ARTICLE · 10 DECEMBER 2020

Apple Implements Privacy "Nutrition Label" For Apps

Husch Blackwell LLP

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App developers will need to navigate a new privacy questionnaire designed to provide users with an easy to understand presentation of an App's privacy practices.

United StatesPrivacy

David M. Stauss

Malia K. Rogers

Shelby E. Dolen

Keypoint: App developers will need to navigate a new privacy questionnaire designed to provide users with an easy to understand presentation of an App's privacy practices.

As of December 8, 2020, Apple now requires all newly submitted applications (Apps) on its App Store, or updates to Apps, to include a privacy nutrition label describing the App's privacy practices. This is in addition to Apple's existing requirement that all Apps provide a link to a publicly accessible full privacy policy.

The privacy nutrition label is automatically generated based on a developer's answers to a series of questions about the types of data the App collects (both first party and third-party collection), how each data type is used, whether the data is linked to the user, and whether the data is used for tracking purposes.

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