Photos API User Data and Developer Policy

As a developer using Google Photos APIs, you often collect and manage Photos user data. Please keep these key principles in mind:

  • Protect privacy: Don't use Photos user data for prohibited uses, we prohibit third parties from selling user data or using user data for advertising purposes.
  • Be transparent: Accurately represent and explain to users what data you will collect, why you will collect it, and how you will use it.
  • Be respectful: Honor user requests to delete their data.
  • Be secure: Handle all user data securely and demonstrate you adhere to certain security practices.
  • Be specific: Don't request access to data that you don't need. All data access should only be to provide the user benefitting features of your application or service.

The Google API Services User Data Policy governs the use of all Google API Services when you, the developer, request access to user data. This Photos API Services User Data and Developer Policy contains additional information that governs your use and access to Photos APIs.

In addition to the below policy, the Google APIs Terms of Service, Google Photos User Content and Conduct Policy, and UX guidelines also govern your use of and access to Google Photos APIs and associated Photos user data.

Please check back from time to time as these policies are occasionally updated. It is your responsibility to monitor and ensure your compliance with these policies on a regular basis. If, at any time, you cannot meet the requirements of our policies (or if there is a significant risk that you will not be able to meet them), please immediately stop using our services and reach out to us. We reserve the right to remove or restrict access to Google user data if you do not comply with this policy.

Appropriate access to and use of Google Photos APIs

Requests to access user data must be clear and understandable. Google Photo APIs may only be used in accordance with the applicable policies, terms and conditions, and for approved use cases as set forth in this Policy. This means you may only request access to permissions when your application or service meets one of the approved use cases. Approved use cases for access to Google Photo API scopes permissions are:

  • Applications or services for storing, editing, printing, exporting, and sharing images and videos. Your new app/integration should add something to Google Photos' core functionality, not just recreate it.

The Google Photo APIs are not allowed for certain use cases, including the following:

  • Do not use Google Photos APIs to store or serve media such as photos or videos that are not of a personal nature. For storing internal enterprise data or hosting website media, consider using Google Cloud Storage instead.
  • Do not use Google Photos APIs as a replacement for a large-scale content delivery network (CDN).
  • Do not use this Google Photos APIs to create, train, or improve (directly or indirectly) similar or competing products or services.
  • Do not make a substitute for Google Photos. For example, do not use the APIs to create a general purpose photo gallery app.
  • Do not use Google Photos APIs to produce face clusters (for example, facial clustering is used to help people organize their personal memories and are not intended for use by developers).

Request the minimum relevant permissions

You may only request access to permissions that are critical to implementing your application or service's functionality. This means:

  • Don't request access to information that you don't need. Only request access to the permissions necessary to implement your application's features or services. If your application does not require access to specific permissions, then you must not request access to these permissions. Don't attempt to "future proof" your access to user data by requesting access to information that might benefit services or features that have not yet been implemented.
  • Request permissions in context where possible. Only request access to user data in context (via incremental auth) whenever you can, so that users understand why you need the data.

Transparent and accurate notice and control

You need to have a privacy policy that discloses how your application or web service collects, uses, and shares user data. Applications and services must also request access to user data in context (via incremental auth when possible), so that users better understand what data will be provided, why you need the data, and how the data will be used. In addition to the requirements under applicable law, you must also adhere to the following requirements, which reflect our OAuth 2.0 and Google API Services User Data policies:

