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Wow, nice, since my app is focused on privacy, this could become a huge marketing bonus. However, the questionaire seems quite complicated. I ask for the email

by WA 6y ago

Wow, nice, since my app is focused on privacy, this could become a huge marketing bonus. However, the questionaire seems quite complicated. I ask for the email adress and Apple wants to know if I connect the email address with the identity of a user. However, what does that even mean? I have no identity of a user except the email address.

jonathanpoulter 6y ago
Maybe they're looking to get a lot of granularity. Thinking of, https://haveibeenpwned.com/ https://haveibeenpwned.com/, you could give an email address and get value from the site, but there's no need for an account. Assuming you store the email that's certainly more of a privacy/security risk than using it once and throwing it away.
- WA 6y ago
  Possibly. The wording is odd. It assumes that I have information about the identity of a user, but the only thing I have is the email address. If my app asks for more data, which are backed up as a service to the user (no tracking), that is of course connected to the email address of the account. However, there is no effort from my side to find the actual identity of the user. This whole identity thing is very confusing. Might need to contact Apple developer support.
  - nicoburns 6y ago
    Yeah, they even ask that about User ID. I just answered yes.
  - dwaite 6y ago
    The email address is considered information about the identity of a user. It is a very broad concept. If the user has state or permissions on your site based on that email address, that email address is part of the user's account on your site.
floatingatoll 6y ago
If you only have an email address and you make zero effort to cross-reference that with other data (using, for example, any datasets you purchased, or a marketing data enhancement system) then you are not connected their email address to their identity. This is discussed here (search for “identity”): https://developer.apple.com/app-store/app-privacy-details/ https://developer.apple.com/app-store/app-privacy-details/ In contrast, when you provide Facebook an email address, they will explicitly pay a lot of databases to cross-reference your email address and tell Facebook your identity, your salary, and so on.
- sieabahlpark 6y ago
  > If you only have an email address and you make zero effort to cross-reference that with other data (using, for example, any datasets you purchased, or a marketing data enhancement system) then you are not connected their email address to their identity. The email address is an identity. To properly handle privacy you must encrypt the email address so in case of a leak only the current decrypted emails are relevant.
- TheKarateKid 6y ago
  > when you provide Facebook an email address, they will explicitly pay a lot of databases to cross-reference your email address and tell Facebook your identity, your salary, and so on. Can you elaborate on this?
  - s3r3nity 6y ago
    Just do a quick search for "DMPs" or "data management platforms." Multi-billion dollar industry that's focused on collecting data from many different sources, consolidating, and aligning towards real individuals with a combination of deterministic data and probabilistic assumptions. Then, they can sell access to that database to various companies, mostly in the ad-tech space. Source: did consulting work for an ad platform in the RTB space on the DSP side, competitor to Google. EDIT (more context / sidebar thought): this is also why Apple deserves some credit here for their moves, as they are one of the few companies with enough of a war chest to fight against these multi-BILLION dollar interests. It's the type of advantage I worry about losing if Apple has to open up different app stores on the iPhone: if a developer doesn't want to submit documentation and/or get bad publicity for lack of a privacy label, they'll just go to a different, less strict app store.
Aaargh20318 6y ago
> Apple wants to know if I connect the email address with the identity of a user. However, what does that even mean? I have no identity of a user except the email address. Identity basically means anything that allows you to uniquely identify a user, so the e-mail address would apply.
gardaani 6y ago
Another strange one is "Browsing History: Information about content the user has viewed that is not part of the app, such as websites" Apple requires apps to have a web site for customer support. Almost every web server logs anonymous data about visited pages. So, almost every apps need to have "Browsing History" checked??
- dataminded 6y ago
  Only if you are ingesting those logs, correlating them with users and storing that data somewhere.
  - gardaani 6y ago
    Apple seems to want to show privacy labels even for anonymized data which isn't linked to the user. Here's their App Store app showing category "Data Not Linked to You": https://support.apple.com/en-us/HT211971 https://support.apple.com/en-us/HT211971
    - CodesInChaos 6y ago
      That page appears to not show what the data is used for. I wonder if it's shown elsewhere, or why apple asks for that if they don't show it anywhere. As a user, that's certainly information I'd be interested in. (Documentation lists the following purposes: Third-Party Advertising, Developer’s Advertising or Marketing, Analytics, Product Personalization, App Functionality, Other Purposes)
traceroute66 6y ago
I would say Apple have made it perfectly clear "You’ll need to identify whether each data type is linked to the user’s identity (via their account, device, or other details) by you and/or your third-party partners.". In order words : On side A you have the user's email address OR hashed email address. On side B, you have other items of identifiable information ("their account", "their device", "other details"). The question is simple. Do you link side A to side B ? Yes or no.
- WA 6y ago
  What is "their account"? What is "their device"? How do I get these information from the user? I don't find this simple. If I set up an account with an email address, it's not their identity. It's just an account. They could provide a fake email for all I know.
  - traceroute66 6y ago
    "What is "their account"? What is "their device"?" Erm ? Exactly what it says ? "Their account" is their account on your platform. "Their device" is a device that they own and that you are collecting information about. As I said, its simple. Email. Are you linking it to _ANYTHING_ else ? Yes or no ? Are you are collecting an email address (or hash of an email), ON ITS OWN and not doing any further processing.... e.g. for a simple mailing list ? Or are you collecting an email address (or hash of an email) as part of broader set of data you are collecting from the user ? (e.g. email + name + address etc.) Or are you collecting an email address (or hash of an email) and then sending it off to Facebook or other API in an attempt to build a picture ?
    - WA 6y ago
      > "Their account" is their account on your platform. You mean, the Apple account on my platform? How does it get there? I don't have the Apple account of a user. I just have an email address. > "Their device" is a device that they own and that you are collecting information about. I don't collect information about their device. But you still didn't answer the question. What is "their device"? Is it a unique device ID? A fingerprint? What is it? > Are you linking it to _ANYTHING_ else ? Yes or no ? I use the email to create an account on my backend. Users can backup data to their account. But nothing ties to "identity". They could fake all of it. I don't care. I send transactional emails, such as a reset password email. > Or are you collecting an email address (or hash of an email) as part of broader set of data you are collecting from the user ? Not PII data, just stuff they enter in the app. > Or are you collecting an email address (or hash of an email) and then sending it off to Facebook or other API in an attempt to build a picture ? No. But the details of your questions show, imho, that the concept of identity is non-trivial. I can summarize it very simply: users sign up for an account, identified by an email adress (I don't care if it's real), as a service for the user to have an online backup and an easy way to sync data between devices or move them to Android. The goal is NOT to personally identify a user. But could a user be identified by the email address alone BY SOME ENTITY? Yes, probably. Do I do it? No. Do I share the data or offload it to a third party for data processing? No. Or does my rented self-managed VPS, where the backend runs, count as third party? I don't think so. But of course, I use a transactional email service to send emails to users. What about that? I do have a GDPR-compliant data processing agreement for that. But not sure what Apple wants from me in this case. Thing is: It's not trivial and Apple's guide is insufficient. That's all I'm saying. Edit: And to clarify – if it's complicated, data collecting entities such as Facebook could say "well, we did understand this differently" and simply don't tell the truth about the data they're collecting. I guess that is another point in this whole discussion: What if someone lies about their data collection practices? Any consequences? Are there downsides to lying about it?
drawkbox 6y ago
This is a huge bonus for app/game developers that have always been privacy focused, now it becomes something the business/marketing teams also want on their app. What a great day for good developers and consumers to have this as backup to helping preserve people's privacy and stop the blatant selling and abuse of private data. Thank you Apple!

