(March 2024) Google Updates for the EU Digital Markets Act (DMA)

All of Google's integrations that ingest user level data are impacted, including but not limited to:

• Google Ads Attribution Integrations (App Conversion API)
• Google Marketing Platform Attribution Integration (App Conversion API)
• Google Ads Audiences (Customer Match API)
• Google Ads Offline Click Conversions API

Singular has made updates to all integrations to support Google's updates.

When and how to collect user consent signals for EEA users should adhere to your business' and apps requirements for user privacy. Consult your business' legal counsel to understand how your app needs to adhere to internal privacy policies and privacy regulations such as GDPR, ePrivacy Directive, and the Digital Markets Act.

If you decide to collect user consent signals, it is generally recommended that:

• User consent signals be set only when the user has explicitly opted-in or out. It is recommended to leave LDS unset if a user did not make a choice. The absence of a user signal may be important.
• User consent signals are commonly collected in "Privacy Choices" or "Privacy Settings" during the app experience.
• When possible, and depending on your app's consent prompt design and strategy, surface privacy prompts early in the app flows to ensure Singular and other SDKs can collect the user consent signal as early as possible
  
  

If your business determines that EU privacy regulations for EEA users apply to your app: Implement the Singular SDK/S2S "Limit Data Sharing" feature based on the consent prompts your app presents to these users.

• Using Singular's iOS SDK:
  

  limitDataSharing Method
  Description	Notify Singular of user consent (opt-in) for sharing private data. Use limitDataSharing:NO to indicate that the user consented (opted in) to share their information. Use limitDataSharing:YES if the user did not consent.
  Signature	(void)limitDataSharing:(BOOL)shouldLimitDataSharing;
  Usage Example	SwiftObjective-C // User has opted into sharing data Singular.limitDataSharing(false) // User has opted into sharing data [Singular limitDataSharing:NO];

• Using Singular Android SDK:
  

  Singular.limitDataSharing Method
  Signature	Singular.limitDataSharing(boolean shouldLimitDataSharing) Use Singular.limitDataSharing(false) to indicate that the user consented (opted in) to share their information. Use Singular.limitDataSharing(true) if the user did not consent
  Description	Notify Singular of user consent (opt-in) for sharing private data.
  Usage Example	// User has opted into sharing data Singular.limitDataSharing(false);

 

If your business determines that EU privacy regulations don't apply to your app, you can opt-out of EEA user consent signals in Singular. check the "EEA opt-out" option under the "User Privacy" section in the Google Ads and/or Google Marketing Platform partner configuration. LDS and user consent signals are not used by Google with this option.

• Implementing LDS for EEA users is not required if using this option
• This option can be enabled prior to Google's March updates going live

Singular's Limit Data Sharing (LDS) is a feature that allows app developers to pass each user's user consent signals to Singular. LDS is set per user and can be set before or after SDK initialization. LDS is used in Singular User Privacy Postbacks and passed to certain partners like Google, who use it to comply with their own data practices.

See "Supporting User Privacy Choices with Limit Data Sharing FAQ"

Google lists Consent Management Platforms (CMPs) that support the required user consent signals. If you use one of these CMPs, you can extract the user consent signals and pass them through Singular's LimitDataSharing feature. 

 (Coming soon, after March 2024) The Singular SDK/S2S will support an optional mode to automatically ingest user consent signals from these certified CMPs (via the TCF 2.2 standard).

No, although Google recommends using a certified consent management platform (CMP), it is not required for advertisers. Advertisers may choose to manage their own consent prompts an you can pass user consent signals to Singular either with or without a CMP. See "How can I pass user consent signals to Singular?"

Yes, all SDKs that collect and pass user data to Google must independently collect user consent signals.

Starting March 2024

For EEA users that opt-out to user consent:

• User-level attribution to Google campaigns will not be available in Singular.  Google won't be able to report these attributions to MMPs
• (Google Ads only) Google Ads will model conversions for these users, which is reflected in the aggregated network metrics Singular pulls from the Google Ads data connector.
• Google won't be able to use this users data for advertising purposes

For EEA users that opt-in to user consent:

• User-level attribution to Google campaigns are possible
• Google will use this data for advertising purposes