Campaign for Accountability Calls on Apple & Google to Remove Anti-Choice Apps From Their Platforms

WASHINGTON, June 26 -- Campaign for Accountability issued the following news release:

Today, Campaign for Accountability ("CfA"), a nonprofit watchdog group focused on public accountability, sent letters to executives at Apple and Google calling on the companies to remove from their platforms apps belonging to the anti-abortion behemoth Susan B. Anthony List ("SBA List") and anti-choice/anti-LGBT group, the Family Research Council ("FRC"), for violating company policies. CfA's letters document how apps belonging to FRC and SBA List have violated App Store and Google Play rules by 1) misusing users' personal information to recruit new members, 2) failing to provide privacy policies, 3) utilizing template-designed apps that have been banned, and 4) requiring users to sign in to an app before they are able to access its features.

Click here to download a PDF of the letter to Apple (https://campaignforaccountability.org/wp-content/uploads/2019/06/CfA-Letter-Apple-Political-Social-Media-6-26-19.pdf).

Click here to download a PDF of the letter to Google (https://campaignforaccountability.org/wp-content/uploads/2019/06/CfA-Letter-Google-Political-Social-Media-6-26-19.pdf).

CfA Executive Director Daniel E. Stevens said, "The Family Research Council and Susan B. Anthony List are using their smartphone apps to trick unsuspecting Americans in to turning over their personal data just so they can sign up new members. Apple and Google should enforce their own privacy rules and stop Susan B. Anthony List and Family Research Council from abusing innocent Americans."

CfA's letters to executives at Apple and Google call on the companies to expel the SBA List's app, Life Impact, and FRC's app, STAND FIRM, from their platforms. Life Impact and STAND FIRM are both run by Political Social Media LLC, an app developer that operates 13 conservative apps in both the App Store and Google Play. Besides these two anti-choice apps, Political Social Media runs apps for the National Rifle Association, President Trump's campaign committee, and conservative parties in Canada and Australia. CfA's letters call for all of Political Social Media's apps to be removed.

Life Impact and STAND FIRM, like all of Political Social Media's apps, are virtually identical. For each client, including the anti-choice groups, Political Social Media sets up a boilerplate social media platform where members can chat with each other, post comments on in-app newsfeeds, and play games. Political Social Media's apps have drawn intense scrutiny because they lack basic privacy protections. For instance, the company operated an app for the Vote Leave campaign in Great Britain, and a parliamentary committee later questioned the "data privacy concerns raised" by the app. Additionally, the New York Times, NBC News, and BuzzFeed, have all examined how the company uses its apps to mine users' personal data.

All of Political Social Media's apps, including Life Impact and STAND FIRM, appear to violate Apple's App Store Review Guidelines and the Google Play Developer Distribution Agreement. Apple and Google have outlined extensive polices for their platforms that require developers to provide adequate privacy policies and protect their users' data. The tech companies also require developers to build authentic apps and submit them in the name of the company that operates them. Political Social Media, on behalf of FRC and SBA List, appears to be violating all of these policies.

Click here to read more about each letter (https://campaignforaccountability.org/wp-content/uploads/2019/06/Apple-Google-Letters-One-Pager.pdf).

CfA Counsel Alice C.C. Huling elaborated, "Apple and Google have kicked other apps off their platforms for violating their policies, and these anti-choice groups should be no exception. Tech companies should apply their rules uniformly, rather than turn a blind eye to violations by developers with powerful political and social connections. Family Research Council and Susan B. Anthony List should not be allowed to violate company policies to prey on unsuspecting consumers in an effort to expand their anti-abortion rhetoric."

Campaign for Accountability is nonprofit watchdog organization that uses research, litigation, and aggressive communications to expose misconduct and malfeasance in public life and hold those who act at the expense of the public good accountable for their actions.

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To: Katherine Adams, Senior Vice President and General Counsel

Philip W. Schiller, Senior Vice President, Worldwide Marketing

Matt Fischer, Vice President, App Store

Apple Inc.

One Apple Park Way

Cupertino, California 95014

Re: Removal of Political Social Media LLC's Apps from the App Store

Dear Ms. Adams, Mr. Schiller, Mr. Fischer:

Campaign for Accountability ("CfA"), a nonprofit watchdog organization, respectfully requests that Apple remove all apps developed by Political Social Media LLC from the App Store. Political Social Media operates the brands, uCampaign, LLC and Jarbik, LLC, among others, which operate approximately 13 apps that appear to be violating the App Store Review Guidelines.

Background

Political Social Media LLC was incorporated in Delaware on January 31, 2014./1 The company employs several brand names including uCampaign and Jarbik./2 Through these brands, the company operates several apps available for download in the App Store./3 These apps appear to be violating the App Store Review Guidelines by misusing users' personal information, building identical apps based on a template, and requiring users to sign in and share their contacts with the company./4

The apps operated by Political Social Media are targeted at political conservatives./5 For instance, through the uCampaign brand, the company runs the official app for the pro-gun organization, the National Rifle Association ("NRA"), and anti-abortion groups, Susan B. Anthony List ("SBA List") and Family Research Council ("FRC")./6 The company also operates the official app for President Trump's campaign committee and the app for the Great America PAC, a super PAC that supports President Trump./7 Additionally, uCampaign runs an app for the Conservative Party of Canada and the Australian Christian Lobby./8

Jarbik runs an app for the Generation Atomic, an advocacy organization that supports nuclear energy, and has managed apps for several international political movements, including a nationalist party in Malta and an anti-abortion group in Ireland./9

Political Social Media's apps for each of these organizations are virtually identical./10 The company sets up a boilerplate social media platform that is branded for each of its client organizations./11 The apps draw in supporters of those organizations who use them to chat with each other and post comments on in-app newsfeeds. The apps also offer games and challenges for users to play and receive rewards./12 The app descriptions suggest users can use the apps to stay up to date on the latest news about each client organization or candidate./13

The apps generate value for sponsoring organizations by leveraging the contacts of their users./14 Political Social Media prods users to turn over their address books and other identifying information to the app developers upon signing up./15 The company then encourages users to send messages to everyone in their address books, which benefits the sponsors./16 Even if users do not turn over their address books when they register, the apps regularly incentivize users to share their contacts. The NRA app, for instance, requires users to obtain 250 action points in order to post a comment on the platform. Users can obtain points by sharing the app with their friends or allowing the app to track their location, among other methods. BuzzFeed reported in May 2018 that some of the Political Social Media's apps required users to turn over their contact information in order access the apps' main features./17

Political Social Media founder Thomas Peters explained the app's method in a blog post discussing how his company helped Sen. Ted Cruz (R-TX) win the 2016 Iowa caucuses: As a phone app it has authorized access to a supporter's phone address book contacts. That allows it to match those contacts to Cruz's voter universes and prompt existing supporters to reach out personally to identified potential supporters. To date the feature has matched over a third of a million potential supporters who are contacts of one or more of the app's current supporters.

