App Store Connect: iOS Apps Must Disclose Data Collection Practices

Posted on December 22, 2020

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App Store Connect: iOS Apps Must Disclose Data Collection Practices

Apple has always prided itself on caring for the privacy of its customers. And their latest move continues in that direction — they’ve announced App Store Connect to help customers see what each app may potentially do with their user data once it’s downloaded to their devices.

What Does This Mean for Your App?

Starting December 8, 2020, all apps are now required to disclose their data collection practices, including the data collection practices of any third-party software that the app runs.

This means app developers must answer a questionnaire detailing the types of data being collected, how that data is being used, whether the app runs code from a third party, and if so, where that user data goes and whether users are being tracked by it.*

We’ve outlined a few tips below to help you if you’re using CleverTap’s SDK in your iOS app. But due to the complexity of Apple’s privacy rules and app integrations with multiple third-party SDKs, please make sure you refer to Apple’s App Privacy Details page and your own legal team to figure out the right decision for your app.

Answer the Questions Before Your Next Upgrade

From December 8, 2020 onward, the information on your data collection practices is now required when submitting new apps or app updates to the App Store.

And note that the App Store typically shuts down around the Christmas and New Year holidays each year.

Plan to answer these privacy questions even if your upgrade is down the road. It’s best to get this done sooner rather than later.

How to Answer the App Privacy Questions in App Store Connect

Data Type

Here, we outline the types of data that the CleverTap SDK collects.

There are really only 4 data types that our SDK tracks out of the box. These are:

  • Product interactions (e.g., app launches and any other user interaction configured by the app developer)
  • Technical device information (e.g., OS, device type, language, WiFi status, screen size, etc.)
  • Network information (e.g., HTTP user agent)
  • IDFV

Legend:

  • Collected: This means CleverTap SDK will track this data out of the box.
  • Not collected: This means the CleverTap SDK will not track this type of data.
  • May be, By Default: Not collected. This means the CleverTap SDK will not track this out of the box. But if you’ve configured your app to transmit it to CleverTap, respond accordingly.

 

Data Type

CleverTap Data Collection

Remarks

Contact information

  • Name
  • Email address
  • Phone number
  • Physical address
  • Other user contact info 

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Health and fitness

  • Health
  • Fitness

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Financial info

  • Payment info
  • Credit info
  • Other financial info

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Location info

  • Precise location

  • Coarse location

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Requires additional integration :
Precise Location Integration, and
Coarse Location integration (IP Address)

Sensitive info

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Contacts

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

User content

  • Emails or text messages
  • Photos or videos
  • Audio data
  • Gameplay content
  • Customer support
  • Other user content

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Browsing history

Not collected

If you have configured to transmit this data, respond accordingly.

Search history

Not collected

If you have configured to transmit this data, respond accordingly.

Identifiers

  • User ID
  • Device ID

May be, By Default: Not collected

Latest CleverTap iOS SDK does not capture IDFA or other device IDs like IMEI etc. IDFV is used to create the CleverTap ID, which is disclosed under Other Data.

Purchases

  • Purchase history

May be, By Default: Not collected

If you have configured to transmit this data, respond accordingly.

Usage data

  • Product interaction
  • Advertising data
  • Other usage data (for example, Wi-Fi)

Required, Collected

Product interaction: Yes
Advertising data: No
Other usage data: No

Product interactions: App launches are measured, as well as any other user interaction, configured by the app developer.
Advertising & Other usage data: if you have configured to transmit this data, respond accordingly.

Diagnostics data

  • Crash data
  • Performance data
  • Other diagnostics data

Not collected

Crash data: No
Performance data: No
Other diagnostics data: No

For crash & other diagnostics data: if you have configured to transmit this data, respond accordingly.

Other Data

Required, Collected

Technical device information (for example, OS, device type, language, WiFi status, screen size,  etc.) or network information (for example, IP address, HTTP user agent) is received by CleverTap.

IDFV is collected.

 

 

Data Use

How does your app handle or utilize customer data? Below, we’ve clarified the possible use cases for the user data collected. Select the ones appropriate for your app.

 

 

PurposeSelection based on how data from CleverTap will be used
Third-Party AdvertisingSelect if you share the data type with a third party for the purpose of displaying third-party ads in your app.
Developer’s Advertising or MarketingSelect if you share the data type with a third party for the purpose of displaying first-party ads in your app, sending marketing communications directly to your users, or sharing data with entities who will display your ads.
AnalyticsSelect this if the CleverTap SDK is integrated, which means you are using the data to evaluate user behavior, including to understand the effectiveness of existing product features, plan new features, or measure audience size or characteristics.
Product PersonalizationSelect if you are using the data to customize what the user sees, such as a list of recommended products, posts, or suggestions based on their past behavior. This must be selected if you plan to use CleverTap Engagement features like Product Experiences, In-App Notifications, App Inbox, etc. to personalize the product.
App FunctionalitySelect if your app uses the data to: authenticate the user, enable features, prevent fraud, implement security measures, ensure server up-time, minimize app crashes, improve scalability and performance, or perform customer support. 
Other Purposes

(any other purposes not listed)

Select if applicable.

 

 

Data Linked to the User

Data types collected through CleverTap are typically connected to identifier(s) when configured. App developers should select Yes when asked if the data is linked to an identity.

What associations the customer is capable of making (e.g. to a customer account or an identifiable individual) is unique to the customer and at its own discretion.

Tracking

You’ll need to understand whether you and your third-party partners use data from your app to track users and, if so, which data is used for this purpose. CleverTap iOS SDK does not track and it is unique to the customer and at its own discretion.

Privacy Links

Please refer to CleverTap privacy policy here: https://clevertap.com/privacy-policy/.

More Resources

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