the app and what you use that information for.

If you access users’ locations when they’re not using your app, it’s a good idea to clearly disclose what you’re doing and provide users with choices.



I am tired of my personal information information being breached. Can consumers file a law suit. In the last 5 years, the IRS, Bank of America (twice), SunTrust and now Equifax has been careless with my personal information, i.e. SSN, DOB, address and other personal information. This has got to stop. Thank you. Rudell R. Ferguson

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