The second source of data are self, individual friend and neighborhood surveys. App supporters have completed over 20,000 political ID surveys about themselves, their friends and their neighbors, generating valuable cross-section data on the supporters' political views, activism affinities and personal network, essential information for a modern, data-driven campaign./18 (emphasis in original) Political Social Media uses this information to send political messages to the friends and family of an app's users./19 uCampaign boasted about the success of this model in a description of its apps on the NationBuilder website:

We follow the 80/20 rule - take your top 20% of supporters who will perform 80% of the actions and give them a smartphone app that allows them to do 10X more than what they would do on a website, while creating valuable data which is automatically synced to your Nation. Our platform allows you to manage your app once we have collaborated to build and launch it. We offer advanced features such as matching your supporters' phone address book contacts to voter files and big data as well as crowdsourcing grassroots activities like text messaging and fundraising to your supporters. Match your supporters to their state and federal elected officials using geolocation to make lobbying seamless. Our clients include local, state, federal, presidential, international, advocacy and referendums./20 (emphasis added)

The Nationbuilder description also reveals the scale of the privacy problem: for every person that downloads the app, the app can identify 34 possible supporters of an organization./21 Misusing Personal Information

While Political Social Media has received glowing media profiles for ingeniously leveraging users' contact data, the company's political activities have been scrutinized by government investigators./22 For instance, in 2016 uCampaign developed an app for the Vote Leave campaign, which advocated for Great Britain to leave the European Union./23 A parliamentary committee tasked with investigating the campaign specifically cited the "data privacy concerns raised" by uCampaign's app./24

Additionally, Political Social Media drew widespread criticism for misusing its users' data during the 2016 presidential election. For instance, NBC News reported:

Immediately after installation, the app requests access to users' address books; app creator Thomas Peters, CEO of uCampaign, said this is to help users share the app with their friends. But the app's privacy policy says the campaign can use that data -- the names, emails, home addresses and more stored in a user's address book -- however they'd like.

"Trump's [app] is at a whole other level," explained the American Civil Liberties' Nicole Ozer. "It's not just to pay with your privacy, but to sell out your friends and colleagues who are in your contact list."/25

Indeed, Business Insider reported in November 2016:

If users download the app and agree to share their address books, including phone numbers and emails, the app then shoots the data [sic] a third-party vendor, which looks for matches to existing voter file information that could give clues as to what may motivate that specific voter. Thomas Peters, whose company uCampaign created Trump's app, said the app is "going absolutely granular," and will -- with permission -- send different, A/B tested messages to users' contacts based on existing information./26

Alarmingly, though, a 2018 version of the company's privacy policy stated that the company "may share your personal information with other organizations, groups, causes, campaigns, political organizations, and our clients that we believe have similar viewpoints, principles or objectives as us."/27 As BuzzFeed reported:

This means data can be shared...with previous clients such as the NRA, the Trump presidential campaign, the Republican National Committee, and the Susan B. Anthony List, a major US anti-abortion group. In the UK, the network includes the Conservative Party and main pro-Brexit campaign, Vote Leave./28

Political Social Media's Privacy Policies

Political Social Media's apps can access users' precise location, camera, calendars, and contacts if users give them permission./29 Of the 13 apps currently available for download from Political Social Media, 11 of them, including the apps for the NRA, the SBA List, and FRC, have identical privacy policies. Notably, the privacy policies are not found on the websites of the sponsoring organizations themselves. Instead, using the App Store, all of these apps link to privacy policies on websites operated by Jarbik, uCampaign, or RumbleUp, another brand that belongs to Political Social Media./30 The policy - common to all Political Social Media brands -- provides: As noted above, we share your Personal Information with the uCampaign client that administers the Client Application that you use. Except as otherwise set forth in this Privacy Policy, we do not share your information with other third parties, nor do we share information between uCampaign clients./31

This policy gives the company wide latitude to share personal information of its users: We may, with your permission, collect third party contact information (including, without limitation, names, telephone numbers, emails and social media handles, if available) from your mobile address book.

We may receive Personal Information about you from other users of the Platform. This may happen if they connect their address books to our services, or if they invite you to use our services via the Platform. Additionally, we may also receive Personal Information about you from the uCampaign client administering the Client Application. If you have received a text message through our services, your information was uploaded to the Platform through the uCampaign client that contacted you. We will treat all such Personal Information in accordance with this privacy policy.

We may share your Personal Information with other entities affiliated with us for internal reasons, primarily for business and operational purposes. uCampaign, or any of its assets, including the Platform, may be sold, or other transactions may occur in which your Personal Information is one of the business assets of the transaction. In such case, your Personal Information may be transferred./32 (emphasis added)

The privacy policy for Political Social Media's apps allow the developer to collect the personal information of individuals who received text messages from an app's users, even if the recipient did not download one of the company's apps. Political Social Media does not provide message recipients with an opportunity to consent to this data collection.

While the company has removed the alarming language that BuzzFeed highlighted, the current policy still allows the company to share users' information with anyone "affiliated with us." Presumably, the company can rely on this policy to share users' data with any of the clients that use its apps. The policy further states:

Information about your use of the Platform as an end-user will also be available to the uCampaign client that is administering the Client Application. For more information about this uCampaign client's privacy practices, please refer to the client's privacy policy./33

This instruction, however, is nearly impossible. For instance, 11 of Political Social Media's apps, including SBA List's app and FRC's app, do not provide any link to the client's privacy policy. Furthermore, the SBA List's own website does not include a link to its privacy policy./34 The only way to find the SBA List's privacy policy is to use an outside search engine. And even then, the privacy policy only covers the organization's website./35 It does not mention anything about the app operated by Political Social Media.

