Permission needed for App Tracking Transparency if we don't share info with other organisations?

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

Replies

Did you ever found an answer to your question?

We are curious as well if you ever resolved your question.

I'd love to learn the outcome because we are dealing with a similar issue on our app. We do not share data with other parties. It is quite difficult to understand Apple's position on this. The Review Board tells us to head to the forums but from what I'm seeing there are only more unanswered questions.

I'm really struggling to understand why there isn't a clear answer to this question. If you do not share data with any 3rd parties AND you own the data must you embroil your privacy policy messaging with Apple's new Apple Tracking Transparency?

By Apple's definition (below) we believe are not "tracking" in a way that violates Apple's policy or our independent commitment to our users regarding their privacy. Yet our App was recently rejected.

"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."

Any further insight is much appreciated. Thanks!

We're facing the same issue. Not tracking users, but being rejected for not popping the ATT. They specifically keep referring to the fact that we're requesting explicit permissions for GDPR purposes in Europe, but that is a completely different policy, unrelated to tracking. What I don't understanding is why we need to waste such enormous energies explaining to reviewers what their own APIs purpose is, they're essentially asking us to misuse their ATT API and confuse users. We're not going to tell our users that we track them when we do not (because it not only be misleading our users but also contradicting our privacy policy), so our only alternative is to strip analytics from the app entirely which would be so totally counter-productive for both our own progress and Apple AppStore quality.