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Suppose I have an android app on Google Play. They encourage publishers to have EULAs and Privacy Policies for each app. Suppose I put my EULA and Policies on some simple site (web page). For example, I used Google Sites for that purposes. My question is (it may be a bit silly):

Do I need separate Terms of Use and Privacy Policies also for that site? That's quite recursively ...

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I was sent to this question by a coworker and realise that it's been posted quite a while ago. Anyhow, since this might help other people in the future...here we go:

Privacy policies are largely a requirement for any website with a commercial background, so yes it's very likely that you'll need a website privacy policy.

When it comes to the marketing website for an app, the European authorities (more specifically a pan-European privacy thinktank) say this:

The Working Party recommends that information about personal data processing is also available, and easy to locate, such as within the app store and preferably on the regular websites of the app developer responsible for the app. It is unacceptable that the users be placed in a position where they would have to search the web for information on the app data processing policies instead of being informed directly by the app developer or other data controller.

Now, if there is a connection between that website and the app there is nothing wrong with making the proper disclosures in one privacy policy and make it cover both properties. As a matter of fact it is probably the more logical approach that will confuse users less (instead of having them read two different documents).

Terms follow a slightly different logic. Apple provides a default EULA doc for all downloaded apps. If your site has things going on in addition to being a mere marketing page, then you might want to look into creating a proper terms doc. There too though, if you cover some basic requirements coming from Apple's side, you should be able to combine them into one document reigning both the app and the site.

Hope this helps!

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