Privacy & Information Security Law Blog

On April 20, 2021, Apple announced that its AppTracking Transparency Framework (“ATT Framework”) will go into effect starting April 26, 2021, along with the upcoming public release of iOS 14.5, iPadOS 14.5 and tvOS 14.5.

The announcement specifies that when submitting an app to Apple for review, app developers must (1) declare in the app’s App Store Privacy Information section any form of “tracking” the app will engage in (i.e., by Identifier for Advertisers or any other identifier, e.g., name or e-mail address) and (2) include a purpose string in the opt-in to tracking prompt to explain why the app would like to track the user.

Apple reminded app developers that fingerprinting devices (i.e., collecting device and usage data with the intent of deriving a unique representation of a user) is in violation of the Apple Developer Program License Agreement. This follows news reports that Apple has already begun rejecting apps that use fingerprinting technology.