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A Tale of Two Regulatory Regimes: Creation and Analysis of a Bilingual Privacy Policy Corpus

Over the past decade, researchers have started to explore the use of NLP to develop tools aimed at helping the public, vendors, and regulators analyze disclosures made in privacy policies. With the introduction of new privacy regulations, the language of privacy policies is also evolving, and disclosures made by the same organization are not always the same in different languages, especially when used to communicate with users who fall under different jurisdictions. This work explores the use of language technologies to capture and analyze these differences at scale. We introduce an annotation scheme designed to capture the nuances of two new landmark privacy regulations, namely the EU’s GDPR and California’s CCPA/CPRA. We then introduce the first bilingual corpus of mobile app privacy policies consisting of 64 privacy policies in English (292K words) and 91 privacy policies in German (478K words), respectively with manual annotations for 8K and 19K fine-grained data practices. The annotations are used to develop computational methods that can automatically extract “disclosures” from privacy policies. Analysis of a subset of 59 “semi-parallel” policies reveals differences that can be attributed to different regulatory regimes, suggesting that systematic analysis of policies using automated language technologies is indeed a worthwhile endeavor.