Data types that meet all of the following criteria are optional to disclose:
- The data is not used for tracking purposes, meaning the data is not linked with Third-Party Data for advertising or advertising measurement purposes, or shared with a data broker. For details, see the Tracking section.
- The data is not used for Third-Party Advertising, your Advertising or Marketing purposes, or for Other Purposes, as those terms are defined in the Tracking section.
- Collection of the data occurs only in infrequent cases that are not part of your app's primary functionality, and which are optional for the user.
- The data is provided by the user in your app's interface, it is clear to the user what data is collected, the user's name or account name is prominently displayed in the submission form alongside the other data elements being submitted, and the user affirmatively chooses to provide the data for collection each time.
Data types must meet all criteria in order to be considered optional for disclosure. If a data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in App Store Connect.
Examples of data that may not need to be disclosed include data collected in optional feedback forms or customer service requests that are unrelated to the primary purpose of the app and meet the other criteria above.
For the purpose of clarity, data collected on an ongoing basis after an initial request for permission must be disclosed.
Regulated Financial Services Disclosure
Data types that are collected by an app that facilitates regulated financial services and where the data collected meets all of the following criteria are optional to disclose:
- Collection of the regulated data is in accordance with a legally required privacy notice under applicable financial services or data protection laws or regulations (e.g., GDPR or GLBA).
- Collection by the app of that data occurs only in cases that are not part of your app's primary functionality, and which are optional for the user.
- Such notice provides that data is not shared with unaffiliated third parties to market other products and services.
- Such data is not linked with third-party data for advertising purposes or shared with a data broker except for purposes of fraud detection or prevention or security purposes, or with a consumer reporting agency for credit reporting.
Data types must meet all criteria in order to be considered optional for disclosure. If a data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in your privacy section.
Health Research Disclosure
Data types that are collected as part of a health research study and where the data collected meets all of the following criteria are optional to disclose:
- The data is collected by an entity whose collection of the data is subject to an informed consent form (ICF) as part of a health research study that has been reviewed and approved by an institutional review board or ethics review board.
- All such data collection must follow the relevant App Store Guidelines and the data may not be used for tracking purposes.
If the data type collected by your app meets some, but not all, of the above criteria, it must be disclosed in your privacy section.