The App Store now helps users better understand an app’s privacy practices before they download the app on any Apple platform. On each app’s product page, users can learn about some of the data types the app may collect, and whether that data is linked to them or used to track them. You’ll need to provide information about your app’s privacy practices, including the practices of third-party partners whose code you integrate into your app, in App Store Connect. This information is required to submit new apps and app updates to the App Store.
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Answering app privacy questions
As you get ready to select your answers from the options presented in App Store Connect, keep in mind:
- You need to identify all of the data you or your third-party partners collect, unless the data meets all of the criteria for optional disclosure listed below.
- Your app’s privacy practices should follow the App Store Review Guidelines and all applicable laws.
- You’re responsible for keeping your responses accurate and up to date. If your practices change, update your responses in App Store Connect. You may update your answers at any time, and you do not need to submit an app update in order to change your answers.
Account Holders and Admins can learn app promotion strategy in App Store Connect.
The purpose of the label is to help your customers understand what data is collected from your app and how it is used. To complete that, you’ll need to know the types of data that you and/or your third-party partners collect from your app before answering the questions in App Store Connect. Keep in mind that even if you collect the data for reasons other than analytics or advertising, it still needs to be declared. For example, if you collect data solely for the purpose of app functionality, declare the data on your label and indicate that it is only being used for that purpose.
“Collect” refers to transmitting data off the device in a way that allows you and/or your third-party partners to access it for a period longer than what is necessary to service the transmitted request in real time.
“Third-party partners” refers to analytics tools, advertising networks, third-party SDKs, or other external vendors whose code you’ve added to your app.
Data types that meet all of the following criteria are optional to disclose:
- The data is not used for tracking purposes, meaning the data is not linked with Third-Party Data for advertising or advertising measurement purposes, or shared with a data broker. For details, see the Tracking section.
- The data is not used for Third-Party Advertising, your Advertising or Marketing purposes, or for Other Purposes, as those terms are defined in the Tracking section.
- Collection of the data occurs only in infrequent cases that are not part of your app’s primary functionality, and which are optional for the user.
- The data is provided by the user in your app’s interface, it is clear to the user what data is collected, the user’s name or account name is prominently displayed in the submission form alongside the other data elements being submitted, and the user affirmatively chooses to provide the data for collection each time.
Data types must meet all criteria in order to be considered optional for disclosure. If a data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in App Store Connect.
Examples of data that may not need to be disclosed include data collected in optional feedback forms or customer service requests that are unrelated to the primary purpose of the app and meet the other criteria above.
For the purpose of clarity, data collected on an ongoing basis after an initial request for permission must be disclosed.
Regulated Financial Services Disclosure
Data types that are collected by an app that facilitates regulated financial services and where the data collected meets all of the following criteria are optional to disclose:
- Collection of the regulated data is in accordance with a legally required privacy notice under applicable financial services or data protection laws or regulations (e.g., GDPR or GLBA).
- Collection by the app of that data occurs only in cases that are not part of your app’s primary functionality, and which are optional for the user.
- Such notice provides that data is not shared with unaffiliated third parties to market other products and services.
- Such data is not linked with third-party data for advertising purposes or shared with a data broker except for purposes of fraud detection or prevention or security purposes, or with a consumer reporting agency for credit reporting.
Data types must meet all criteria in order to be considered optional for disclosure. If a data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in your privacy section.
Health Research Disclosure
Data types that are collected as part of a health research study and where the data collected meets all of the following criteria are optional to disclose:
- The data is collected by an entity whose collection of the data is subject to an informed consent form (ICF) as part of a health research study that has been reviewed and approved by an institutional review board or ethics review board.
- All such data collection must follow the relevant App Store Guidelines and the data may not be used for tracking purposes.
If the data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in your privacy section.
Types of data
Refer to the list of data types below and compare them to the data collection practices in your app.
You should have a clear understanding of how each data type is used by you and your third-party partners.
For example, collecting an email address and using it to authenticate the user and personalize the user’s experience within your app would include App Functionality and Product Personalization.
