Internet Privacy Policy

What is an internet privacy policy?

An Internet Privacy Policy is a formal document that sets up a legal framework for processing, usage, and storage of users’ personal information collected from a website or mobile application. An internet privacy policy could also be referred to as a privacy policy user agreement. This is so because this document represents a sort of legal arrangement between a business owner and user regarding the collection of the user’s personal information.

Collection and processing of personal information of users is quite a sensitive issue, as it requires business owners to build a reliable technical infrastructure to be able to safeguard collected data. At the same time, there is no federal law in the U.S. providing a unified approach with regard to the collection and processing of personal data. On the state level some states tend to have stricter regulation, like the California Consumer Privacy Act, which is aimed at protecting sensitive data of California residents only.

A user privacy policy is, however, a mandatory document every online business shall have, including:

• e-commerce stores;
• websites that provide only informational services;
• mobile applications using location trackers or camera permissions;
• AI-based applications or websites;
• social media platforms; or
• content-sharing platforms, etc.

There is no particular structure a privacy policy user agreement should have. It depends on the type of website, the services it provides, the functionality it has, the list of third parties engaged (if any), and many other factors.

How to create a website privacy policy template?

Drafting a website privacy policy template requires inclusion of a number of important clauses to make a document legally valid. Besides that, it is important to address in full how users’ data is processed, as well as all types of processed data. This not only creates trust but also ensures compliance with effective legislation.

Description of the Website or App

Every website or app privacy policy template starts with the detailed description of the business itself. Through the website or app, users can purchase goods, services, or access to various information services. Thus, the text of the policy shall reflect the exact purpose of the website.

The second important element is to provide detailed information about the website owner, also known as a data controller. A website owner is a person that operates the website or mobile app and could be an individual, business, or organization. Thus, the text of a policy must define their name, mailing or business address, and contact phone number or email.

The third important element is the inclusion of the details of a data processor. This is a person (usually a business or organization) responsible for processing users’ personal data collected after using a website or application. The data processor could be the same person as a business owner or a separate entity. For example, if a website has an installed payment gateway, the data processor of users’ financial data will be a financial institution and not a website owner. Thus, an internet privacy policy should also include, in that case, the full name, mailing address, and contact details of a data processor.

Functionality of the Website or App

Describing a functionality of the website or app in the text of a user privacy policy allows us to define all possible channels through which a user’s data can become available. The functionality may include:

• A user can register on the website to create their personal account. During this step a user provides personal details, like name, email address, etc.
• User-generated content. Some websites or mobile applications allow users to post their comments, photos, likes, etc.
• AI-based services. A lot of online businesses engage AI-based services. Therefore, the text of a general privacy policy must incorporate a separate AI privacy policy dealing with the protection of data used in AI processing.

Types of Collected Data

Either a website or an app privacy policy template shall define the types of personal information they collect from users. Such a list may include:

• identification data (e.g., name, residential address, phone number);
• technical information or cookies data (e.g., browser type, IP address, session duration, language of the browser);
• behavioral data (e.g., number of clicks, time spent on the website); and
• user’s sensitive data (e.g., bank card details, biometrics).

Third-Party Services

This is quite a broad section, as it includes a variety of third-party providers that an online business may use for the operation of their website and managing business in general. When talking about third-party services, the website or mobile application may include:

• third-party tracking tools (e.g., Meta Pixel, Google Analytics);
• affiliate marketing links or banned ads;
• payment provider processing links (e.g., Airwallex, Venom); or
• third-party cookies (e.g., a Facebook or Instagram link in the footer of the website), etc.

Every online business shall remember one important rule: whichever third-party tool you use or install on your website or mobile application, that tool shall be described in your website privacy policy template. All in all, users should be aware of all possible third parties who potentially have access to any fraction of your personal data when a user is using your website or mobile application.

Last but not least, even a small business privacy policy template shall inform users that they additionally have to review third parties’ privacy policies to learn about the processing of their personal data by those third parties.

AI-Based Services and Data Processing

If your application or website uses AI-based services, in that case you need a separate AI privacy policy template addressing the security of personal data processed by those AI tools. This shall not necessarily be a separate document, as all important clauses could be incorporated into a general privacy policy template.

Therefore, the text of a privacy policy for an AI services template shall include:

• the functions of AI-based services (e.g., video generation, AI bot);
• the name of the AI-based platform that allows your business to incorporate AI-based services and tools (e.g., Avian, Adobe Sensei);
• the detailed list of all information that AI-based services will collect;
• purpose of data collection by AI-based services (e.g., to analyze such information);
• how long the collected information will be stored in your system (e.g., 1 week, 10 months); and
• how a user is able to opt out from AI-based services.

Data Transfer Details

In the course of collection of users’ personal data, businesses may transfer this information outside the U.S. Therefore, the text of a website privacy policy template must inform users regarding the following:

• if there is a cross-border transfer (i.e., a transfer of data outside the U.S. territory); and
• the list of third countries where the data is being transferred (in case of a cross-border transfer).

This is vital to inform users regarding the list of countries where their information is being transferred for a number of reasons. First, users can further check if the standards and safeguards related to the protection of personal data are reliable enough. Second, if users are not satisfied with such a cross-border transfer, they can opt out from this policy and usage of the website or mobile application immediately.

Amendment of the Privacy Policy

Every website privacy policy template shall define how exactly users will be informed about the amendments or changes made to this policy. There are several ways:

• sending a personal email to users;
• publishing a visible notice on the head page of the website or application; or
• changing the “Last Updated” status to the new date, etc.

Unlike with an ordinary contract, a user in the case of a privacy policy user agreement cannot oppose the introduction of new changes or amendments. Contrary to that, a user can either stop using the website or mobile application or agree in full to continue the usage.

Nowadays online businesses tend to inform their users about the upcoming changes well in advance. However, there is no particular legal norm requiring online businesses to send any advance notice to users informing them about the planned policy’s amendments.

Contact Details

Users should be able to reach an owner of the website or mobile application anytime, should they have any questions or concerns regarding processing of their personal data. Therefore, a solid user privacy policy has to incorporate the following information:

• Full name and position of a contact person who is responsible for the processing of personal data within the organization (e.g., data protection officer or a business owner representative).
• Contact phone and email address of a responsible person.
• Working hours or availability of a responsible person; and
• Office address of a responsible person (optional).

How to customize a privacy policy online at FasterDraft?

To get a fully customized legal document template, follow the instructions given below:

1. Click the “Create Document” button.
2. Answer simple questions in the form.
3. Select a template’s format—sample privacy policy PDF or Word.
4. Make a payment.
5. Download and publish this template for your website, app, or AI-based application.