Game-of-telephone privacy policy
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When a consumer reviews a privacy policy, this privacy policy is supposed to inform the consumer what data will be collected, and how the data will be used. A game-of-telephone privacy policy constitutes a situation whereby a consumer's agreement with an app developer may be different between the app developer's agreement with a third party. For instance:
- Third party says that data collected using their SDK can be used to determine insurance rates by insurance providers.
- Third party licenses SDK to app developer who agrees to these terms.
- App developer says to app user that application collects location data just to provide me in-app services & that it may be shared with third parties.
- App developer never discloses to app user that collected data will be used to determine app user's insurance rates.
- App developer does not meaningfully disclose relationship with third party in their terms of service.
This is akin to me agreeing with my friend James that we may engage in violent behavior. You become friends with my friend James. Therefore, as a result of your friendship with James, it becomes implied that you have agreed to violent behavior.
An excellent example of this would be the relationship between Arity (a business that sells data-collection SDKs), the mobile apps that use Arity SDKs, and the user of those mobile apps, mentioned in the Allstate Arity driver data theft case.