Pitfall 1: Missing or unsigned Data Processing Agreement
The mistake: Developers assume Google's standard terms cover GDPR compliance, or skip formal DPA acceptance thinking it's paperwork theater.
Why it happens with Google Play Billing: The DPA is buried in Play Console settings under a generic "data protection" menu. It's easy to miss, especially for founders launching their first subscription app. Many assume "using a Google service" automatically grants compliance.
Consequence: Your processing is technically non-compliant under GDPR Article 28. Data protection authorities (e.g., EDPB, Irish DPC) can issue compliance notices. In enforcement cases like those against app developers using Firebase (another Google service), regulators have cited unsigned DPAs as a primary violation. EU users can lodge complaints, resulting in investigation and potential fines (though typically lower for SMBs in first-time cases).
Pitfall 2: Incomplete or vague privacy policy disclosure about Google
The mistake: Mentioning "third-party payment processors" generically without naming Google LLC or explaining what purchase data Google receives and retains.
Why it happens with Google Play Billing: Developers focus on disclosing *their own* data practices but treat Google's role as a black box. The policy says "we use secure payments" without detailing that Google retains purchase history, subscription status, and account linkage.
Consequence: Violates GDPR Article 13 (controller transparency) and CCPA Section 1798.100 (right to know). Regulators and users cannot assess data flows or exercise rights. In CCPA audits, vague processor disclosures are frequently cited. Users may not understand they can request erasure of Google Play purchase records.
Pitfall 3: No consent mechanism for subscription data processing
The mistake: Treating purchase consent ("agree to buy") as sufficient for all downstream data processing, or failing to distinguish between payment processing and retention/analytics.
Why it happens with Google Play Billing: The purchase flow itself feels like explicit consent. Developers assume the user's agreement to pay covers Google's retention of subscription status indefinitely.
Consequence: Under GDPR, consent for payment ≠ consent for secondary processing (e.g., if Google uses purchase data for fraud detection, analytics, or cross-product profiling). If your app or Google's Privacy Policy indicates uses beyond payment fulfillment, you need separate, informed consent. Failure risks GDPR Article 7 violations (invalid consent). CCPA requires opt-out mechanisms for data sales; if Google shares purchase data with third parties, California users must have a functional "Do Not Sell" link.
