Submitting App Privacy Details (Nutrition Labels) to the App Store

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Alon Nafta
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Apple App Store Privacy Disclosure Guide

Comprehensive guide for completing Apple's App Store privacy questionnaire when submitting apps integrating Singular SDK, covering data collection, usage declarations, and compliance requirements.

Legal Disclaimer: Guidelines on this page do not constitute legal advice. Consult with your legal and privacy teams for guidance on compliance with Apple's requirements and applicable privacy laws.

Since December 8, 2020, Apple requires app developers to describe app privacy practices, including practices of third-party partners integrated into the app, when submitting new apps or app updates to App Store.

This guide helps you accurately complete privacy disclosures for Singular-integrated apps, ensuring compliance with Apple's transparency requirements.

Target Audience iOS Developers, Product Managers, Legal/Compliance Teams
Prerequisites
  • App Store Connect account with App Manager role or higher
  • Understanding of Singular SDK configuration in your app
  • Knowledge of data types collected by your app

Apple's Privacy Requirements

Background and Context

Apple updated App Store submission process to provide users transparency about app privacy practices before download, requiring developers to disclose data collection and usage through privacy "nutrition labels" visible on app product pages.

Why Apple Requires Privacy Disclosures
#

User Transparency Initiative

Apple's privacy labels enable users to learn about app's privacy practices before downloading, including:

  • Data Types Collected: What information app gathers from users
  • Data Usage Purposes: How collected data is utilized
  • User Linking: Whether data is linked to user's identity
  • Tracking Status: Whether data is used for tracking across apps/websites

Developer Responsibilities

When submitting new app or app update, you must complete App Store Connect questionnaire covering:

  • Your app's privacy practices and data collection
  • Third-party vendor practices (including Singular SDK)
  • All integrated SDKs and analytics tools
  • Data usage and sharing with partners

Compliance Requirement: Privacy information must follow App Store Review Guidelines and all applicable laws. Failure to provide accurate disclosures may result in app rejection or removal.

Questionnaire Scope
#

Comprehensive Disclosure

Questionnaire covers ALL privacy-related data collections and uses, not only those applicable to Singular SDK. Must disclose practices of:

  • Your first-party data collection
  • Singular SDK data collection
  • Other third-party SDKs (analytics, advertising, etc.)
  • Backend services collecting user data

Ongoing Accuracy Requirement

Responses must remain accurate and up-to-date:

  • Update responses when privacy practices change
  • Updates can be made anytime in App Store Connect
  • No app update submission required to change responses
  • Regular audits recommended to ensure continued accuracy

Before You Begin

Preparation Checklist

Essential Preparation Steps:

  • Update Singular SDK: Ensure using latest Singular SDK version for accurate privacy manifest and data collection information
  • Audit Your Configuration: Identify specific data types configured to send to Singular (custom events, user IDs, revenue tracking, etc.)
  • Review All SDKs: Document privacy practices of ALL integrated third-party SDKs, not only Singular
  • Understand Your Implementation: Know which optional Singular features you've implemented (custom user ID, revenue tracking, ad monetization, etc.)
  • Consult Legal Team: Involve legal/privacy team to ensure accurate interpretation and disclosure

Singular SDK Configuration

Configurable Data Collection

Singular SDK is highly configurable - data collection varies based on your implementation choices. Almost all data collected by Singular is optional and subject to developer choice, including providing opt-in or opt-out options for users.

Important Context: Privacy disclosures should reflect YOUR specific Singular SDK implementation, not theoretical maximum data collection. Only disclose data types actually collected in your configuration.

Apple Resources

Official Documentation

Data Types Collected by Singular

Comprehensive reference of data types and Singular SDK's default collection behavior for completing App Store privacy questionnaire.

Data Collection Reference Table

Default Singular SDK Behavior

Following table describes default data collection behavior of latest Singular SDK. Reference this when compiling questionnaire responses, noting that almost all data collected by Singular is optional and subject to developer configuration.

Configuration-Dependent: Table shows default SDK behavior. Your actual data collection may differ based on SDK configuration, optional features implemented, and user consent settings.