App Store Review Guidelines

Privacy

The App Store Review Guidelines state that apps must:

Confirm that any third party with whom an app shares user data (in compliance with these Guidelines) -- such as analytics tools, advertising networks and third party SDKs, as well as any parent, subsidiary or other related entities that will have access to user data -- will provide the same or equal protection of user data as stated in the app's privacy policy and required by these Guidelines./36

For users of Political Social Media's apps, it is impossible to know if the company is adhering to this requirement. Most of the apps managed by Political Social Media do not include links to privacy policies for the organizations that have hired the company. As noted above, there is no way to find the privacy policy for the SBA list or FRC from their "official" apps.

Additionally, Political Social Media's privacy policies state:

You have the right to access your Personal Information held by us and, if necessary, have it amended or deleted. You can also request not to receive email communications and/or other marketing information from us./37

For most of the apps, though, the only contact information listed is for uCampaign or Jarbik./38 The privacy policies generally do not provide contact information for the client organizations that are the beneficiaries of the apps and presumably store the users' information. Based on these template apps and generic privacy policies, users cannot have confidence that their data will be deleted by all of the parties that obtain their personal information.

Additionally, the App Store Review Guidelines state:

Do not use information from Contacts, Photos, or other APIs that access user data to build a contact database for your own use or for sale/distribution to third parties, and don't collect information about which other apps are installed on a user's device for the purposes of analytics or advertising/marketing.

Do not contact people using information collected via a user's Contacts or Photos, except at the explicit initiative of that user on an individualized basis; do not include a Select All option or default the selection of all contacts. You must provide the user with a clear description of how the message will appear to the recipient before sending it (e.g. What will the message say? Who will appear to be the sender?)./39

Yet it is exactly such prohibited activities that drive Political Social Media's entire operation./40 Political Social Media has stated publicly that the purpose of its apps is to collect contact information from its users in order to deliver messages from its clients to their contacts at scale./41 Political Social Media's activities, therefore, are a prima facie violation of the App Store Review Guidelines.

Template Apps

The App Store Review Guidelines also prohibit Political Social Media's template model. The guidelines state:

Apps created from a commercialized template or app generation service will be rejected unless they are submitted directly by the provider of the app's content. These services should not submit apps on behalf of their clients and should offer tools that let their clients create customized, innovative apps that provide unique customer experiences. Another acceptable option for template providers is to create a single binary to host all client content in an aggregated or "picker" model, for example as a restaurant finder app with separate customized entries or pages for each client restaurant, or as an event app with separate entries for each client event./42

Nevertheless, Political Social Media provides nearly identical template apps for each of its clients. Political Social Media's contravention of Apple policy has been noted previously. TechCrunch reported that the company's apps likely would be ensnared by the guidelines and removed from the App Store./43 Unfortunately, Apple has yet to remove Political Social Media's apps despite their clear violation of this policy. The fact that the official apps for two controversial advocacy organizations, FRC and SBA List, are nearly identical and operated by Political Social Media highlights the problem with failing to implement this rule.

App Sign In

Additionally, the apps operated by Political Social Media appear to violate the account sign-in provisions of the App Store Review Guidelines. Specifically, the guidelines state: Account Sign-In: If your app doesn't include significant account-based features, let people use it without a log-in. Apps may not require users to enter personal information to function, except when directly relevant to the core functionality of the app or required by law. If your core app functionality is not related to a specific social network (e.g. Facebook, WeChat, Weibo, Twitter, etc.), you must provide access without a login or via another mechanism. Pulling basic profile information, sharing to the social network, or inviting friends to use the app are not considered core app functionality. The app must also include a mechanism to revoke social network credentials and disable data access between the app and social network from within the app. An app may not store credentials or tokens to social networks off of the device and may only use such credentials or tokens to directly connect to the social network from the app itself while the app is in use./44

Not only do Political Social Media's apps require users to sign in to have any access to the apps' features, the apps' business purpose is to generate content for its users to distribute to their contacts outside the app./45 Essentially the guidelines state that Political Social Media's strategy for disseminating political messages is "not considered core app functionality" and, therefore, is prohibited.

Conclusion

Previously, Apple has revoked access to apps that violate the company's rules. Yet here, Apple has failed to act despite clear evidence that Political Social Media has been violating several provisions of the App Store Review Guidelines. Further, beyond simply violating the rules, Political Social Media's apps have been investigated by United Kingdom government regulators and criticized by privacy advocates. Moreover, these apps are contributing to the rancorous political discourse in America and around the world. At a time when democracies are struggling to cope with and confront the ever-increasing onslaught of misleading information filtered through social media, Apple should remove these apps from the App Store to ensure users have access to rule-abiding apps that share legitimate information.

Sincerely,

Daniel E. Stevens

Executive Director

Alice C.C. Huling

Counsel

Foonotes:

1/ Political Social Media LLC, Entity Details, Delaware Department of State, Division of Corporations, accessed at https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx.

2/ Laura Silver, The Apps For Ireland's Anti-Abortion Campaigns Allow User Data To Be Shared With The NRA, BuzzFeed, May 22,2018, available at https://www.buzzfeed.com/laurasilver/ireland-anti-abortion-campaigns-appsprivacy- nra.

3/ https://itunes.apple.com/us/app/ucampaign/id920668377?mt=8#see-all/more-by-this-developer; https://itunes.apple.com/us/developer/jarbik-llc/id1232401366.

4/ https://developer.apple.com/app-store/review/guidelines/.

5/ https://itunes.apple.com/us/app/ucampaign/id920668377?mt=8#see-all/more-by-this-developer.

6/ https://itunes.apple.com/us/app/nra-ila/id1110581701?mt=8; https://itunes.apple.com/us/app/lifeimpact/ id1275319079?mt=8; https://itunes.apple.com/us/app/stand-firm/id1377187936.

7/ https://itunes.apple.com/us/app/america-first/id1135325440?mt=8; https://itunes.apple.com/us/app/greatamerica/ id1191599692?mt=8.

8/ https://itunes.apple.com/us/app/cpc-app/id1302432862?mt=8; https://apps.apple.com/us/app/australian-christianlobby/ id1155648847.

9/ https://apps.apple.com/us/app/atomic-action/id1206164857; Silver, BuzzFeed, May 22, 2018; https://web.archive.org/web/20180528161251/https://itunes.apple.com/us/app/pn-malta/id1232401367?mt=8; https://web.archive.org/web/20180528161308/https://itunes.apple.com/us/developer/jarbik-llc/id1232401366.

