New App Privacy Disclosures Required by Apple

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New apps and app updates submitted to Apple's App Store on or after December 8, 2020 must include new privacy information before they can be published in the App Store. Referred to as a privacy "nutrition label", app publishers will be required to disclose information regarding their apps' data collection and use practices, including the practices of third-party partners whose code is integrated into the app, which is intended to help users understand an app's privacy practices before they download the app on any Apple platform. On each app's product page, users will be able to learn about some of the data types the app may collect, and whether that data is linked to them or used to track them. Notably, for apps currently available in the App Store, there is no need to provide the new privacy disclosures until developers submit an update to that app.

Under the new requirements, you must identify all of the types of data that are collected by you or your third-party partners, unless the data meets all of certain criteria delineated by Apple for optional disclosures. The categories of type of data collected that require disclosure include: contact information, certain health and fitness data, financial information, location, sensitive information, contacts, user content, browsing history, search history, identifiers, purchases, usage data, diagnostics, and other data. More detailed information regarding the data that falls within these categories can be found at: Apple.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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