I think it's part of the problem of writing a statement to be read by a large number of people - it could be read as "There is nothing legally forcing us to do

I think it's part of the problem of writing a statement to be read by a large number of people - it could be read as "There is nothing legally forcing us to do this, but we are doing us anyway as it is in the best interests of our users" (which is positive) OR it could be read as "We didn't have to do this; we did you a favour, but there might be situations where we don't disclose this" (which is fairly negative). FWIW, I think the former is the intent. Personally, I'd probably just say "We felt that we had to disclose this to protect the interests of our users" (and not acknowledge that they might not, or that they had to make a decision to do so), or just say what they _are_ doing ("We are disclosing this in order to protect our users") and avoid the possibility that it is misinterpreted. I don't think there is anything to be gained by saying that they might not have done this.