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 how to enter their responses in App Store Connect.
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.
“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.
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.
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.
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, then you’ll need to disclose the specific type of data that you request.
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.