Privacy & Information Security Law Blog

On June 3, 2021, Google informed app developers that beginning in late 2021, when Android 12 OS users opt out of personalized ads, the advertising ID provided by Google Play services (the Google Ad ID, or “GAID”) will not be made available to app developers for any purpose.

The GAID is a unique, user-resettable ID that is used for personalized advertising and other limited purposes. Presently, when a user opts out of receiving personalization ads on their Android device, the user’s GAID remains available to app developers for certain limited purposes (including analytics and fraud prevention). With the announced change, beginning in late 2021, the GAID of users who opt out of receiving personalized ads will no longer be available to app developers for any purpose. Developers instead will receive a string of zeros in its place.

According to the announcement, in July 2021, Google will provide an alternative solution to the GAID to support essential use cases, such as analytics and fraud prevention. These change will expand beyond users of Android 12 OS in early 2022, to apply to all devices that support Google Play.

Google’s announcement comes on the heels of Apple’s AppTracking Transparency framework (“ATT” framework), which came into effect in April 2021. Unlike Apple’s ATT framework, however, Google will not (1) require users to affirmatively opt-in to the use of their GAID for advertising purposes or (2) following a user opt-out, prohibit app developers from using other persistent device identifiers to target the user’s device with ads, as long as the app presents users with a privacy policy and handles user data in accordance with the Google Developer Distribution Agreement. Google’s announcement follows new Google Play app data privacy and security disclosure requirements, announced in May 2021.