  1. You must provide a disclosure of your data access, collection, use, and sharing. The disclosure:
    1. Must accurately represent the identity of the application or service that seeks access to user data;
    2. Must be within the application itself if application-based or in a separate dialog window if web-based;
    3. Must be displayed in the normal usage of the application if application-based or website if web-based and not require the user to navigate into a menu or settings;
    4. Must provide clear and accurate information explaining the types of data being accessed, requested, and/or collected;
    5. Must explain how the data will be used and/or shared: if you request data for one reason, but the data will also be utilized for a secondary purpose, you must notify users of both use cases;
    6. Cannot be placed only in a privacy policy or terms of service; and,
    7. Cannot be included with other disclosures unrelated to personal and sensitive data collection.
  2. Your disclosure must accompany and immediately precede a request for user consent. You must not begin collection prior to obtaining affirmative consent. The request for consent:
    1. Must present the consent dialog in a clear and unambiguous way;
    2. Must require affirmative user action (for example, tap to accept, tick a check-box, a verbal command, etc.) in order to accept;
    3. Must not interpret navigation away from the disclosure (including tapping away or pressing the back or home button) as consent; and,
    4. Must not utilize auto-dismissing or expiring messages.
  3. You must provide user help documentation that explains how users can manage and delete their data from your app or service.

Limited use of user data

Upon accessing Google Photos APIs for an appropriate use, your use of the data obtained must comply with the below requirements. These requirements apply to data derived from both Sensitive and Restricted scopes.

  1. Limit your use of data to providing or improving your appropriate use case or features that are visible and prominent in the requesting application's user interface.
  2. Transfers of data are not allowed, except:
    1. To provide or improve your appropriate use case or user-facing features that are visible and prominent in the requesting application's user interface and only with the user's consent;
    2. For security purposes (for example, investigating abuse);
    3. To comply with applicable laws and/or regulations; or,
    4. As part of a merger, acquisition or sale of assets of the developer after obtaining explicit prior consent from the user.
  3. Do not allow humans to read user data, unless:
    1. You have obtained and documented the user's explicit consent to read specific data (for example, helping a user re-access the product or a service after having lost their password);
    2. The data (including derivations) is aggregated and anonymized and used for internal operations in accordance with applicable privacy and other jurisdictional legal requirements;
    3. It's necessary for security purposes (for example, investigating abuse); or,
    4. To comply with applicable laws and/or regulations.

All other transfers, uses, or sale of user data is completely prohibited, including:

  1. Transferring or selling user data to third parties like advertising platforms, data brokers, or any information resellers.
  2. Transferring, selling, or using user data for serving ads, including retargeting, personalized or interest-based advertising.
  3. Transferring, selling, or using user data to determine credit-worthiness or for lending purposes.
  4. Transferring, selling, or using user data to create, train, or improve a machine learning or artificial intelligence model beyond that specific user's personalized model for the appropriate use case or user-facing feature.

An affirmative or other similar statement that your use of the data complies with the Limited Use restrictions must be disclosed in your application or on a website belonging to your web-service or application; for example, a link on a homepage to a dedicated page or privacy policy noting: "The use of information received from Photos APIs will adhere to the Google User Data Policy, including the Limited Use requirements."

Maintain a secure operating environment

Treat all user data securely in transit and at rest. Take reasonable and appropriate steps to protect all applications or systems that make use of the Google Photos API and any data derived from it against unauthorized or unlawful access, use, destruction, loss, alteration, or disclosure. Applications accessing Restricted Scopes must demonstrate that they adhere to certain security practices.

Recommended security practices include implementing and maintaining an Information Security Management System such as outlined in ISO/IEC 27001 and ensuring your application or web service is robust and free from common security issues as set out by the OWASP Top 10.

Required security measures include:

  1. Using an industry accepted encryption standard to encrypt user data that is:
    1. Stored on portable devices or portable electronic media;
    2. Maintained outside of Google's or your systems;
    3. Transferred across any external network not solely managed by you; and,
    4. At rest on your systems.
  2. Transmitting data using secure modern protocols (for example, over HTTPS).
  3. Keeping user data and credentials, specifically tokens such as OAuth access and refresh tokens, encrypted at rest.
  4. Ensuring keys and key material are managed appropriately, such as stored in a hardware security module or equivalent-strength key management system.

Required security measures for Restricted Scopes also include following the Cloud Application Security Assessment (CASA). In addition, depending on the API being accessed and number of user grants or users, we may also require that your application or service undergo a periodic security assessment and obtain a Letter of Assessment from a Google-designated third party.