From the PDF:
In conclusion, the Data Inspectorate finds:
• App users are not adequately informed about which data is collected about them, what it is
collected for, or how the data may be reused.
• It appears unclear to the Data Inspectorate who is legally responsible (the controller) for
applications that collect personal data.
• App users’ right to access their personal data that has been collected is difficult to exercise when there is no indication of who is legally responsible for the processing (who is the controller).
• Existing opportunities to explain how apps use personal data on App Store or Android Market are seldom used. If this were done more often, users would be in a better position to decide whether to install apps or not before downloading them.
• Available opportunities to explain how personal data is used within apps are rarely used. It is worth including information here, too, so it is easily available to users once they have downloaded the apps. However, if information is given only inside the apps, users will only be informed after they have given their consent when downloading the apps – this is the wrong way round in accordance to the Personal Data Act.
• The opportunities to explain how apps use personal data on app managers’ websites are rarely used. This is unfortunate, as a publication of privacy policies would make information more available and clarify for the user who is legally responsible for the apps. It would also clarify which legal system (jurisdiction) the apps fall under in terms of using personal data.