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The policy requires advertisers using personalized advertising features including remarketing and custom audiences to comply with a separate, linked set of data collection and use policies governing how user information may be collected, handled, and applied in targeting.
This analysis describes what Google Ads's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that the data governance obligations for personalized advertising are contained in a separate policy document not reproduced here, requiring advertisers using these targeting features to review and comply with additional requirements beyond this overview document.
The agreement establishes that user information including full name, email address, mailing address, phone number, financial status, political affiliation, sexual orientation, race or ethnicity, and religion are categories identified as requiring careful handling, and that personalized advertising targeting based on such data is subject to separate policy requirements.
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"Google wants users to trust that information about them will be respected and handled with appropriate care. As such, the advertising partners shouldn't misuse this information, nor collect it for unclear purposes or without appropriate disclosures or security measures. Note : Additional policies apply when using personalized advertising, which includes remarketing and custom audiences. If you use personalized advertising targeting features, be sure to review the personalized ads data collection and use policies.Excerpt from Google Ads's Advertising Policies Overview
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 6 and 9 regarding lawful bases for processing personal data and conditions for processing special category data (health, political opinions, religious beliefs, sexual orientation, racial or ethnic origin). CCPA and its amendments under CPRA regulate the use of sensitive personal information in advertising. The FTC has enforcement authority over deceptive data collection practices under Section 5 of the FTC Act. COPPA applies where user data collection may involve individuals under 13. 2) GOVERNANCE EXPOSURE: High. The categories of sensitive user data identified in this provision (political affiliation, sexual orientation, race or ethnicity, religion, financial status) correspond directly to special category data under GDPR and sensitive personal information under CCPA, both of which impose heightened processing restrictions. Advertisers using remarketing or custom audience features who collect or upload such data to Google's systems face material regulatory exposure if appropriate legal bases, consent mechanisms, and data transfer agreements are not in place. 3) JURISDICTION FLAGS: EU and EEA advertisers face the most significant exposure, as processing of special category data for advertising purposes requires explicit consent under GDPR and may be restricted under national implementing legislation in certain member states. California advertisers must provide specific disclosures and opt-out mechanisms for the use of sensitive personal information in advertising under CPRA. Illinois advertisers using biometric identifiers in targeting face BIPA-specific obligations. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertisers uploading customer data to Google's custom audiences feature must assess whether data processing agreements with Google adequately address GDPR controller-processor obligations and CCPA service provider requirements. Data mapping exercises should identify whether any uploaded customer lists contain special category or sensitive data that may not be permissible for advertising use under applicable law. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit personalized advertising configurations to verify that data collection mechanisms feeding remarketing and custom audience lists include appropriate consent language and disclosures. Data processing agreements with Google should be reviewed for alignment with applicable privacy law requirements. Advertisers should maintain records of lawful basis for processing user data used in targeting, particularly for EU campaigns involving sensitive data categories.
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This provision establishes that the data governance obligations for personalized advertising are contained in a separate policy document not reproduced here, requiring advertisers using these targeting features to review and comply with additional requirements beyond this overview document.
The agreement establishes that user information including full name, email address, mailing address, phone number, financial status, political affiliation, sexual orientation, race or ethnicity, and religion are categories identified as requiring careful handling, and that personalized advertising targeting based on such data is subject to separate policy requirements.
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