What does "tracking" mean, according to Apple ?

Question

hvsmp OP

Created Oct ’22

Replies 2

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Views 1.4k

Participants 3

Hi,

We have a client portal app, synching data with a CRM. The last version of our app has been refused for this reason :

"We noticed your app accesses web content you own where you collect cookies. Cookies may be used to track users, but you do not use App Tracking Transparency to request the user's permission before collecting data used to track."

Thing is :

we collect data for audience measuring only (using Matomo) ;
there is no advertising, and no data-broker involved, no other 3rd-parties ;
we do prompt users either to accept cookie or not, only to be compliant with GDPR ;
we did not implement the App Tracking Transparency notification though.

It's unclear to decide what we must do. The answer of Apple is :

"If you do not collect cookies for tracking purposes on iOS, remove the cookie prompts or revise them to clarify you do not track users."

But we cannot remove the cookie prompt, because it's required for GDPR compliance.

Any idea of how we can solve this ?

Thank you.

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Answer 1

Claude31 OP

Oct ’22

But we cannot remove the cookie prompt, because it's required for GDPR compliance.

I don't think so. AFAIK, if you do not use cookies, you don't have to ask.

https://gdpr.eu/cookies/

To comply with the regulations governing cookies under the GDPR and the ePrivacy Directive you must:

Receive users’ consent before you use any cookies except strictly necessary cookies.
Provide accurate and specific information about the data each cookie tracks and its purpose in plain language before consent is received.
Document and store consent received from users.
Allow users to access your service even if they refuse to allow the use of certain cookies
Make it as easy for users to withdraw their consent as it was for them to give their consent in the first place.

My reading of first bullet is that you need to ask only when you use cookies.

Be cautious though: your site may set cookies that you don't know. There are tools to check if you have cookies or not (e.g., cookiebot).

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Answer 2

endecotp OP

Oct ’22

If you do not collect cookies for tracking purposes on iOS ... revise them to clarify you do not track users.

Do this.

(Are you hosting the Matomo server instance yourself?)

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