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Data subjects’ consent in a mobile app

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Guest user Created:   Dec 16, 2019 Last commented:   Dec 16, 2019

Data subjects’ consent in a mobile app

I have a question on obtaining data subjects’ consent under GDPR in a mobile app (Android/iOS). The mobile app content is food and recipes:

We want to activate this mobile app in some countries in pure English language, so the mobile app and the content is NOT translated to local language. Privacy Notice we provide, is indeed translated to local languages.

But the screens in the app, where we want to ask the users of the mobile app for his consent, are in English.

We have checked a huge number of other food/recipes apps in the app-stores, but haven’t found any app, where full app is in English, but consent screens are in local language.
Also we see that as confusing, when an app is switching the language in the user experience of the app.

The question is now, is there any rule, or is it mandatory from GDPR point of view, that the screen obtaining data subjects’ consent has to be also translated into local language ?

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Andrei Hanganu Dec 16, 2019

The Regulation requires Privacy Notices to be concise, transparent, intelligible and easily accessible. The Regulation should standardize the content of your privacy notices, it is likely that they will still need to be translated into local languages if they are directed at a particular jurisdiction. In particular, it is hard to see how your notice can be “accessible” if it is in a language the individual does not understand. Similarly, in some Member States such as France, the use of a local language for consumers and employees is mandatory under consumer protection and employment law.

If you want to find out more about privacy notices check out this free webinar Privacy Notices under the EU GDPR (https://advisera.com/eugdpracademy/webinar/privacy-notices-under-the-eu-gdpr-free-webinar-on-demand/)

 

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Dec 16, 2019

Dec 16, 2019

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