by WA 6y ago

jonathanpoulter 6y ago

Maybe they're looking to get a lot of granularity. Thinking of, https://haveibeenpwned.com/ https://haveibeenpwned.com/, you could give an email address and get value from the site, but there's no need for an account. Assuming you store the email that's certainly more of a privacy/security risk than using it once and throwing it away.

WA 6y ago
Possibly. The wording is odd. It assumes that I have information about the identity of a user, but the only thing I have is the email address. If my app asks for more data, which are backed up as a service to the user (no tracking), that is of course connected to the email address of the account. However, there is no effort from my side to find the actual identity of the user. This whole identity thing is very confusing. Might need to contact Apple developer support.
- nicoburns 6y ago
  Yeah, they even ask that about User ID. I just answered yes.
- dwaite 6y ago
  The email address is considered information about the identity of a user. It is a very broad concept. If the user has state or permissions on your site based on that email address, that email address is part of the user's account on your site.

floatingatoll 6y ago

If you only have an email address and you make zero effort to cross-reference that with other data (using, for example, any datasets you purchased, or a marketing data enhancement system) then you are not connected their email address to their identity. This is discussed here (search for “identity”): https://developer.apple.com/app-store/app-privacy-details/ https://developer.apple.com/app-store/app-privacy-details/ In contrast, when you provide Facebook an email address, they will explicitly pay a lot of databases to cross-reference your email address and tell Facebook your identity, your salary, and so on.

sieabahlpark 6y ago
> If you only have an email address and you make zero effort to cross-reference that with other data (using, for example, any datasets you purchased, or a marketing data enhancement system) then you are not connected their email address to their identity. The email address is an identity. To properly handle privacy you must encrypt the email address so in case of a leak only the current decrypted emails are relevant.
TheKarateKid 6y ago
> when you provide Facebook an email address, they will explicitly pay a lot of databases to cross-reference your email address and tell Facebook your identity, your salary, and so on. Can you elaborate on this?
- s3r3nity 6y ago
  Just do a quick search for "DMPs" or "data management platforms." Multi-billion dollar industry that's focused on collecting data from many different sources, consolidating, and aligning towards real individuals with a combination of deterministic data and probabilistic assumptions. Then, they can sell access to that database to various companies, mostly in the ad-tech space. Source: did consulting work for an ad platform in the RTB space on the DSP side, competitor to Google. EDIT (more context / sidebar thought): this is also why Apple deserves some credit here for their moves, as they are one of the few companies with enough of a war chest to fight against these multi-BILLION dollar interests. It's the type of advantage I worry about losing if Apple has to open up different app stores on the iPhone: if a developer doesn't want to submit documentation and/or get bad publicity for lack of a privacy label, they'll just go to a different, less strict app store.

