PRIVACY

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Privacy Policy

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In brief · quick answer

A privacy policy is a legal document that explains how an organization collects, uses, stores, shares, and protects personal data. It is required by law in most jurisdictions for any website or app that handles user data.

§ 1 Definition

A privacy policy (or privacy notice) is a transparent statement that informs users about an organization's data handling practices. It typically covers what personal data is collected, how it is collected, why it is collected, how it is used, who it is shared with, how long it is retained, and what rights users have over their data. Under GDPR, CCPA/CPRA, and other privacy laws, a privacy policy is a legal requirement, not optional. The policy must be written in clear, plain language (not legalese) and must be easily accessible, usually via a link in the website footer.

§ 2 What a Privacy Policy Must Include

Identity of the data controller: Who is responsible for the data. Types of data collected: Personal identifiers (name, email), usage data, device data, cookies, payment information. Legal basis for processing: Consent, contract, legitimate interest, legal obligation. Purposes of processing: Why the data is used. Data sharing: Third parties, service providers, advertising partners. International transfers: If data is transferred across borders. Data retention periods: How long data is kept. Security measures: How data is protected. User rights: Access, correction, deletion, portability, objection. Contact information: How to reach the data protection officer or privacy team. Policy updates: How changes will be communicated.

§ 3 Jurisdictional Requirements

GDPR: Requires a comprehensive privacy notice that meets Articles 13 and 14. Must be provided at the time of data collection. CCPA/CPRA: Requires a privacy policy that explains consumers' rights and how to exercise them. Must be updated annually. PIPEDA (Canada): Requires meaningful consent and transparent policies. LGPD (Brazil): Similar to GDPR in structure and requirements. APP (Australia): Requires clear identification of the entity and what data is collected. Many jurisdictions have overlapping requirements; a single comprehensive policy covering multiple laws is common for global businesses.

§ 4 Privacy Policy vs Terms of Service

A privacy policy covers data handling practices. Terms of Service (ToS) cover the legal agreement between the user and the service: acceptable use, disclaimers, liability limits, payment terms, account termination rules. Both are separate documents. You need both. Never combine them into a single confusing document.

§ 5 Note

Do not copy another company's privacy policy. Your policy must accurately reflect your actual data handling practices. Having a policy that describes practices you do not follow is worse than having no policy at all it is misrepresentation and can lead to regulatory action.

§ 6 Common questions

Q. Do I need a privacy policy if I don't collect personal data?: A. Almost every website collects some personal data: IP addresses through server logs, cookies, analytics tools. If you have any form of data collection, you need a privacy policy. There is no practical scenario where a commercial website collects zero personal data.
Q. Can I use a free privacy policy generator?: A. Yes, but be careful. A generic template may not cover your specific data practices or the specific laws that apply to you. Always review and customize. Iubenda, Termly, and PrivacyPolicies.com are popular options.
Q. How often should I update my privacy policy?: A. Whenever your data practices change. Under GDPR, users must be informed of material changes. Annual review is a minimum best practice.

Key takeaways

A privacy policy explains how you handle user data. It is legally required.
Must include: data types, purposes, sharing, retention, user rights, contact info.
Different laws (GDPR, CCPA, LGPD) have different requirements.
Your policy must accurately reflect your actual practices.

How Atomic Glue helps

Atomic Glue drafts privacy policies tailored to your specific data practices and jurisdictional requirements. We also implement the technical infrastructure to support the rights described in your policy. Get in touch.

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# Privacy Policy

Category: Privacy (also: Legal)

Author: Atomic Glue Security Team

## Definition

## What a Privacy Policy Must Include

**Identity of the data controller**: Who is responsible for the data. **Types of data collected**: Personal identifiers (name, email), usage data, device data, cookies, payment information. **Legal basis for processing**: Consent, contract, legitimate interest, legal obligation. **Purposes of processing**: Why the data is used. **Data sharing**: Third parties, service providers, advertising partners. **International transfers**: If data is transferred across borders. **Data retention periods**: How long data is kept. **Security measures**: How data is protected. **User rights**: Access, correction, deletion, portability, objection. **Contact information**: How to reach the data protection officer or privacy team. **Policy updates**: How changes will be communicated.

## Jurisdictional Requirements

**GDPR**: Requires a comprehensive privacy notice that meets Articles 13 and 14. Must be provided at the time of data collection. **CCPA/CPRA**: Requires a privacy policy that explains consumers' rights and how to exercise them. Must be updated annually. **PIPEDA (Canada)**: Requires meaningful consent and transparent policies. **LGPD (Brazil)**: Similar to GDPR in structure and requirements. **APP (Australia)**: Requires clear identification of the entity and what data is collected. Many jurisdictions have overlapping requirements; a single comprehensive policy covering multiple laws is common for global businesses.

## Privacy Policy vs Terms of Service

## Note

## Common questions

Q: Do I need a privacy policy if I don't collect personal data?

A: Almost every website collects some personal data: IP addresses through server logs, cookies, analytics tools. If you have any form of data collection, you need a privacy policy. There is no practical scenario where a commercial website collects zero personal data.

Q: Can I use a free privacy policy generator?

A: Yes, but be careful. A generic template may not cover your specific data practices or the specific laws that apply to you. Always review and customize. Iubenda, Termly, and PrivacyPolicies.com are popular options.

Q: How often should I update my privacy policy?

A: Whenever your data practices change. Under GDPR, users must be informed of material changes. Annual review is a minimum best practice.

## Key takeaways

A privacy policy explains how you handle user data. It is legally required.
Must include: data types, purposes, sharing, retention, user rights, contact info.
Different laws (GDPR, CCPA, LGPD) have different requirements.
Your policy must accurately reflect your actual practices.

## Related entries

Last updated December 2024. Permalink: atomicglue.co/glossary/privacy-policy