ZwillGen Privacy Policy Check Up

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6. OVERPROMISING

5. SHARING DATA

4. MOBILE APP DATA

3. MEMBERSHIPS AND DISTINCTIONS

2. LAW ENFORCEMENT REQUESTS

1. CROSS-DEVICE TRACKING

Does your privacy policy contain a provision reserving the right to share all data collected in the event of a corporate sale or transaction?

Has your company created a branded mobile app? Did you update your privacy policy to include the mobile data you collect, and how you share and use that data? We’ve provided a brief outline of some key points to keep in mind as you update your privacy policy when you become an “app developer.”

Do you participate in a privacy or data security seal program? Were you once Safe Harbor certified? If “yes” (and probably even if “no”), then you will want to review your privacy policy and your site to confirm that statements about your memberships and distinctions are accurate and current.

Does your privacy policy explain the circumstances necessitating disclosure of information to the government pursuant to legal process and whether you are going to inform users when such demands are received?

Are you overpromising on security? Only some types of businesses might increase sales by making strong security promises in their privacy policy, but every business will have their privacy policy scrutinized for misrepresentations in the event of a security breach.

Does your company use technology to track and link consumers’ behavior across multiple Internet-connected devices? If so, you should evaluate whether your company’s privacy policy accurately and clearly discloses such cross-device tracking as well as any choices you offer, and consider whether you track sensitive topics across devices.