Aaargh20318 6y ago

> Apple wants to know if I connect the email address with the identity of a user. However, what does that even mean? I have no identity of a user except the email address. Identity basically means anything that allows you to uniquely identify a user, so the e-mail address would apply.

gardaani 6y ago

Another strange one is "Browsing History: Information about content the user has viewed that is not part of the app, such as websites" Apple requires apps to have a web site for customer support. Almost every web server logs anonymous data about visited pages. So, almost every apps need to have "Browsing History" checked??

dataminded 6y ago
Only if you are ingesting those logs, correlating them with users and storing that data somewhere.
- gardaani 6y ago
  Apple seems to want to show privacy labels even for anonymized data which isn't linked to the user. Here's their App Store app showing category "Data Not Linked to You": https://support.apple.com/en-us/HT211971 https://support.apple.com/en-us/HT211971
  - CodesInChaos 6y ago
    That page appears to not show what the data is used for. I wonder if it's shown elsewhere, or why apple asks for that if they don't show it anywhere. As a user, that's certainly information I'd be interested in. (Documentation lists the following purposes: Third-Party Advertising, Developer’s Advertising or Marketing, Analytics, Product Personalization, App Functionality, Other Purposes)

traceroute66 6y ago

I would say Apple have made it perfectly clear "You’ll need to identify whether each data type is linked to the user’s identity (via their account, device, or other details) by you and/or your third-party partners.". In order words : On side A you have the user's email address OR hashed email address. On side B, you have other items of identifiable information ("their account", "their device", "other details"). The question is simple. Do you link side A to side B ? Yes or no.

WA 6y ago
What is "their account"? What is "their device"? How do I get these information from the user? I don't find this simple. If I set up an account with an email address, it's not their identity. It's just an account. They could provide a fake email for all I know.
- traceroute66 6y ago
  "What is "their account"? What is "their device"?" Erm ? Exactly what it says ? "Their account" is their account on your platform. "Their device" is a device that they own and that you are collecting information about. As I said, its simple. Email. Are you linking it to _ANYTHING_ else ? Yes or no ? Are you are collecting an email address (or hash of an email), ON ITS OWN and not doing any further processing.... e.g. for a simple mailing list ? Or are you collecting an email address (or hash of an email) as part of broader set of data you are collecting from the user ? (e.g. email + name + address etc.) Or are you collecting an email address (or hash of an email) and then sending it off to Facebook or other API in an attempt to build a picture ?
  - WA 6y ago
    > "Their account" is their account on your platform. You mean, the Apple account on my platform? How does it get there? I don't have the Apple account of a user. I just have an email address. > "Their device" is a device that they own and that you are collecting information about. I don't collect information about their device. But you still didn't answer the question. What is "their device"? Is it a unique device ID? A fingerprint? What is it? > Are you linking it to _ANYTHING_ else ? Yes or no ? I use the email to create an account on my backend. Users can backup data to their account. But nothing ties to "identity". They could fake all of it. I don't care. I send transactional emails, such as a reset password email. > Or are you collecting an email address (or hash of an email) as part of broader set of data you are collecting from the user ? Not PII data, just stuff they enter in the app. > Or are you collecting an email address (or hash of an email) and then sending it off to Facebook or other API in an attempt to build a picture ? No. But the details of your questions show, imho, that the concept of identity is non-trivial. I can summarize it very simply: users sign up for an account, identified by an email adress (I don't care if it's real), as a service for the user to have an online backup and an easy way to sync data between devices or move them to Android. The goal is NOT to personally identify a user. But could a user be identified by the email address alone BY SOME ENTITY? Yes, probably. Do I do it? No. Do I share the data or offload it to a third party for data processing? No. Or does my rented self-managed VPS, where the backend runs, count as third party? I don't think so. But of course, I use a transactional email service to send emails to users. What about that? I do have a GDPR-compliant data processing agreement for that. But not sure what Apple wants from me in this case. Thing is: It's not trivial and Apple's guide is insufficient. That's all I'm saying. Edit: And to clarify – if it's complicated, data collecting entities such as Facebook could say "well, we did understand this differently" and simply don't tell the truth about the data they're collecting. I guess that is another point in this whole discussion: What if someone lies about their data collection practices? Any consequences? Are there downsides to lying about it?

drawkbox 6y ago

This is a huge bonus for app/game developers that have always been privacy focused, now it becomes something the business/marketing teams also want on their app. What a great day for good developers and consumers to have this as backup to helping preserve people's privacy and stop the blatant selling and abuse of private data. Thank you Apple!