Data linked to the user
You’ll need to identify whether each data type is linked to the user’s identity (via their account, device, or other details) by you and/or your third-party partners. Data collected from an app is often linked to the user’s identity, unless specific privacy protections are put in place before collection to de-identify or anonymize it, such as:
- Stripping data of any direct identifiers, such as user ID or name, before collection.
- Manipulating data to break the linkage and prevent re-linkage to real-world identities.
Additionally, in order for data not to be linked to a particular user’s identity, you must avoid certain activities after collection:
- You must not attempt to link the data back to the user’s identity.
- You must not tie the data to other datasets that enable it to be linked to a particular user’s identity.
Note: “Personal Information” and “Personal Data”, as defined under relevant privacy laws, are considered linked to the user.
You’ll need to understand whether you and/or your third-party partners use data from your app to track users and, if so, which data is used for this purpose.
“Tracking” refers to linking data collected from your app about a particular end-user or device, such as a user ID, device ID, or profile, with Third-Party Data for targeted advertising or advertising measurement purposes, or sharing data collected from your app about a particular end-user or device with a data broker.
“Third-Party Data” refers to any data about a particular end-user or device collected from apps, websites, or offline properties not owned by you.
Examples of tracking include:
- Displaying targeted advertisements in your app based on user data collected from apps and websites owned by other companies.
- Sharing device location data or email lists with a data broker.
- Sharing a list of emails, advertising IDs, or other IDs with a third-party advertising network that uses that information to retarget those users in other developers’ apps or to find similar users.
- Placing a third-party SDK in your app that combines user data from your app with user data from other developers’ apps to target advertising or measure advertising efficiency, even if you don’t use the SDK for these purposes. For example, using a login SDK that repurposes the data it collects from your app to enable targeted advertising in other developers’ apps.
The following situations are not considered tracking:
- When the data is linked solely on the end-user’s device and is not sent off the device in a way that can identify the end-user or device.
- When the data broker uses the data shared with them solely for fraud detection or prevention or security purposes, and solely on your behalf.
Privacy Choices (Optional): A publicly accessible URL where users can learn more about their privacy choices for your app and how to manage them. For example, a webpage where users can access their data, request deletion, or make changes.
Your app has web views.
Data collected via web traffic must be declared, unless you are enabling the user to navigate the open web.
You collect and store IP address from your users.
Declare the relevant data types based on how you use IP address, such as precise location, coarse location, device ID, or diagnostics.
You offer in-app private messaging between users that are not SMS text messages.
Declare emails or text messages on your label. Text messages refer to both SMS and non-SMS messages.
Your app includes game saves, multiplayer matching, or gameplay logic.
Declare Gameplay Content on your label.
You collect different types of data from users depending on whether the user is a child, whether they are a free or paid user, whether they opt in, where they live, or for some other reason.
You use Apple frameworks or services, such as MapKit, CloudKit, or App Analytics.
If you collect data about your app from Apple frameworks or services, you should indicate what data you collect and how you use it. You are not responsible for disclosing data collected by Apple.
You use location, device identifiers, and other sensitive data, but only on device, and the data is never sent to a server.
Data that is processed only on device is not “collected” and does not need to be disclosed in your answers. If you derive anything from that data and send it off device, the resulting data should be considered separately.
You collect precise location, but immediately de-identify and coarsen it before storing.
Disclose that you collect Coarse Location, since the precise location data is immediately coarsened and precise location is not stored.
Your app includes free-form text fields or voice recordings, and users can save any type of information they want through those mediums, including names and health data.
Mark “Other User Content” to represent generic free form text fields and “Audio Data” for voice recordings. You’re not responsible for disclosing all possible data that users may manually enter in the app through free-form fields or voice recordings. However, if you ask a user to input a specific data type into a text field, such as their name or email, or if you have a feature that enables users to upload a particular media type, such as photos or videos, then you’ll need to disclose the specific type of data.
You collect data to service a request but do not retain it after servicing the request.
“Collect” refers to transmitting data off the device and storing it in a readable form for longer than the time it takes you and/or your third-party partners to service the request. For example, if an authentication token or IP address is sent on a server call and not retained, or if data is sent to your servers then immediately discarded after servicing the request, you do not need to disclose this in your answers in App Store Connect.