10/ Emma Hinchliffe, A Four-person Company is Behind the Apps of Donald Trump, the NRA and Other Conservative Groups, Mashable, October 7, 2016, available at https://mashable.com/2016/10/07/ucampaign-conservative-apps/.

11/ Silver, BuzzFeed, May 22, 2018.

12/ https://itunes.apple.com/us/app/ucampaign/id920668377?mt=8#see-all/more-by-this-developer.

13/ Id.

14/ James Vincent, Ted Cruz's app turns handing over your friends' contact info into a game, The Verge, November 11, 2015, available at https://www.theverge.com/2015/11/11/9711364/ted-cruz-campaign-app-gamification.

15/ The NRA app, for instance, asks users to share their location when they register.

16/ Natasha Singer and Nicholas Confessore, Republicans Find a Facebook Workaround: Their Own Apps, The New York Times, October 20, 2018, available at https://www.nytimes.com/2018/10/20/technology/politics-appsconservative- republican.html.

17/ See Silver, BuzzFeed, May 22, 2018.

18/ Thomas Peters, We Are the Stealth Startup that Helped Ted Cruz Win Iowa, Medium, February 4, 2016, available at https://medium.com/@uCampaignCEO/meet-the-stealth-startup-that-helped-ted-cruz-win-iowa-fea6745b8a6d.

19/ Singer and Confessore, The New York Times, Oct. 20, 2018.

20/ https://nationbuilder.com/ucampaignupdate.

21/ Id.

22/ Hinchliffe, Mashable, Oct. 7, 2016. .

23/ Mark Scott, Politicians Follow in Facebook's Footsteps on Mass Data Collection, Politico, April 8, 2018, available at https://www.politico.eu/article/facebook-cambridge-analytica-data-protection-privacy-brexit-trump-vote-leaveucampaign/.

24/ Disinformation and 'Fake News': Interim Report, Digital, Culture, Media, and Sport Committee, United Kingdom House of Commons, July 29, 2018, Chapter 3, available at https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/363/36306.htm.

25/ Jane C. Timm, Trump's New App Wants You - And Your Data, NBC News, August 31, 2016, available at https://www.nbcnews.com/politics/2016-election/trump-s-new-app-wants-you-your-data-n640236.

26/ Maxwell Tani, Donald Trump's Campaign is Using the Same Ap[p the 'Leave' Campaign Used During Brexit to Spur Voter Turnout, Business Insider, November 7, 2016, available at https://www.businessinsider.com/donaldtrumps- phone-app-brexit-2016-11.

27/ Silver, BuzzFeed, May 22, 2018.

28/ Id.

29/ https://reports.exodus-privacy.eu.org/en/reports/29364/.

30/ The following apps provide their own privacy policies: Atomic Action, Australian Conservatives, Diabetes Patient Advocacy Coalition, and the Great America PAC.

31/ http://letsw.in/privacy.html.

32/ Id.

33/ https://ucampaignapp.com/privacy.html.

34/ https://www.sba-list.org/about-susan-b-anthony-list.

35/ https://www.sba-list.org/privacy-policy.

36/ https://developer.apple.com/app-store/review/guidelines/.

37/ https://ucampaignapp.com/privacy.html.

38/ Id.; https://jarbik.com/privacy.html.

39/ https://developer.apple.com/app-store/review/guidelines/

40/ Hinchliffe, Mashable, Oct. 7, 2016.

41/ https://nationbuilder.com/ucampaignupdate. 42 https://developer.apple.com/app-store/review/guidelines/.

43/ Sarah Perez, Apple's Widened Ban on Templated Apps is Wiping Small Business from the App Store, TechCrunch, December 8, 2017, available at https://techcrunch.com/2017/12/08/apples-widened-ban-on-templated-apps-iswiping- small-businesses-from-the-app-store/.

44/ https://developer.apple.com/app-store/review/guidelines/.

45/ Singer and Confessore, The New York Times, Oct. 20, 2018.

* * *

To: Jamie Rosenberg, Vice President, Business & Operations Android & Google Play

Purnima Kochikar, Director, Google Play, Apps & Games Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043

Re: Removal of Political Social Media LLC's Apps from Google Play

Dear Mr. Rosenberg and Ms. Kochikar:

Campaign for Accountability ("CfA"), a nonprofit watchdog organization, respectfully requests that Google remove all apps developed by Political Social Media LLC from Google Play. Political Social Media operates the brands, uCampaign, LLC and Jarbik, LLC, among others, which operate approximately 12 nearly identical apps that appear to be violating the Google Play Developer Distribution Agreement and Google's Developer Program Policies.

Background

Political Social Media LLC was incorporated in Delaware on January 31, 2014./1 The company employs several brand names including uCampaign and Jarbik./2 Through these brands, the company operates several apps available for download in Google Play.3 The company appears to be violating the Google Play Developer Distribution Agreement and Google's Developer Program Policies by failing to provide adequate privacy policies, misusing users' personal information, and building template apps and submitting them to Google Play on behalf its client organizations./4

The apps operated by Political Social Media target political conservatives./5 For instance, through the uCampaign brand, the company runs the official app for the pro-gun organization, the National Rifle Association ("NRA"), and the anti-abortion groups, Susan B. Anthony List ("SBA List") and Family Research Council ("FRC")./6 The company also operates the official app for President Trump's campaign committee and the app for the Great America PAC, a super PAC that supports President Trump./7 Additionally, uCampaign runs an app the Conservative Party of Canada and the Australian Christian Lobby./8

Jarbik runs an app for the Generation Atomic, an advocacy organization that supports nuclear energy, and has managed apps for several international political movements, including a nationalist party in Malta and an anti-abortion group in Ireland./9

Political Social Media's apps for each of these organizations are virtually identical./10 The company sets up a boilerplate social media platform that is branded for each of its client organizations./11 The apps draw in supporters of those organizations who use them to chat with each other and post comments on in-app newsfeeds. The apps also offer games and challenges for users to play and receive rewards./12 The app descriptions suggest users can use the apps to stay up to date on the latest news about each client organization or candidate./13

The apps generate value for sponsoring organizations by leveraging the contacts of their users./14 Political Social Media prods users to turn over their address books and other identifying information to the app developers upon signing up./15 The company then encourages users to send messages to everyone in their address books, which benefits the sponsors.16 Even if users do not turn over their address books when they register, the apps regularly incentivize users to share their contacts. The NRA app, for instance, requires users to obtain 250 action points in order to post a comment on the platform. Users can obtain points by sharing the app with their friends or allowing the app to track their location, among other methods. BuzzFeed reported in May 2018 that some of the Political Social Media's apps previously required users to turn over their contact information in order access the apps' main features./17

Political Social Media founder Thomas Peters explained the app's method in a blog post discussing how his company helped Sen. Ted Cruz (R-TX) win the 2016 Iowa caucuses: As a phone app it has authorized access to a supporter's phone address book contacts. That allows it to match those contacts to Cruz's voter universes and prompt existing supporters to reach out personally to identified potential supporters. To date the feature has matched over a third of a million potential supporters who are contacts of one or more of the app's current supporters.

