Supporting the Google EU consent policy

The following integrations are relevant to Google's new EU consent policy:

• Google Ads (googleadwords_int)
• GMP DV360 (dv360_int)

If end users of your apps from these integrations are based in the European Economic Area (EEA), make sure to take the necessary actions to comply with the requirements of Google's new EU consent policy.

Marketers need to obtain consent from end users in the EEA for the use of personal data to keep using Google Ads and GMP DV360 features related to measurement, ad personalization, and remarketing.

The AppsFlyer SDK (Android - v6.13.0+, iOS - v6.13.1+) can send the necessary consent data with each event to meet Google's requirements.

• Upgrade your SDK to the latest version (Android - v6.13.0+, iOS - v6.13.1+), Applicable to Android or iOS apps.
• Once the SDK is upgraded, see here implementation instructions for supporting the DMA.

Marketers have two options to send the required consent data to AppsFlyer:

• Directly via the SDK or an S2S API: Marketers can send the consent data directly to AppsFlyer using the SDK. Applicable to Android or iOS apps.
• Via TCF Strings: Marketers who currently use or plan to use a Consent Management Platform (CMP) can send the data fields through standard IAB TCF strings (TCF V2.2). Make sure to include the Google vendor ID (755) in the list of consented vendors. 

AppsFlyer then enables customers to transmit the consent signals to Google. However, it is important to note that AppsFlyer does not collect, alter, or control end-user consent. Marketers working with Google are responsible for collecting the necessary consent fields.

See this video on how to send consent data to AppsFlyer.

End-user consent values are sent to Google for the relevant AppsFlyer integrations (googleadwords_intand dv360_int) using the following fields:

1. See Google’s definition for each field.
2. When DMA doesn't apply to the user, AppsFlyer suggests refraining from sending consent fields other than gdpr_applies=false

AppsFlyer enables advertisers, where they believe the DMA requirements don’t apply to their end-users (for example when they are non-EU), to prevent sending consent data to Google. This is done by activating a toggle in the relevant integration pages.

To refrain from sharing consent data with Google:

1. In AppsFlyer, from the side menu, select Collaboration > Active Integrations.
2. Search for the partner and click Manage integration.
3. From the integration setup tab, turn on Non EU users

At this stage, only mobile app events are shared with Google so there's no need to share with AppsFlyer consent for web events. If users progress from the web to your app, their consent will be collected within the app at a later stage regardless.

The Digital Markets Act (DMA) applies to users within the EU and EEA (European Economic Area), impacting these countries. Although the UK and Switzerland are not part of the EU, Google has unilaterally extended its consent policy to include those countries as well.

AppsFlyer recommends consulting with your legal team to secure consent in a DMA-compliant manner. While Google provides general instructions, it doesn't offer specific language for prompts. 

After AppsFlyer receives the TCF strings from your CMP (either through the AppsFlyer SDK or S2S), they are processed and translated on AppsFlyer servers. The following translation is mapped and sent to Google, as recommended by Google:

Yes. Google requires consent data to be included in each event sent from AppsFlyer, as Google doesn't merge user consent data from Firebase with data sent from AppsFlyer. Therefore, consent data must be sent to AppsFlyer, which forwards it to Google. Similarly, sharing consent data with AppsFlyer alone is insufficient for Firebase SDK requirements. This means you must send the data to both AppsFlyer and Firebase.

Address user consent in the European Economic Area (EEA)

Collaborate with your company’s legal counsel. They can provide insights into the implications of European user consent policies on the data you're sharing with partners like Google. If relevant, implement privacy prompts such as "Privacy Settings" or "Privacy Choices" to gather marketing and advertising-related user consent signals from your app users.

Verify CMP Compliance and TCF 2.2 Support

Ensure that your Consent Management Platform (CMP) supports TCF 2.2, which is the most updated Transparency and Consent Framework TCF) version. Your TCF should also be well-informed about the new Google EU consent requirements and can advise you on how to support it via TCF.

Implement the newest SDK/Server-to-Server (S2S) APIs

Consider the following options for sending the new consent fields, either using the SDK or S2S API calls:

• Using the SDK:
  • Implement the latest version of the AppsFlyer SDK (Android - v6.13.0+, iOS - v6.13.1+) for iOS and Android apps
  • Choose how to send the consent data
• Using S2S API calls:
  • Before sending in-app events to AppsFlyer, update your API calls to include the consent_data object for each event. See how to do this. 

Transition from the Legacy GMP Integration (DoubleClick)

If you're still using the legacy AppsFlyer GMP integration (doubleclick_int), plan to complete the transition to the newer version (dv360_int) within Q1, 2024. The Legacy integration is not EU consent compatible, and will be deprecated soon. See more details here.

EU users who decline to their data being used by Google for advertising purposes (ad_user_data=0), won't be claimed for attribution by Google Ads and DV360. This means AppsFlyer won't be able to attribute them.

The change may affect the number of EEA users appearing in your audiences and being exposed to remarketing campaigns on Google. EEA-based users will be required to consent before having their information shared with Google. Those who don’t consent will be excluded from audiences on Google’s side, and won’t be exposed to your campaigns. This raises the question of how to get consent from your users and what the ramifications may be for your business and advertising efforts. Learn more about changes to Audiences.