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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 ad

by 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?
  - kayodelycaon 6y ago
    > 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. Then you are collecting emails to identify users. It doesn't matter if the email is fake or not. In other words, you are explicitly connecting a specific device to a specific account on your backend via that email.
    - WA 6y ago
      > Then you are collecting emails to identify users. I use it to authenticate users. I don't use it to "identify" users. I give zero fucks about the identity of users. > In other words, you are explicitly connecting a specific device to a specific account on your backend via that email. No, because I don't collect any more data about the device, I don't link anything. Users use the app. They can use multiple devices. I know nothing about the devices and don't care. Users themselves link their account to their device (on their device), but I don't get any information about this. I posted this in another comment, but it makes sense here too: I find it odd that Apple didn't choose words that are already clear with respect to privacy laws such as GDPR. The GDPR doesn't talk about identity. It defines personal data or personally identifiable information (PII). If you collect this data, you're subject to GDPR compliance. Apple has a weird phrasing of this. You apparently can collect an email address, but not link it to an identity, which is different from collecting an email address and linking it to an identity. It's unclear to me what they mean by this and what "identity" is supposed to mean.
sprite 6y ago
If you store the email in a database and associate it with any other data (password, settings, profile information, etc) I would think it qualifies as an account.
jsmith45 6y ago
My understanding is as follows: If you are able to answer "Is email address[or other collected data] ________ associated the user whose database row has primary key _______?" then that is considered being tied to the account, and thus tied to the identity. If you are using email address as a user id, then it is very much tied to the user's account on your service. For tying to device, this could be based on reading the devices serial number somehow, using the Id for Advertisers, or just generating a unique random identifier at install time, and use that to distinguish records. So if you can answer "What is the race of the user with random install id _______" then for apples purposes you have tied race to device and thus to identity. Basically unless anonymized nearly all data that you collect will be considered by Apple to be identity tied, unless you don't have user accounts, and don't include some form of device identifier with the data. It is literally impossible to have any form of user account without at least having one thing "tied to user identity". Even if you use "sign in with apple" and do not collect the anonymized email address they provide, you will have at least "user id" (the "sub" token from apple) and probably also "Other User Content". For example, an otherwise offline game might collect the time taken to beat each level without any device identifying information to allow the developer to understand if levels were harder than expected. In that case you have collection of "Product Interaction" data that is not identity tied.
megablast 6y ago
Your app is focused on privacy, yet you can’t answer these simple questions??? What?
- WA 6y ago
  My app respects the users privacy. There is no tracking, no analytics, no data sharing with third parties. It’s not a privacy product, if this was unclear. And yes, part of answering these questions is an honest assessment whether I and Apple agree on what it means to respect a user’s privacy.
nodamage 6y ago
It sounds like you're being intentionally obtuse here. The guidelines say: Note: “Personal Information” and “Personal Data”, as defined under relevant privacy laws, are considered linked to the user. This implies that email addresses are, by definition, considered linked to the user's identity. The fact that someone could submit a fake email address is irrelevant, just as if you collected mailing addresses and someone put in "123 Fake Street", or if you collected phone numbers and someone put in "123-456-7890".
- WA 6y ago
  I re-read this section. The "Note" makes sense, but the whole description on Apple's website is weird, especially if you consider that Apple allows you to collect an email address that apparently isn't linked to the user. How is this possible? Apple does have categories of data, such as contact info. If contact info is considered "linked to the user", why offer this granularity in the first place? Read this section, fill in "email address" where it talks about data in general and try to make sense of it: https://developer.apple.com/app-store/app-privacy-details/#linked-data https://developer.apple.com/app-store/app-privacy-details/#l... Anyways, I wasn't intentionally obtuse here, because I mostly think in terms of GDPR compliance, but you're right. I apparently thought of this in a more complicated way than necessary.

by WA 6y ago

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?
- kayodelycaon 6y ago
  > 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. Then you are collecting emails to identify users. It doesn't matter if the email is fake or not. In other words, you are explicitly connecting a specific device to a specific account on your backend via that email.
  - WA 6y ago
    > Then you are collecting emails to identify users. I use it to authenticate users. I don't use it to "identify" users. I give zero fucks about the identity of users. > In other words, you are explicitly connecting a specific device to a specific account on your backend via that email. No, because I don't collect any more data about the device, I don't link anything. Users use the app. They can use multiple devices. I know nothing about the devices and don't care. Users themselves link their account to their device (on their device), but I don't get any information about this. I posted this in another comment, but it makes sense here too: I find it odd that Apple didn't choose words that are already clear with respect to privacy laws such as GDPR. The GDPR doesn't talk about identity. It defines personal data or personally identifiable information (PII). If you collect this data, you're subject to GDPR compliance. Apple has a weird phrasing of this. You apparently can collect an email address, but not link it to an identity, which is different from collecting an email address and linking it to an identity. It's unclear to me what they mean by this and what "identity" is supposed to mean.

sprite 6y ago

If you store the email in a database and associate it with any other data (password, settings, profile information, etc) I would think it qualifies as an account.

jsmith45 6y ago

My understanding is as follows: If you are able to answer "Is email address[or other collected data] ________ associated the user whose database row has primary key _______?" then that is considered being tied to the account, and thus tied to the identity. If you are using email address as a user id, then it is very much tied to the user's account on your service. For tying to device, this could be based on reading the devices serial number somehow, using the Id for Advertisers, or just generating a unique random identifier at install time, and use that to distinguish records. So if you can answer "What is the race of the user with random install id _______" then for apples purposes you have tied race to device and thus to identity. Basically unless anonymized nearly all data that you collect will be considered by Apple to be identity tied, unless you don't have user accounts, and don't include some form of device identifier with the data. It is literally impossible to have any form of user account without at least having one thing "tied to user identity". Even if you use "sign in with apple" and do not collect the anonymized email address they provide, you will have at least "user id" (the "sub" token from apple) and probably also "Other User Content". For example, an otherwise offline game might collect the time taken to beat each level without any device identifying information to allow the developer to understand if levels were harder than expected. In that case you have collection of "Product Interaction" data that is not identity tied.

megablast 6y ago

Your app is focused on privacy, yet you can’t answer these simple questions??? What?

WA 6y ago
My app respects the users privacy. There is no tracking, no analytics, no data sharing with third parties. It’s not a privacy product, if this was unclear. And yes, part of answering these questions is an honest assessment whether I and Apple agree on what it means to respect a user’s privacy.

nodamage 6y ago

It sounds like you're being intentionally obtuse here. The guidelines say: Note: “Personal Information” and “Personal Data”, as defined under relevant privacy laws, are considered linked to the user. This implies that email addresses are, by definition, considered linked to the user's identity. The fact that someone could submit a fake email address is irrelevant, just as if you collected mailing addresses and someone put in "123 Fake Street", or if you collected phone numbers and someone put in "123-456-7890".

WA 6y ago
I re-read this section. The "Note" makes sense, but the whole description on Apple's website is weird, especially if you consider that Apple allows you to collect an email address that apparently isn't linked to the user. How is this possible? Apple does have categories of data, such as contact info. If contact info is considered "linked to the user", why offer this granularity in the first place? Read this section, fill in "email address" where it talks about data in general and try to make sense of it: https://developer.apple.com/app-store/app-privacy-details/#linked-data https://developer.apple.com/app-store/app-privacy-details/#l... Anyways, I wasn't intentionally obtuse here, because I mostly think in terms of GDPR compliance, but you're right. I apparently thought of this in a more complicated way than necessary.