Meta · Llama API Terms of Service · View original document ↗

User Consent and Privacy Obligations on Developers

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Meta recorded 13 documented changes in the last 30 days.
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium May 21, 2026

The updated terms authorize Meta to retain user-submitted content if its systems flag the content for a potential policy violation, in addition to retention tied to legal compliance and contractual rights. This expands the circumstances under which content may be preserved without explicit time limits. Under the revised language, content retention decisions may now be driven by automated policy-violation flagging in addition to legal or contractual necessity. Developers integrating the Llama API should understand that flagged content may be retained indefinitely pending policy review.

View change record →

Clause Stability Mostly Stable

1
Change
1
Month Monitored
May 12, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.
This clause has changed once in 1 month of monitoring.

Change history

removed May 21, 2026

Removal of this detailed privacy notice requirement eliminates specific obligations regarding privacy policy content, user consent mechanisms, and visibility of privacy disclosures.

View full change record →

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Visit Facebook Settings under Apps and Websites to review which apps have access to your account data and remove any that you no longer wish to share data with.

How other platforms handle this

Grindr Medium

Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...

Strava Medium

For individuals in the United States, please also refer to our Notice For Individuals Residing In Certain US States below and the Consumer Health Data Policy.

Shein Medium

enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and Section 5 of the FTC Act against app developers who fail to maintain adequate privacy disclosures or consent mechanisms for users including children.
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
TCPA
United States Federal
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Llama API Terms of Service
Entity
Meta
Document last updated
May 11, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 12, 2026
Record ID
CA-P-011487
Document ID
CA-D-00778
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
baefabd2047c61b77d3dbc86fb3962da868600ef84c32db58013c52ddbab3929
Analysis generated
May 11, 2026 11:49 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Meta
Document: Llama API Terms of Service
Record ID: CA-P-011487
Captured: 2026-05-11 11:49:07 UTC
SHA-256: baefabd2047c61b7…
URL: https://conductatlas.com/platform/meta/llama-api-terms-of-service/user-consent-and-privacy-obligations-on-developers/
Accessed: June 30, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Meta's User Consent and Privacy Obligations on Developers clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Meta?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Meta.