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> "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 use

by 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.

by WA 6y ago

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.