In the case of free ad-funded applications "the ad network is a data controller, but as the developer you will likely have a duty to inform your users of what personal data will be collected, how it will be used, by whom, and what control your users can exercise," ICO said in the document.
"Consider just-in-time notifications, where the necessary information is provided to the user just before data processing occurs," the ICO said. "Notifications like this could be particularly useful when collecting more intrusive data such as GPS location, or for prompting users about features of an app that they are using for the first time. You could avoid excessive notification by remembering the user's choice for a certain time period before reminding them again."
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