Hi, We develop an app for a telephone network operator. It is a free service app to allow users to see their subscription products, usage, etc. We use a tool to show a commercial/service banner (in fact a collectionViewCell) to users. For instance, when a user is eligible for renewal we show an appropriate banner. Or if there is a special offer, we may show that to selected customers, based on their subscription parameters. Users can tap on the banner to check out the offer, or they can close it, or just ignore it. We want to track what a user selects, so that we don't show a banner that a user is clearly not interested in over and over again. We use that tracking data ourselves only. We don't share that data with other parties and we don't enrich the data with data from other parties. The data is stored in commercial tools like Firebase, but we own the data and no one outside our organisation has access. The big question is: do we need to ask the user for permission for tracking this data or not? I read the statement on the Apple User privacy and Data use page. Based on this sentence I think we don't need to ask the user for permission: "Tracking refers to the act of linking user or device data collected from your app with user or device data collected from other companies’ apps, websites, or offline properties for targeted advertising or advertising measurement purposes. Tracking also refers to sharing user or device data with data brokers.". We do not share data with other parties. I understand we do need to explain to the user exactly what we are collecting and why. Could you please confirm? Please suggest. Thanks! Frans Glorie

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