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Very interesting! OP if you are the developer of this, I have a few questions:

1) Did you consult with any legal entities when creating this? Is there any risk of creating legal jeopardy for people by inferring that they could use a utility like this to create a legally-sound privacy policy without consulting a lawyer?

2) What consumers currently exist for machine output of privacy policies? I can imagine a standardized machine-readable JSON file on all sites (a la sitemap.xml) could be useful for browser utilities to forewarn you about present or absent tenets of a site's privacy policy.

3) Have you considered using something like this as a boilerplate utility for actual lawyers to improve their throughput for creating privacy policies?

4) Have you considered a similar utility for site terms of service? Is the problem different in magnitude?

5) Are privacy policies legally onerous if you do them in multiple languages? Seems like translation arbitrage would be disadvantageous.



Yes, I'm the author of this. Thanks for these interesting questions! (Happy to answer other questions as well.)

1) Yes, I consulted with a lawyer for the version in one language which became the basis for this project. Though this has just been the basis, as I said, and things have changed already, and are expected to change in the future. Some kind of regular review of the current version with legal experts may be a good idea. Apart from that, please see the disclaimer that is included for obvious reasons.

2) None. It's as simple as that, sorry! The important use case has so far been using the output to display on websites. But it's obvious that, having all the input available in a structured and machine-readable form, it would be a good idea to also offer outputs in various machine-readable forms and formats. The vision was exactly that something like a "privacy-policy.json" besides your "sitemap.xml" or "robots.txt" could be helpful and an interesting first step towards a larger "ecosystem", which must necessarily exist.

3) No. I just didn't have the time for that, yet. I also don't know if that's really something that lawyers could use or would want to use. But this is definitely an interesting idea that might be worth exploring.

4) The “Terms of Service“ are a completely different beast, I would say. There's probably not much that could be re-used, and the challenges have only minor overlap, although the concept is quite similar in general.

5) You would probably declare one policy to be your canonical version that really counts, and any translations would be for information purposes and assistance only, without legal validity. Turning to the implementation in this project, translations could probably differ somewhat from each other and wouldn't need to be exact 1:1 translations, word-by-word. Languages such as "en" could also be split up into "en-US", "en-GB", etc. -- not just for the purpose of handling small language differences better, but also for the purpose of adjusting this to the jurisdiction.


On 4) I can pretty much guarantee that this [1] was from a standard template for a generic website+app gathering user info and allowing social integration. Same for the privacy policy.

[1] https://web.archive.org/web/20160603092300/https://www.thene...


Thanks! What you wanted to say is this proves that terms of service, just as a privacy policy, can be generated from templates and be used in practice, right?


Yes, exactly.


Well there is a nice disclaimer:

Disclaimer

This project does not constitute legal advice and is not to be relied upon or acted on as such. Any material presented here is for general information purposes only and may be out of date, incomplete or not suitable for your jurisdiction. You should seek independent legal advice from a qualified professional to guide your decisions around a valid and complete privacy policy.


Right, that's the disclaimer that has been put up there, both for the safety of the authors and for the safety of any potential users.

I hope that disclaimer is not deterrent. It's simply the truth: For legal purposes, you should never rely on any online resources without talking through this with a lawyer of your choice, if you want to be on the safe side. No matter if those resources are a manual guide or a computer tool.




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