Apple Requires Apps to Include New Privacy "Nutrition Label" by December 8, Delays Opt-In for Tracking Requirement Until Early 2021

Wilson Sonsini Goodrich & Rosati
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Wilson Sonsini Goodrich & Rosati

Apple recently announced that app developers must check a series of yes/no boxes that will generate a "nutrition label"-style summary of the app's privacy practices. This new summary, formally called "App Privacy," will be shown to users within the App Store before they install an app. This is the latest move in Apple's ongoing effort to make privacy practices more transparent, and it requires app developers to take action now to ensure they can continue to update their apps after December 8, 2020. If developers take no action, their apps will essentially be frozen as they exist on that date.

This new requirement adds to the existing requirement that apps link to a privacy policy. While the new questions address several subjects covered in a typical privacy policy, simply cross-walking an app's existing privacy policy statements into yes/no answers may not allow the developer to answer all of the questions. Apple's questions also distinguish between data used to "track" a user under Apple's broad definition of "tracking," versus data that is merely "linked" to the user. There are some limited exceptions for data practices that are "optional to disclose." If apps incorporate third-party code—such as advertising or analytics SDKS—they will also need to describe what data the third party collects, how the data may be used, and whether the data is used to track users. Apple's announcement includes a list of data types included in the questions and what the resulting labels look like. Within App Store Connect—the tool developers will use to check the boxes—developers can also see a preview of what the disclosures will look like to the end user.

Separately, Apple has delayed plans to launch its App Tracking Transparency (ATT) framework until early 2021. Under the ATT framework, apps will be required to obtain users' opt-in consent in order to track them across different online services or offline properties for targeted advertising or ad measurement purposes, or to access their device's advertising identifier.

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