QUESTION

We found a template Privacy Policy and Terms of Use online, is that good enough for us to use?

SHORT ANSWER
Simply put: no. Privacy Policies and Terms of Use much reflect what you actually do with the data. Templates, without doing more, will not work.
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At a minimum, you’ve got to say what you do and do what you say when it comes to your customers’ information. Not only does this type of transparency build the type of trust that is the foundation for good client relationships, it is also a regulatory requirement.

Because templates aren’t created based on how your site or app actually runs, there’s a good chance that these documents will not describe your policies and practices accurately—not a good place to be for what are (likely) the only privacy-related documents that your customers and regulators see. Auditing your business’s policies and practices while working with an attorney to tailor your documentation is the best and most efficient way to get on track with privacy regulations.