Apple recently announced that app developers must check a series of yes/no boxes that will generate a “nutrition label”-style summary of the app’s privacy practices. This new summary, formally called “App Privacy,” will be shown to users within the App Store before they install an app. This is the latest move in Apple’s ongoing effort to make privacy practices more transparent, and it requires app developers to take action now to ensure they can continue to update their apps after December 8, 2020. If developers take no action, their apps will essentially be frozen as they exist on that date.
Separately, Apple has delayed plans to launch its App Tracking Transparency (ATT) framework until early 2021. Under the ATT framework, apps will be required to obtain users’ opt-in consent in order to track them across different online services or offline properties for targeted advertising or ad measurement purposes, or to access their device’s advertising identifier.
For more information or advice concerning Apple’s upcoming requirements, or for assistance with creating your app’s disclosures, please contact Tracy Shapiro, Eddie Holman, Stephen Schultze, or another member of the firm’s privacy and cybersecurity practice.