The Federal Court on Friday found the US-incorporated tech giant breached Australian consumer law by misleading some privacy-conscious Australians who had tried to adjust location tracking.

While some consumers may have turned location history "off" on their Google accounts, the collection and use of their location data continued because the "Web and App Activity" function was still toggled on.

Consumers were thus tracked despite believing they had secured their privacy.

Friday's ruling was described as a world first by the chairman of the Australian Competition and Consumer Commission, Rod Sims.

Mr Sims reiterated Google's business model was "to collect as much data as it possibly can" from users - who use its Google Account services for nothing - and monetise the data by selling it to advertisers.

Those advertisers can then target ads to the individual user based on where they've been and what they have interacted with online.

While Mr Sims did not criticise that business model, he said those who sought to opt out of digital platforms' tracking should not be misled.

"Some consumers just don't care whether the platforms and others know exactly what they're doing and when, others care a lot," Mr Sims told reporters.

"When consumers take steps to stop Google collecting and storing the location data, they should not be misled into what they actually have to do to achieve that outcome.

"If you buy any good or service, you want a good understanding of what you are actually letting yourself in for."

Google said in a statement it had improved its privacy controls and there was no allegation it had breached the Australian privacy act.

It pointed out the ACCC's case had failed on some fronts.

The court rejected the allegation that Google was still misleading consumers after updating its location history statement in May 2018.

Google faces a maximum fine of $1.1 million per breach, but the court will need to determine what constitutes a breach and the number of breaches that have occurred.

Mr Sims said that because the major digital platforms are reliant upon data accumulation to maximise revenue, "there's always that incentive to not perhaps be up front with you in terms of what data they're collecting, in case you object".

The ACCC has two other cases against digital platforms before Australian courts - one involving Facebook's now-defunct "Onavo Protect" app and another involving Google's information collection activities.

Mr Sims said he believed "there'll be more cases coming".

He also reiterated Australian privacy laws must be updated to reflect the country's data-driven economy.

"This is very pervasive technology and we want to make sure the price you're paying, which is your data, is a price you're comfortable to pay," Mr Sims said.

Australian Associated Press