App Store Compliance
App Tracking Transparency and beyond
It’s getting harder and harder for apps to earn revenue through advertising and data monetization. Apple’s recent App Tracking Transparency (ATT) and App Privacy guidelines introduce a new way for consumers to control how their data is collected and used. This holds great promise for user privacy, however, these updates also pose a dilemma and uncertainty for mobile apps that have come to rely on advertising revenue.
Tutela offers app publishers a way to earn additional revenue without tracking, without advertisements, and without requiring AppTrackingTransparency opt-in.
Better yet, the data we collect helps telecoms companies around the world build better networks in the areas that need it most. In a time when equal access to reliable internet is more important than ever, we take great pride in using our data for public good.
As outlined in our privacy charter, our company depends on data and its proper and lawful treatment in compliance with privacy legislation. We invest heavily in compliance, and take proactive steps to go above and beyond basic privacy and data protection requirements. This is why thousands of apps trust Tutela as their partner and as a source of additional revenue.
The following information will focus on Tutela’s compliance with Apple’s guidelines, and the measures we’ve taken to ensure our data is not linked to user identity, and not used for tracking.
Effective December 8, 2020, Apple updated the information required to submit new apps and app updates to the App Store. The new submission process introduces a new App Privacy section within App Store Connect. This section must also disclose data used by third-party partners integrated into an app. If you have not already, please familiarize yourself with these guidelines here.
To comply with Apple policies, developers that work with Tutela need to acknowledge and detail the Data Use around each type of data Tutela collects. Please note that the following breakdown only applies to your use of the Tutela SDK. To ensure compliance with this App Store policy you must also include information covering your own uses of data and those of any other partners too.
Step 1 of 5: Get Started
First, navigate to the App Privacy section within App Store Connect and click Get Started.
Next, select “Yes, we collect data from this app”
Step 2 of 5: Data Collected
Scroll down and check the boxes for each type of data as they apply to Tutela, your app, and your other partners.
Only the following types of data are collected for Tutela’s use cases:
Precise Location + Coarse Location - Tutela collects location in order to plot network performance on a map to convey coverage.
Product Interaction - The state of an app during a network test (e.g. “in use”) may be collected for data validation purposes. Tutela never sees or records any content viewed by users.
Performance Data + Other Diagnostic Data - We collect Performance Data such as energy use, and Other Diagnostic Data, to help identify whether various factors contribute to specific network issues (like the network version of a crash report).
Other Data - We measure mobile network performance.
Step 3 of 5: Data Use
After selecting the appropriate Types of Data, you’ll need to click to “Set up” each data type, which will prompt you to describe how each type of data is being used.
Tutela only uses the data we collect (as outlined in Step 2 above) for “Analytics”, “App Functionality”, and “Other Purposes”:
❌ Third-Party Advertising
❌ Developer’s Advertising or Marketing
✔️ Analytics - We collect network analytics in order to improve network performance for the app and its users on Tutela customer networks
❌ Product Personalization
✔️ App Functionality - Users may experience better network performance and app performance as a result of sending network analytics data to Tutela
✔️ Other Purposes - We measure mobile network performance
Step 4 of 5: Data linked to the user
Next, you’ll need to indicate whether each type of data is linked to users’ identity.
As outlined below, Tutela does not link data to the user. In relation to Tutela’s collection and use of data, you can select ❌ “No” for each data type, to indicate that data is not linked to the user’s identity.
Per Apple’s guidelines, to ensure that data is not linked to user identity:
Step 5 of 5: Tracking
Finally, you’ll need to indicate whether each type of data is used for “Tracking”.
As outlined below, Tutela does not use data for tracking. In relation to Tutela’s collection and use of data, you can select ❌ “No” for each data type, to indicate that data is not used to track users.
Starting with iOS 14.5, apps are required to ask users for their permission to track them across apps and websites owned by other companies. Apple’s App Tracking Transparency framework impacts how developers can collect and share end user data.
Tutela does not use data for tracking. Per Apple’s guidelines, we do not use data for targeted advertising or advertising measurement purposes, and we take the following measures to ensure data is not sent off the device in a way that can identify the end-user or device:
As a result, we are compliant with Apple’s App Tracking Transparency framework guidelines, and our SDK can be initialized independent of the ATT opt-in in iOS 14.5 and beyond.
Disclaimer: There remains some industry uncertainty surrounding Apple’s interpretation of the App Tracking Transparency and App Privacy policies.
We have received our own advice, and this page is our interpretation of Apple’s guidelines. The information on this page is not legal advice, nor is it a replacement or substitute for your own review. We will continue to empower our app partners to make the final determination of when the Tutela SDK is initialized. We support them either way, and can assume no liability for implementation decisions taken by our partners.
If you have any questions regarding App Store compliance, please forward this page to your legal team, or contact us at partners@tutela.com.