The second source of data are self, individual friend and neighborhood surveys. App supporters have completed over 20,000 political ID surveys about themselves, their friends and their neighbors, generating valuable cross-section data on the supporters' political views, activism affinities and personal network, essential information for a modern, data-driven campaign.18 (emphasis in original) Political Social Media uses this information to send political messages to the friends and family of an app's users.19 uCampaign boasted about the success of this model in a description of its apps on the NationBuilder website:

We follow the 80/20 rule - take your top 20% of supporters who will perform 80% of the actions and give them a smartphone app that allows them to do 10X more than what they would do on a website, while creating valuable data which is automatically synced to your Nation. Our platform allows you to manage your app once we have collaborated to build and launch it. We offer advanced features such as matching your supporters' phone address book contacts to voter files and big data as well as crowdsourcing grassroots activities like text messaging and fundraising to your supporters. Match your supporters to their state and federal elected officials using geolocation to make lobbying seamless. Our clients include local, state, federal, presidential, international, advocacy and referendums./20 (emphasis added)

The Nationbuilder description also reveals the scale of the privacy problem: for every person that downloads the app, the app can identify 34 possible supporters of an organization.21 Misusing Personal Information

While Political Social Media has received glowing media profiles for ingeniously leveraging users' contact data, the company's political activities have been scrutinized by government investigators.22 For instance, in 2016 uCampaign developed an app for the Vote Leave campaign, which advocated for Great Britain to leave the European Union.23 A parliamentary committee tasked with investigating the campaign specifically cited the "data privacy concerns raised" by uCampaign's app./24

Additionally, Political Social Media drew widespread criticism for misusing its users' data during the 2016 presidential election. For instance, NBC News reported: Immediately after installation, the app requests access to users' address books; app creator Thomas Peters, CEO of uCampaign, said this is to help users share the app with their friends. But the app's privacy policy says the campaign can use that data -- the names, emails, home addresses and more stored in a user's address book -- however they'd like.

"Trump's [app] is at a whole other level," explained the American Civil Liberties' Nicole Ozer. "It's not just to pay with your privacy, but to sell out your friends and colleagues who are in your contact list."/25

Indeed, Business Insider reported in November 2016:

If users download the app and agree to share their address books, including phone numbers and emails, the app then shoots the data [sic] a third-party vendor, which looks for matches to existing voter file information that could give clues as to what may motivate that specific voter. Thomas Peters, whose company uCampaign created Trump's app, said the app is "going absolutely granular," and will -- with permission -- send different, A/B tested messages to users' contacts based on existing information./26

Alarmingly, though, a 2018 version of the company's privacy policy stated that the company "may share your personal information with other organizations, groups, causes, campaigns, political organizations, and our clients that we believe have similar viewpoints, principles or objectives as us."/27 As BuzzFeed reported:

This means data can be shared...with previous clients such as the NRA, the Trump presidential campaign, the Republican National Committee, and the Susan B. Anthony List, a major US anti-abortion group. In the UK, the network includes the Conservative Party and main pro-Brexit campaign, Vote Leave./28

Political Social Media's Privacy Policies

Political Social Media's apps can access users' precise location, camera, calendars, and contacts if users give them permission./29 Of the 12 apps currently available for download from Political Social Media, 10 of them, including the apps for the NRA, the SBA List, and FRC, have identical privacy policies. Notably, the privacy policies listed in the app are not found on the websites of the sponsoring organizations themselves. Instead, using Google Play, all of these apps link to privacy policies on websites operated by Jarbik, uCampaign, or RumbleUp, another brand that belongs to Political Social Media./30 The policy - common to all Political Social Media brands - provides:

As noted above, we share your Personal Information with the uCampaign client that administers the Client Application that you use. Except as otherwise set forth in this Privacy Policy, we do not share your information with other third parties, nor do we share information between uCampaign clients./31

This policy gives the company wide latitude to share personal information of its users: We may, with your permission, collect third party contact information (including, without limitation, names, telephone numbers, emails and social media handles, if available) from your mobile address book.

We may receive Personal Information about you from other users of the Platform. This may happen if they connect their address books to our services, or if they invite you to use our services via the Platform. Additionally, we may also receive Personal Information about you from the uCampaign client administering the Client Application. If you have received a text message through our services, your information was uploaded to the Platform through the uCampaign client that contacted you. We will treat all such Personal Information in accordance with this privacy policy.

We may share your Personal Information with other entities affiliated with us for internal reasons, primarily for business and operational purposes. uCampaign, or any of its assets, including the Platform, may be sold, or other transactions may occur in which your Personal Information is one of the business assets of the transaction. In such case, your Personal Information may be transferred./32 (emphasis added)

The privacy policy for Political Social Media's apps allows the developer to collect the personal information of individuals who received text messages from an app's users, even if the recipient did not download one of the company's apps. Political Social Media does not provide message recipients with an opportunity to consent to this data collection./33

While the company has removed the alarming language that BuzzFeed highlighted, the current policy still allows the company to share users' information with anyone "affiliated with us." Presumably, the company can rely on this policy to share users' data with any of the clients that use its apps. The policy further states:

Information about your use of the Platform as an end-user will also be available to the uCampaign client that is administering the Client Application. For more information about this uCampaign client's privacy practices, please refer to the client's privacy policy./34

The instruction to refer to "the client's privacy policy" is futile. Ten of Political Social Media's apps, including those of FRC and SBA List, do not, in fact, provide a link to the client's privacy policy. Beyond the app, the SBA List's own website does not even include a link to its privacy policy.35 The only way to find the SBA List's organizational privacy policy is through an outside search engine. And even then, the available policy applies only to the organization's website; there is no reference to the Political Social Media app.36 Similarly, FRC's privacy policy does not provide any information about its app./37

Google Play Developer Distribution Agreement

Privacy

Google provides developers with a wealth of information regarding how to build apps for Android and Google Play. Repeatedly, Google emphasizes the requirement that app developers protect users' privacy. For instance, the Google Play Developer Distribution Agreement states:

You agree that if You make Your Products available through Google Play, You will protect the privacy and legal rights of users. If the users provide You with, or Your Product accesses or uses, usernames, passwords, or other login information or personal information, You agree to make the users aware that the information will be available to Your Product, and You agree to provide legally adequate privacy notice and protection for those users. Further, Your Product may only use that information for the limited purposes for which the user has given You permission to do so./38 (emphasis added)

Despite the agreement, Political Social Media does not provide an "adequate privacy notice" for its users. For 10 of the 12 apps offered by Political Social Media, the only privacy policy included is that for Political Social Media's companies.

