October 20, 2021

Volume XI, Number 293

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October 19, 2021

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October 18, 2021

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Apple’s App Tracking Transparency Now In Effect

As of this week, Apple’s requirements for apps to follow its AppTrackingTransparency are now in effect. These requirements went hand-in-hand with the iOS 14.5 launch, and impacts how an app can track users and access their advertising device IDs. In particular, consumer consent is now required if the app collects consumer information and shares it with others “for purposes of tracking across apps and web sites.” Apple has provided developers with specific implementation steps, which will be reviewed when apps are submitted to Apple for approval. As part of the submission, companies need to explain why they want to track users, as required under Apple’s guidelines.

As implemented, the process will mean that the app user would receive a pop-up telling them that the app wants to access the user’s unique device ID for advertisers. The pop-up asks the user if they want to be tracked and why the app they are using wants them to opt-in. The “why” is something that the app developer will need to draft and have contained within the pop-up.

Putting It Into Practice: As we discussed with the implementation of the privacy “nutrition labels,” companies who are engaging in covered tracking activities should take care that descriptions submitted to Apple are accurate.

Copyright © 2021, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume XI, Number 119
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About this Author

Liisa Thomas, Sheppard Mullin Law Firm, Chicago, Cybersecurity Law Attorney
Partner

Liisa Thomas, a partner based in the firm’s Chicago and London offices, is Co-Chair of the Privacy and Cybersecurity Practice. Her clients rely on her ability to create clarity in a sea of confusing legal requirements and describe her as “extremely responsive, while providing thoughtful legal analysis combined with real world practical advice.” Liisa is the author of the definitive treatise on data breach, Thomas on Data Breach: A Practical Guide to Handling Worldwide Data Breach Notification, which has been described as “a no-nonsense roadmap for in-house and...

312-499-6335
Bridget Russel, Business Trial Legal Specialist, Sheppard Mullin
Associate

 

Bridget Russell is an associate in the Business Trial Practice Group in the firm's Century City office. 

310-228-2273
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