Enabling Multilingual Privacy Policy Audits: Large-Scale Analysis of Spanish Mobile Apps

Policymakers enact and revise privacy laws expecting meaningful benefits for their people in practice. While scholarship has measured the real-world impact of some privacy regulations-the EU and California most notably-limited empirical evidence exists for many of the more than 140 countries that have implemented some form of privacy legislation. Switzerland, a multilingual country bordered almost entirely by EU states, is one such example. This paper analyzes the extent to which a 2023 alignment of Swiss privacy law with EU privacy regulation affected website privacy policies in Switzerland. To address Switzerland's unique multilingual culture, we develop an LLM-based pipeline that extracts legally relevant information as document-level labels in a single inference without requiring translation. On a benchmark of 120 expert-annotated privacy policies in German, French, Italian, and English, our pipeline achieves F1 scores above 0.90 for most pairs of languages and legally relevant disclosures. Applying this pipeline to privacy policies we collected from more than 35,000 Swiss- and EU-facing websites before and after the 2023 privacy law revision, we find significant increases in both mandatory and voluntary disclosures of data subject rights among Swiss privacy policies. In exploring the mechanisms driving increased disclosure rates, we discover heavy use of automated privacy policy generators and find that generated policies are associated with up to 15 percentage points higher disclosure rates. These results provide large-scale empirical evidence of how regulatory change and novel drafting technologies impact the content of privacy policies in a unique multilingual environment.

Privacy policies are essential for users to understand how service providers handle their personal data. However, these documents are often long and complex, as well as filled with technobabble and legalese, causing users to unknowingly accept terms that may even contradict the law. While summarizing and interpreting these privacy policies is crucial, there is a lack of high-quality English parallel corpus optimized for legal clarity and readability. To address this issue, we introduce APPSI-139, a high-quality English privacy policy corpus meticulously annotated by domain experts, specifically designed for summarization and interpretation tasks. The corpus includes 139 English privacy policies, 15,692 rewritten parallel corpora, and 36,351 fine-grained annotation labels across 11 data practice categories. Concurrently, we propose TCSI-pp-V2, a hybrid privacy policy summarization and interpretation framework that employs an alternating training strategy and coordinates multiple expert modules to effectively balance computational efficiency and accuracy. Experimental results show that the hybrid summarization system built on APPSI-139 corpus and the TCSI-pp-V2 framework outperform large language models, such as GPT-4o and LLaMA-3-70B, in terms of readability and reliability. The source code and dataset are available at https://github.com/EnlightenedAI/APPSI-139.

The advent of LLMs has significantly changed the research on privacy policy and data compliance analysis by enabling tasks that previously required specialized, domain-specific tools. However, it remains unclear to what extent LLMs can truly replicate the diverse functionalities, and the wide range of methodologies and analysis offered by prior work. In this paper, we conduct the first systematic evaluation of whether off-the-shelf LLMs can replace specialized privacy analysis tools. We study six representative tools spanning three major functionalities: contradiction detection, regulatory compliance analysis, and privacy policy summarization and aggregation, and across three intermediate tasks: structured data extraction using tuples, Semantic Role Labeling (SRL) and manual privacy policy labeling. We compare the performance of two state-of-the-art LLMs (GPT-5.2 and Gemini-2.5 in various configurations) against the tools by directly prompting the models to perform corresponding functionalities and tasks on a custom dataset of 10 privacy policies, allowing us to assess whether off-the-shelf models can produce tool-specific functionalities without further engineering or domain-specific training, major limitations in prior work. Our results show that LLMs consistently match or exceed the capabilities of existing tools across the functionalities. In manual labeling of first-party collection entities, LLMs achieved an average precision of 81.8% and recall of 70.9%, while for labeling of third-party sharing entities, they achieved an average precision of 91.4% and recall of 70.8% compared to the OPP-115 dataset. Overall, our findings indicate that LLMs can effectively perform a broad range of functionalities and tasks in privacy policy and regulation analysis that previously required specialized tools.