Moreover, Political Social Media's privacy policy states:

You have the right to access your Personal Information held by us and, if necessary, have it amended or deleted. You can also request not to receive email communications and/or other marketing information from us./39

For most of the apps, though, the only contact information listed is for uCampaign or Jarbik./40 There is no contact information for the client organizations benefitting from the apps and, presumably, storing users' information. As a result, users cannot have confidence that their data will be deleted by all of the parties that obtain their personal information.

Personal Information

Beyond the privacy policy, the Google Play Developer Distribution Agreement explains that developers must not misuse the personal information of their users. The Privacy, Security, and Deception section of Google's Developer Program Policies states: You must be transparent in how you handle user data (e.g., information collected from or about a user, including device information). That means disclosing the collection, use, and sharing of the data, and limiting the use of the data to the purposes disclosed, and the consent provided by the user. In addition, if your app handles personal or sensitive user data, please also refer to the additional requirements in the "Personal and Sensitive Information" section below./41 And:

Personal and sensitive user data includes, but isn't limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts SMS and call related data, microphone and camera sensor data, and sensitive device or usage data. If your app handles sensitive user data, then you must:

- Limit your collection and use of this data to purposes directly related to providing and improving the features of the app (e.g. user anticipated functionality that is documented and promoted in the app's description).

- Post a privacy policy in both the designated field in the Play Console and within the app itself. The privacy policy must, together with any in-app disclosures, comprehensively disclose how your app collects, uses, and shares user data. Your privacy policy must disclose the type of parties to which any personal or sensitive user data is shared.

- Handle all personal or sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS)./42

An example of a "common violation" is:

An app that accesses a user's phone or contact book data and doesn't treat this data as personal or sensitive data subject to the Privacy Policy, Secure Transmission, and Prominent Disclosure requirements./43

The policy also provides that if an "app handles non-public phonebook or contact information," Google does not "allow unauthorized publishing or disclosure of people's non-public contacts."/44 Additionally, Google's Unwanted Software Policy states:

We've found that most unwanted software displays one or more of the same basic characteristics: It collects or transmits private information without the user's knowledge./45 The Developer Program Policies also prohibit apps from using a person's contacts to promote an app. The Store Listing and Promotion section states:

We don't allow apps that directly or indirectly engage in or benefit from promotion practices that are deceptive or harmful to users or the developer ecosystem. This includes apps that engage in the following behavior: Unsolicited promotion via SMS services./46

Despite the clear prohibitions, Political Social Media appears to be flagrantly violating the Google Play Developer Distribution Agreement and Google's Developer Program Policies by failing to appropriately handle the personal information of its users. As Political Social Media has stated publicly, the purpose of its apps is to collect contact information from its users in order to deliver messages from its clients to their contacts at scale./47 As Political Social Media acknowledged on Nationbuilder, its apps "Identify on average 34 individuals per supporter who downloads the app and generate up to 28 new ways to contact these individuals."/48 Permissions

Previously, Political Social Media required users to turn over their phonebook and location, among other things, in order to access most of an app's features./49 Previous versions of the Android operating software required users to grant or deny permissions to an app before installing it.50 The most recent version of Android, however, allows users to grant or deny permissions after installing an app, providing users with more control over their personal information./51 Still, Google makes clear that developers may not abuse permissions granted by users. For instance, the Google Play Developer Distribution Agreement states:

You are responsible for uploading Your Products to Google Play, providing required Product information and support to users, and accurately disclosing the permissions necessary for the Product to function on user Devices./52 The permissions section of Google's Developer Program Policies states: Permission requests should make sense to users. You may only request permissions that are necessary to implement critical current features or services in your application. You may not use permissions that give access to user or device data for undisclosed, unimplemented, or disallowed features or purposes./53

And:

Apps may only use the permission (and any data derived from the permission) to provide approved critical core app functionality (e.g. critical current features of the app that are documented and promoted in the app's description). You may never sell this data. The transfer, sharing, or licensed use of this data must only be for providing critical core features or services within the app, and its use may not be extended for any other purpose (e.g. improving other apps or services, advertising, or marketing purposes). You may not use alternative methods (including other permissions, APIs, or third-party sources) to derive data attributed to the above permissions./54

The developer guide for Android states:

In some circumstances, you want to help the user understand why your app needs a permission. For example, if a user launches a photography app, the user probably won't be surprised that the app asks for permission to use the camera, but the user might not understand why the app wants access to the user's location or contacts. Before your app requests a permission, you should consider providing an explanation to the user./55

The developer guide also states:

Only use the permissions necessary for your app to work. Depending on how you are using the permissions, there may be another way to do what you need (system intents, identifiers, backgrounding for phone calls) without relying on access to sensitive information.

And:

Be transparent. When you make a permissions request, be clear about what you're accessing, and why, so users can make informed decisions. Make this information available alongside the permission request including install, runtime, or update permission dialogues.

The developer guide also states that apps will only be allowed on Android if: The app requests only the absolute minimum permissions that it needs to support core functionality.

And:

The app does not request permissions to access sensitive data (such as Contacts or the System Log) or services that can cost the user money (such as the Dialer or SMS), unless related to a core capability of the app./56

Political Social Media's apps, however, do not abide by these standards. As the company has made abundantly clear throughout its marketing materials, the purpose of its apps is to convince users to turn over their contact information for the benefit of the sponsoring organizations. Political Social Media entices users to enjoy its platform and play the games in order to get access to the phonebooks of its users. Political Social Media's apps, therefore, are a prima facie violation of the Google Play Developer Distribution Agreement.