Data Type Category Collected by Singular Details and Context
Contact Info
  • Name
  • Email Address
  • Phone Number
  • Physical Address
  • Other User Contact Info
 No

Singular SDK does not collect any contact information.

Questionnaire Answer: Select "No" for all Contact Info subcategories unless your app collects this data independently.

Health & Fitness
  • Health
  • Fitness
 No

Singular SDK does not collect health or fitness data.

Questionnaire Answer: Select "No" unless your app sends health/fitness data to Singular via custom events (which would be unusual).

Financial Info
  • Payment Info
  • Credit Info
  • Other Financial Info
 No

Singular SDK does not collect payment information, credit data, or other financial information.

Revenue Tracking Note: While Singular tracks revenue amounts from in-app purchases, it does NOT collect payment methods, credit card numbers, or other financial information. Revenue amounts are classified under "Purchases" category, not "Financial Info."

Location
  • Precise Location
  • Coarse Location
 No

Singular SDK does not collect GPS coordinates or location data.

IP Address Note: While Singular collects IP address (classified under "Other Data"), this is NOT considered location data by Apple's definitions unless used to derive precise/coarse location.

Sensitive Info
  • Racial or ethnic data
  • Sexual orientation
  • Religious/philosophical beliefs
  • Political opinion
  • Biometric data
 No

Singular SDK does not collect sensitive information categories.

Contacts
  • User's contacts list
 No

Singular SDK does not access or collect user's contacts.

User Content
  • Emails or Text Messages
  • Photos or Videos
  • Audio Data
  • Gameplay Content
  • Customer Support
  • Other User Content
 No

Singular SDK does not collect user-generated content.

Browsing History No

Singular SDK does not track web browsing history.

Search History No

Singular SDK does not collect in-app search queries or search history.

Identifiers
  • User ID
  • Device ID
 Optional

User ID: You may choose to send custom user IDs to Singular using setCustomUserID() method. This is optional and controlled by your implementation.

Device ID: IDFA is collected when accessible (requires App Tracking Transparency authorization). IDFV is always collected.

Questionnaire Answer:

  • Select "Yes" for Device ID (IDFA and IDFV collected)
  • Select "Yes" for User ID only if you've implemented setCustomUserID()
Purchases
  • Purchase History
 Optional

You may decide to use Singular to measure some or all purchase events.

Questionnaire Answer: Select "Yes" only if you've implemented revenue tracking using Singular SDK's revenue methods. This includes:

  • In-app purchase tracking
  • Subscription revenue events
  • Custom revenue events
Usage Data
  • Product Interaction
  • Advertising Data
  • Other Usage Data
 Optional

Product Interaction: Sessions and app launches are automatically collected by Singular. Additionally, you may send custom product interaction events (level completions, feature usage, etc.).

Advertising Data: Singular can measure ad revenue for customers using ad monetization product. If implemented, ad revenue events are sent to Singular.

Other Usage Data: Singular can measure other in-app events as configured by app developer (custom events, user milestones, etc.).

Questionnaire Answer:

  • Always select "Yes" for Product Interaction (sessions/launches tracked automatically)
  • Select "Yes" for Advertising Data only if using Singular's ad monetization tracking
  • Select "Yes" for Other Usage Data if tracking custom events beyond sessions
Diagnostics
  • Crash Data
  • Performance Data
  • Other Diagnostic Data
 No

Singular SDK does not collect crash logs, performance metrics, or other diagnostic data.

Surroundings
  • Environment Scanning
 No

Singular SDK does not collect AR/environment data.

Body
  • Hands
  • Head
 No

Singular SDK does not collect body movement or structure data.

Other Data
  • Other Data Types
 Yes

Singular collects device information and network information:

  • Device Information: OS version, device model (e.g., iPhone 15), device type
  • Network Information: IP address, user agent string
  • Device Identifiers: IDFV (Identifier for Vendor) - always collected

Questionnaire Answer: Select "Yes" for Other Data and describe that device information (OS, device model) and network information (IP address, user agent) are collected, along with IDFV.

Data Usage Purposes

In addition to data types collected, Apple requires describing HOW your app uses collected data. Select applicable usage purposes based on your implementation.

