Developers are responsible for writing and publishing their own privacy policy and for getting users' consent before collecting their data. The privacy policy must be at least as protective as Meta's own policies.
This analysis describes what Meta'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 places independent legal and operational obligations on developers to maintain compliant privacy disclosures and consent mechanisms, meaning that failures in these areas are the developer's responsibility rather than Meta's.
Users of third-party apps built on Meta's platform are entitled to a privacy policy from the developer that accurately describes what data is collected and how it is used. Whether a given developer has complied with this requirement is the developer's independent responsibility under these terms.
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By accessing or using the Services, you represent and warrant that: (a) you are at least 18 years of age or over the age of majority in the jurisdiction where you are a resident or citizen; and (b) your registration and your use of the Service is in compliance with any and all applicable laws and re...
YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
If you are a California resident, you may have certain rights under the California Consumer Privacy Act (CCPA). These rights may include: the right to know about personal information collected, disclosed, or sold; the right to delete personal information collected from you; the right to opt-out of t...
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"You must provide and make available to users a privacy policy that is at least as protective as our policies and that accurately describes what data you collect, how you use it, and how you share it. You are responsible for obtaining any necessary consent from users before collecting, using, or sharing their data, including as required by applicable law. You must display a link to your privacy policy in your app and in any app store from which your app can be downloaded.— Excerpt from Meta's Llama API Terms of Service
REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 12-14 (transparency obligations), Article 7 (consent conditions), CCPA notice requirements, and COPPA requirements for apps accessible to children under 13. The relevant enforcement authorities include EU data protection authorities, the California Privacy Protection Agency, and the FTC as the primary COPPA enforcement body in the US. GOVERNANCE EXPOSURE: High. Placing full responsibility on developers for consent collection and privacy disclosure is operationally significant, particularly for developers serving users in multiple jurisdictions with different consent standards. A developer's failure to maintain an adequate privacy policy or obtain valid consent could trigger regulatory action independent of Meta's own compliance posture. JURISDICTION FLAGS: GDPR consent requirements are particularly stringent: consent must be freely given, specific, informed, and unambiguous. California CCPA and CPRA require specific disclosures at collection and provide opt-out rights for certain data uses. COPPA imposes verifiable parental consent requirements for apps directed at or knowingly accessed by children under 13. Illinois BIPA may apply if developer apps collect biometric data. CONTRACT AND VENDOR IMPLICATIONS: Developers using subprocessors or third-party SDKs within their apps must ensure that their own privacy policies and consent mechanisms accurately describe downstream data sharing. GDPR Article 28 requires written data processing agreements with subprocessors, which developers must maintain independently of their agreement with Meta. COMPLIANCE CONSIDERATIONS: Developers should conduct a consent mechanism audit to verify that their apps collect valid consent under each applicable legal standard in the jurisdictions where their users are located. Privacy policies should be reviewed for accuracy against current data collection practices, and a data mapping exercise should confirm that all collection and sharing practices are disclosed. Records of consent should be maintained to demonstrate compliance in the event of a regulatory inquiry.
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This provision places independent legal and operational obligations on developers to maintain compliant privacy disclosures and consent mechanisms, meaning that failures in these areas are the developer's responsibility rather than Meta's.
Users of third-party apps built on Meta's platform are entitled to a privacy policy from the developer that accurately describes what data is collected and how it is used. Whether a given developer has complied with this requirement is the developer's independent responsibility under these terms.
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