Template Apps

Google's Developer Program Policies also prohibit Political Social Media's template model. The guidelines regarding "repetitive content" state:

We don't allow apps that merely provide the same experience as other apps already on Google Play. Apps should provide value to users through creation of unique content or services./57

Google offers examples of common violations:

Copying content from other apps without adding any original content or value. Creating multiple apps with highly similar content and user experience. If these apps are each small in content volume, developers should consider creating a single app that aggregates all the content.

Apps that are created by an automated tool, wizard service, or based on templates and submitted to Google Play by the operator of that service on behalf of other persons are not allowed. Such apps are only permissible if they are published by an individually registered developer account belonging to the user of the automated tool, not the operator of the service./58

Nevertheless, Political Social Media is publishing nearly identical template apps for each of its clients and submitting them to Google Play using its own developer account, instead of each client, including FRC and SBA List -- submitting its own app as Google requires./59 As TechCrunch reported, Google's policy was rewritten to address this exact problem./60

Unfortunately, Google has yet to remove Political Social Media's apps from Google Play despite the company's clear violation of this policy. The fact that the official apps for two controversial advocacy organizations, FRC and SBA List, are nearly identical and published by Political Social Media highlights the problem with failing to implement this rule.

Enforcement

The Google Play Developer Distribution Agreement states:

If Google becomes aware and determines in its sole discretion that a Product or any portion thereof (a) violates any applicable law; (b) violates this Agreement, applicable policies, or other terms of service, as may be updated by Google from time to time in its sole discretion; (c) violates terms of distribution agreement with device manufacturers and Authorized Providers; or (d) creates liability for or has an adverse impact on Google or Authorized Providers; then Google may reject, remove, suspend, or reclassify the Product from Google Play or from Devices. Google reserves the right, at its sole discretion, to suspend and/or bar any Product and/or Developer from Google Play or from Devices./61

Here, it is clear that Political Social Media's apps violate the Google Play Developer Distribution Agreement and should be removed from Google Play.

Conclusion

Previously, Google has revoked access to apps that violate the company's rules. Yet here, Google has failed to act despite clear evidence that Political Social Media and, to a lesser extent, FRC and SBA List and others by failing to submit their own apps, are in violation of the Google Play Developer Distribution Agreement. Further, beyond simply violating the rules, Political Social Media's apps have been investigated by United Kingdom government regulators and criticized by privacy advocates. At a time when democracies are struggling to cope with and confront the ever-increasing onslaught of misleading information filtered through social media, Google should remove these apps from Google Play to ensure users have access to rule-abiding apps that share legitimate information.

Sincerely,

Daniel E. Stevens

Executive Director

Alice C.C. Huling

Counsel

Footnotes:

1/ Political Social Media LLC, Entity Details, Delaware Department of State, Division of Corporations, accessed at https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx.

2/ Laura Silver, The Apps For Ireland's Anti-Abortion Campaigns Allow User Data To Be Shared With The NRA, BuzzFeed, May 22,2018, available at https://www.buzzfeed.com/laurasilver/ireland-anti-abortion-campaigns-appsprivacy- nra.

3/ https://play.google.com/store/apps/developer?id=Jarbik; https://play.google.com/store/apps/developer?id=uCampaign.

4/ https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html; https://play.google.com/about/developer-content-policy/.

5/ https://play.google.com/store/apps/developer?id=uCampaign.

6/ https://play.google.com/store/apps/details?id=com.ucampaignapp.nra; https://play.google.com/store/apps/details?id=com.ucampaignapp.sba; https://play.google.com/store/apps/details?id=co.ucampaign.frc.

7/ https://play.google.com/store/apps/details?id=com.ucampaignapp.americafirst; https://play.google.com/store/apps/details?id=com.ucampaignapp.gap.

8/ https://play.google.com/store/apps/details?id=co.ucampaign.cpc; https://play.google.com/store/apps/details?id=com.ucampaignapp.acl.

9/ https://play.google.com/store/apps/details?id=com.ucampaignapp.gna; Silver, BuzzFeed, May 22, 2018; https://appadvice.com/game/app/pn-malta/1232401367.

10/ Emma Hinchliffe, A Four-person Company is Behind the Apps of Donald Trump, the NRA and Other Conservative Groups, Mashable, October 7, 2016, available at https://mashable.com/2016/10/07/ucampaign-conservative-apps/.

11/ Silver, BuzzFeed, May 22, 2018.

12/ https://play.google.com/store/apps/developer?id=uCampaign.

13/ Id.

14/ James Vincent, Ted Cruz's app turns handing over your friends' contact info into a game, The Verge, November 11, 2015, available at https://www.theverge.com/2015/11/11/9711364/ted-cruz-campaign-app-gamification.

15/ The NRA app, for instance, asks users to share their location when they register.

16/ Natasha Singer and Nicholas Confessore, Republicans Find a Facebook Workaround: Their Own Apps, The New York Times, October 20, 2018, available at https://www.nytimes.com/2018/10/20/technology/politics-appsconservative- republican.html.

17/ Older versions of the Android operating system required apps to seek these permissions from users when they downloaded the app. The most recent version of Android allows apps to obtain users' permission after installing the app. See https://developer.android.com/guide/topics/permissions/overview?hl=en; Silver, BuzzFeed, May 22, 2018.

18/ Thomas Peters, We Are the Stealth Startup that Helped Ted Cruz Win Iowa, Medium, February 4, 2016, available at https://medium.com/@uCampaignCEO/meet-the-stealth-startup-that-helped-ted-cruz-win-iowa-fea6745b8a6d.

19/ Singer and Confessore, The New York Times, Oct. 20, 2018.

20/ https://nationbuilder.com/ucampaignupdate.

21/ Id.

22/ Hinchliffe, Mashable, Oct. 7, 2016.

23/ Mark Scott, Politicians Follow in Facebook's Footsteps on Mass Data Collection, Politico, April 8, 2018, available at https://www.politico.eu/article/facebook-cambridge-analytica-data-protection-privacy-brexit-trump-vote-leaveucampaign/.

24/ Disinformation and 'Fake News': Interim Report, Digital, Culture, Media, and Sport Committee, United Kingdom House of Commons, July 29, 2018, Chapter 3, available at https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/363/36306.htm.

25/ Jane C. Timm, Trump's New App Wants You - And Your Data, NBC News, August 31, 2016, available at https://www.nbcnews.com/politics/2016-election/trump-s-new-app-wants-you-your-data-n640236.