Usage Categories Reference

Singular Data Usage

Usage Purpose Applicability to Singular
Third-Party Advertising

Optional - Select this if you share Singular data with third party to display third-party ads in your app.

Context: Applies if you use Singular attribution data to inform third-party ad networks about user segments or campaign performance for ad targeting purposes.

Developer's Advertising or Marketing

Optional - Select this if you display first or third-party ads in your app and use Singular data for advertising purposes.

Context: Applies if you use Singular attribution data to optimize your own advertising campaigns or retargeting efforts.

Analytics

Yes - Always select this. Singular is primarily used for analytics and attribution measurement.

Required Selection: This is Singular's core purpose - measuring app performance, attribution, and user behavior analytics. Always select "Analytics" for Singular SDK implementation.

Product Personalization

Optional - Select this if you use Singular data for product personalization, such as landing page customization or personalized content.

Example Use Cases:

  • Customizing onboarding based on attribution source
  • Personalizing offers based on campaign parameters
  • Tailoring UI/UX based on user acquisition channel
App Functionality

Yes - Select this. Singular SDK is integrated into app as core functionality for attribution and analytics.

Justification: Singular SDK is part of app's core functionality, enabling attribution tracking, event measurement, and campaign performance analysis - essential components of modern app operations.

Other Purposes

Optional - Select this only if you use Singular data for purposes not covered by other categories.

Specify Clearly: If selecting this option, provide clear description of additional data usage purposes in questionnaire.

Typical Usage Selection

Common Configuration

For most Singular SDK implementations, you should select:

Standard Singular Implementation:

  • Analytics (always)
  • App Functionality (always)
  • Third-Party Advertising (only if applicable to your use case)
  • Developer's Advertising (only if applicable to your use case)
  • Product Personalization (only if applicable to your use case)
  • Other Purposes (rarely needed)

Data Linked to User Identity

Final questionnaire section requires specifying whether collected data types are linked to user's identity or used for tracking purposes.

User Identity Linking

Singular SDK and User Identity

Since Singular collects IDFV (always) and IDFA when accessible (with ATT authorization), collected data IS linked to user's identity through device identifiers.

Required Answer: Select "Yes, data is linked to user's identity" when asked about user identity linking for Singular SDK data collection.

Understanding Apple's Definitions

Data Linked to User

What "Linked to User" Means
#

Apple's Definition

Data is linked to user's identity when it is:

  • Connected to user's account, device, or profile information that can identify them
  • Tied to persistent device identifier (IDFA, IDFV)
  • Associated with user ID that can track user across apps or websites

Singular SDK Context

Singular SDK collects:

  • IDFV (Always): Identifier for Vendor, unique per developer per device
  • IDFA (When Authorized): Identifier for Advertisers, requires App Tracking Transparency permission
  • Custom User ID (Optional): If you implement setCustomUserID()

Since these identifiers enable linking data to specific users/devices, data collected by Singular is linked to user identity.

What "Used for Tracking" Means
#

Apple's Tracking Definition

Data is used for tracking when:

  • Data is linked with third-party data for advertising or advertising measurement
  • Data is shared with data brokers
  • Used to build profile of user across apps and websites owned by different entities

Singular SDK and Tracking

Singular SDK may be used for tracking depending on your implementation:

  • Attribution Measurement: Core Singular function - measuring which ads/campaigns drove app installs
  • Cross-App Analytics: If you share Singular data with advertising networks for targeting

App Tracking Transparency (ATT): If your usage constitutes tracking per Apple's definition, you must request ATT permission before collecting IDFA. Consult legal team to determine if your Singular implementation requires ATT prompt.

Completing the Questionnaire

Step-by-step guidance for submitting privacy information in App Store Connect.

Questionnaire Process

1

Access App Store Connect

  1. Log in to App Store Connect with App Manager role or higher
  2. Navigate to your app
  3. Select version you're submitting or updating
  4. Locate "App Privacy" section in left sidebar
2

Answer Data Collection Questions

For each data type category, indicate whether you or your third-party partners (including Singular) collect that data type.

