20th May 2025 
13 Min Read
Retargeting can be a highly effective online advertising strategy, but it relies heavily on the use of personal data. As a result, having a robust retargeting privacy policy is essential for maintaining user trust.
In this article, we will explore what a retargeting privacy policy is and the key elements it should include. We will also examine the requirements set by major ad platforms when using their services for retargeting campaigns.
What is a retargeting privacy policy?
A retargeting privacy policy is a document that outlines how your company targets website users to re-engage them with ads based on their previous online behavior.
If you are familiar with the distinction between session cookies and persistent cookies, you will know that one of the most common uses of the latter is for personalized advertising. That’s because they allow you to effectively target ads according to user behavior.
In particular, they are very useful for retargeting campaigns. These involve tracking users across different sites and targeting them with ads relevant to their interests. For instance, a user might browse a product on a company’s site. Later in the day, they might see an advert for the same product while browsing social media. In theory, this serves as a helpful reminder for the user, who may just need a little nudge to click and buy.
However, not all users are comfortable with cross-device tracking or other retargeting techniques. Some find the feeling of being followed around the internet a little disconcerting.
In response to this, the law has stepped up to the digital plate. Today, the data privacy rules you must follow when conducting retargeting campaigns can be fairly strict and nuanced. As a result, developing a sound retargeting privacy policy has become a crucial element of using retargeting in your ad campaigns.
What should you include in your retargeting privacy policy?
One of the challenges you will face when deciding what to include in a retargeting privacy policy is that it’s not always clear which laws you need to follow. Because retargeting happens online, it’s not as simple as checking your local laws and assuming that’s enough.
For instance, the state of California has much stricter data privacy laws regarding retargeting than the U.S. does at the federal level. If you are based in Idaho but want to do business across the country, it’s unlikely you will want to exclude California residents from your target audience. So, despite being based in another state, you will need to comply with the California Online Privacy Protection Act.
On an international scale, you will encounter similar challenges when doing business in the UK and the European Union, which require GDPR compliance for any company collecting data on their residents.
In practice, then, it’s safer to err on the side of caution by developing a retargeting privacy policy that meets the strictest legal requirements. With that in mind, here are some elements you should include:
Purpose of retargeting and how it works
The first thing you need to do is explain what retargeting is and how it works. Use clear, simple language that does not require legal expertise to understand. This is crucial because users must fully grasp what they are agreeing to when they give consent.
Types of data collected and data collection methods
You will also need to provide full details of the types of data you collect. Some common examples include:
- IP address
- Pages visited and timestamps
- Items added to the shopping cart
- Cookie string data
- User device type
Outline the techniques you use to collect this data as well—for instance, the types of software or tracking technologies you employ.
Details on third-party involvement and scope
Given the structure of the online advertising ecosystem, it’s fairly common for website owners to partner with third-party retargeting services. Some of these platforms require you to list the names of advertisers in your privacy policy. Review the terms and conditions of any contracts you have with third parties to determine whether this is necessary.
Information on how collected data is used
In addition to listing the types of data you collect, you must be transparent about how you plan to use it. In the case of retargeting, this means briefly explaining how and why a user is selected for targeted ads.
Retargeting data retention period
Another important factor is how long you intend to retain the data. Typically, data privacy laws do not allow you to hold on to personal data indefinitely “just in case” you need it. For example, GDPR stipulates that you may only retain data for as long as necessary to fulfill its intended purpose. Be sure to state the retention period clearly in your privacy policy.
Security measures for protecting user data
You will also need to explain the security measures you take to protect customer data. Pay special attention if you have unique security needs.
For instance, some cloud-based services use container software to optimize data processing times, in which case you will need to address specific container security considerations. Container security involves measures such as isolation, access control, and encryption to address the particular vulnerabilities of containerized environments.
You do not need to list every security feature in detail, but you should provide enough of an overview to inspire user confidence that their data is well protected.
Contact details for privacy-related concerns
Users must be able to contact you easily if they have any concerns related to data privacy. Provide multiple contact options—at a minimum, an email address and a phone number. You may also consider offering live chat support or accepting messages through your social media channels.
Links to opt-out tools and preference management
Data privacy laws place a strong emphasis on active consent. You ca not rely on passive statements like “If you continue browsing, this will be taken as consent.”
Instead, you must clearly explain how users can opt in or opt out. Provide straightforward instructions and direct links to pages where they can manage their privacy preferences and settings.
Platform-specific privacy policies and best practices
Depending on which platforms you partner with to advertise, you may need to incorporate specific elements into your privacy policy. Here are a few things to be aware of for some of the top digital advertising platforms:
Google ads
Google has its own privacy requirements for anyone using Google Ads for retargeting. It states that your privacy policy must include:
- How you use retargeting (or “remarketing,” as Google calls it)
- How third-party vendors display your ads on websites
- How third-party vendors use cookies and other identifiers
- An explanation of how users can opt out via Google’s Ad Settings
In addition, Google requires coverage of other standard data privacy points, such as listing the types of data you collect and explaining how that data is used.
Meta (Facebook/Instagram)
Like Google, Meta emphasizes core privacy requirements, including transparency about data collection, clarity on opt-out mechanisms, and the need for active cookie consent.
The main difference is that Meta places less emphasis on third-party involvement—a reflection of its business model, which is primarily focused on its own platforms: Facebook and Instagram.
However, Meta does have some platform-specific requirements. For example, it enforces particular rules for its VR products. If you are retargeting users through Meta VR, you’ll need to include explicit details on how data is collected and used in that context.
LinkedIn ads
Unlike Google and Meta, LinkedIn only recommends having a retargeting privacy policy—it’s not a mandatory requirement for using its advertising services.
That said, LinkedIn does provide guidance on what your policy should include. For example, if you use the LinkedIn Insight Tag to track website visitors, your policy must explain how the tag works.
TikTok ads
TikTok places strong emphasis on user control over data usage. Your privacy policy must include a clear explanation of how users can manage or change their data settings. The platform also requires full disclosure about how the TikTok Pixel functions for ad retargeting.
One important requirement is that if you use lead generation ads on TikTok, you are obligated to display your data privacy policy directly on the landing page.
Twitter (X) ads
X, formerly known as Twitter, is another platform that highlights the importance of transparency, especially regarding third-party involvement. If you sign up to use the Custom Audiences service, your privacy policy must state that you are using third parties to assist with conversion tracking and ad delivery.
Conclusion
Data privacy requirements can be complex, but once you get a handle on them, they are far less intimidating than they may seem at first.
When it comes to crafting a retargeting privacy policy that users trust, the good news is that the regulations you need to comply with are designed to promote user trust. They encourage you to prioritize transparency and consent.
The most important thing to remember as you create your policy is to communicate everything as clearly and simply as possible. If you approach the task with the user in mind, you’ll be able to develop a privacy policy that not only fulfills your legal and contractual obligations but also builds lasting trust with your audience.
Author’s bio: Eric Wahlquist is a tech-focused content marketer with 15+ years of experience. As Senior Content Marketing Manager at SUSE, he simplifies complex technologies through impactful storytelling and helps audiences understand the real-world value of innovation.
Disclaimer: This article is for general informational purposes only and should not be taken as legal or professional advice. The views and opinions expressed in this article are solely those of the author and do not necessarily reflect the views of our organization. We do not endorse any products or services mentioned in the article.