26/ Maxwell Tani, Donald Trump's Campaign is Using the Same Ap[p the 'Leave' Campaign Used During Brexit to Spur Voter Turnout, Business Insider, November 7, 2016, available at https://www.businessinsider.com/donaldtrumps- phone-app-brexit-2016-11.

27/ Silver, BuzzFeed, May 22, 2018.

28/ Id.

29/ https://reports.exodus-privacy.eu.org/en/reports/29364/.

30/ The following apps provide their own privacy policies: Atomic Action, Australian Christian Lobby, Australian Conservatives, Diabetes Patient Advocacy Coalition, and the Great America PAC.

31 http://letsw.in/privacy.html.

32/ Id.

33/ As noted below, this is a violation of Google's Developer Program Policies which states that Google doesn't allow "unsolicited promotion via SMS services." See https://play.google.com/about/storelisting-promotional/.

34/ https://ucampaignapp.com/privacy.html.

35/ https://www.sba-list.org/about-susan-b-anthony-list.

36/ https://www.sba-list.org/privacy-policy.

37/ https://www.frc.org/privacy-policy.

38/ https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.

39/ https://ucampaignapp.com/privacy.html.

40/ Id.; https://jarbik.com/privacy.html.

41/ https://play.google.com/about/privacy-security-deception/personal-sensitive/.

42/ Id.

43/ Id.

44/ Id.

45 https://www.google.com/about/unwanted-software-policy.html.

46/ https://play.google.com/about/storelisting-promotional/.

47/ https://nationbuilder.com/ucampaignupdate.

48/ Id.

49/ Silver, BuzzFeed, May 22, 2018.

50/ https://developer.android.com/guide/topics/permissions/overview?hl=en.

51/ Id.

52/ https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.

53/ https://play.google.com/about/privacy-security-deception/permissions/.

54/ Id.

55/ https://developer.android.com/training/permissions/requesting.html?hl=en.

56/ https://developer.android.com/docs/quality-guidelines/core-app-quality.

57/ https://play.google.com/about/spam-min-functionality/spam/repetitive-content/.

58/ Id.

59/ Sarah Perez, Google Follows in Apple's Footsteps by Cleaning Up Its Play Store, TechCrunch, July 27, 2018, available at https://techcrunch.com/2018/07/27/google-follows-in-apples-footsteps-by-cleaning-up-its-play-store/.

60/ Id.

61/ https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.

* * *

Background on CfA's Letters to Apple and Google Calling on Companies to Remove Apps from Anti-Choice Groups

Contact: Daniel Stevens, [email protected], 202.780.5750

Campaign for Accountability ("CfA"), is a nonprofit watchdog group focused on public accountability and reproductive rights. CfA recently sent letters to executives at Apple and Google calling on the companies to expel from their platforms the apps for Family Research Council ("FRC") and Susan B. Anthony List ("SBA List"). FRC's app, STAND FIRM, and SBA List's app, Life Impact, are operated by Political Social Media LLC, an app developer that operates around 12 conservative apps in both the App Store and Google Play.

Besides STAND FIRM and Life Impact, Political Social Media also runs apps for the National Rifle Association, President Trump's campaign committee, and conservative parties in Canada and Australia. All of Political Social Media's apps, are virtually identical. For each client, including SBA List and FRC, Political Social Media sets up a boilerplate social media platform where members can chat with each other, post comments on in-app newsfeeds, and play games. New York Times: Republicans Find a Facebook Workaround: Their Own Apps Political Social Media's apps have drawn intense scrutiny because they lack basic privacy protections. For instance, the company operated an app for the Vote Leave campaign in Great Britain, and a parliamentary committee later questioned the "data privacy concerns raised" by the app. Additionally, the New York Times, NBC News, and BuzzFeed, have all examined how the company uses its apps to mine the personal data of its users. All of Political Social Media's apps, including Life Impact and STAND FIRM, appear to violate Apple's App Store Review Guidelines and the Google Play Developer Distribution Agreement.

Apple

Political Social Media, on behalf of SBA List and FRC, appears to be violating three core provisions of the App Store Review Guidelines. First, Apple prohibits app developers from misusing the contact information of its users for purposes such as building an outside database or contacting people in a users' phonebook -- the foundation of Political Social Media's business model. The company has boasted about these prohibited tactics when marketing its apps to clients.

BuzzFeed: The Apps For Ireland's Anti-Abortion Campaigns Allow User Data To Be Shared With The NRA Second, Political Social Media relies on identical app templates for each of its client's apps, including Life Impact and STAND FIRM, despite Apple's prohibition on "apps created from a commercialized template or app generation service." TechCrunch reported in December 2017 that Political Social Media's apps likely would be ensnared by these rules and removed from the App Store, but Apple has yet to act.

Third, Apple's guidelines stipulate that if an app "doesn't include significant account-based features," people should be allowed to use the app without being required to log in. Nevertheless, Political Social Media's apps, including Life Impact and STAND FIRM, require users to sign in to have access to an app's features.

Google

Political Social Media's app similarly appear to violate the Google Play Developer Distribution Agreement and Google's Developer Program Policies. First, Political Social Media does not provide an "adequate privacy notice" for its users, since the company does not provide links to the privacy policies for the organizations, like SBA List and FRC, that hire Political Social Media to run their apps.

NBC News: Trump's New App Wants You - And Your Data

Second, Political Social Media appears to be violating Google's repeated instructions to be transparent in handling users' personal information. Political Social Media has stated publicly that the purpose of its apps is to collect users' phonebooks and location data in order to deliver messages from its clients to their associates but does not disclose this information to users. Third, Google requires developers to use only "the permissions necessary for [the] app to work." Yet Political Social Media appears to violate this policy by enticing users to give away their personal information by granting them access to more features in the app or awarding them points.

Fourth, Google requires organizations like SBA List and FRC to submit apps to Google Play in their own name. Political Social Media, however, operates Life Impact and STAND FIRM through its developer account and SBA List has not submitted the app. TechCrunch has also pointed out this discrepancy, but Google has yet to act.

TechCrunch: Google Follows in Apple's Footsteps by Cleaning up its Play Store Campaign for Accountability is nonprofit watchdog organization that uses research, litigation, and aggressive communications to expose misconduct and malfeasance in public life and hold those who act at the expense of the public good accountable for their actions.