Reference Tables: Use "Data Types Collected by Singular" table above to determine correct answers for Singular SDK contribution.

3

Specify Data Usage Purposes

For each data type you collect, select all applicable usage purposes from provided options.

Reference Tables: Use "Data Usage Purposes" table above to determine correct usage selections for Singular data.

4

Indicate User Identity Linking

For each data type, specify whether data is linked to user's identity.

Singular SDK Answer: Select "Yes" for user identity linking since Singular collects IDFV and IDFA (when authorized).

5

Specify Tracking Usage

Indicate whether data is used for tracking purposes as defined by Apple.

Consult Legal Team: Determination of whether your Singular usage constitutes "tracking" requires legal interpretation based on your specific implementation and data sharing practices.

6

Review and Submit

  1. Review all responses for accuracy
  2. Verify responses reflect current implementation
  3. Save responses in App Store Connect
  4. Submit app for review

Ongoing Maintenance: Update responses whenever privacy practices change, even without submitting new app version.

Additional Considerations

Important factors to consider when completing App Store privacy disclosures for Singular-integrated apps.

Multiple Third-Party SDKs

Comprehensive Disclosure

If your app integrates multiple third-party SDKs beyond Singular (analytics, advertising, crash reporting, etc.), you must disclose data practices for ALL integrated SDKs.

Complete SDK Audit Required: Review privacy practices of all integrated third-party SDKs and combine disclosures. Your responses should reflect cumulative data collection across all SDKs, not just Singular.

First-Party Data Collection

Your Own Data Practices

Beyond third-party SDKs, disclose data collection by your own backend services, analytics systems, and app functionality.

  • User account information
  • Custom analytics implementations
  • Backend API data collection
  • Any other first-party data gathering

Updating Privacy Practices

Maintaining Accuracy

Privacy disclosures must remain accurate as your app evolves.

Update Triggers: Revise privacy responses when:

  • Adding new third-party SDK to app
  • Implementing new Singular SDK features (custom user ID, ad monetization, etc.)
  • Changing data collection or usage practices
  • Removing data collection capabilities

Updates can be made anytime in App Store Connect without requiring app submission.

Privacy Policy Requirement

Comprehensive Privacy Documentation

In addition to App Store privacy labels, maintain comprehensive privacy policy accessible to users.

Privacy Policy Best Practices:

  • Clearly describe all data collection practices
  • List all third-party SDKs and their purposes
  • Explain how data is used and shared
  • Provide contact information for privacy inquiries
  • Keep policy updated with current practices

Quick Reference Summary

At-a-glance summary of Singular SDK privacy disclosures for App Store submission.

Data Types - Quick Checklist

Data Type Select in Questionnaire
Contact Info ❌ No
Health & Fitness ❌ No
Financial Info ❌ No
Location ❌ No
Sensitive Info ❌ No
Contacts ❌ No
User Content ❌ No
Browsing/Search History ❌ No
Identifiers ✅ Yes (Device ID always; User ID if implemented)
Purchases ⚠️ If Applicable (only if revenue tracking implemented)
Usage Data ✅ Yes (Product Interaction always; others if applicable)
Diagnostics ❌ No
Other Data ✅ Yes (device info, network info, IDFV)

Usage Purposes - Quick Checklist

Usage Purpose Select in Questionnaire
Analytics ✅ Always
App Functionality ✅ Always
Third-Party Advertising ⚠️ If Applicable
Developer's Advertising ⚠️ If Applicable
Product Personalization ⚠️ If Applicable
Other Purposes ⚠️ Rarely

User Identity - Quick Answer

Data Linked to User:✅ YES

Always select "Yes" - Singular collects IDFV (always) and IDFA (when authorized), which link data to user identity.

Additional Resources

Complete documentation for Apple privacy requirements and Singular SDK implementation.

Apple Documentation

Singular Documentation

Support

Getting Help

For questions about Singular SDK privacy practices or assistance with privacy disclosures, contact Singular Support or your Customer Success Manager.

Final Reminder: This guide provides technical information about Singular SDK data collection but does not constitute legal advice. Consult your legal and privacy teams for guidance specific to your app and jurisdiction.