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September 14, 2019

Third-party analytics, ads in kids apps and 'Sign in with Apple'

Apple has updated the App Store Review Guidelines with changes to rules regarding ads, data collection and privacy in kids apps, and new rules about Sign in with Apple.

Specifically, it is now, in limited cases, permissible to show ads and include third-party analytics in kids apps and creators of kids apps must now comply with all applicable children’s privacy statutes. Newly submitted kids apps must follow these guidelines immediately, while existing apps will have until March 3, 2020 to be fully compliant. Regarding Sign in with Apple, the guidelines now state that any apps that use a third-party login service, e.g. Facebook or Google, must also offer Sign in with Apple.

The complete changes can be seen below:

1.3 Kids Category

You must comply with applicable privacy laws around the world relating to the collection of data from children online. Be sure to review the Privacy section of these guidelines for more information. In addition, Kids Category apps may not send personally identifiable information or device information to third parties. Apps in the Kids Category mayshould not include third-party analytics or third-party advertising or. This provides a safer experience for kids. In limited cases, third-party analytics may be permitted provided that the services do not collect or transmit the IDFA or any identifiable information about children (such as name, date of birth, email address), their location, or their devices. You shouldThis includes any device, network, or other information that could be used directly or combined with other information to identify users and their devices. Third-party contextual advertising may also pay particular attention to privacy laws around the world relating to the collection of data from children online. Be sure tobe permitted in limited cases provided that the services have publicly documented practices and policies for Kids Category apps that include human review the Privacy section of these guidelines for more informationof ad creatives for age appropriateness.

4.2 Minimum Functionality

Your app should include features, content, and UI that elevate it beyond a repackaged website. If your app is not particularly useful, unique, or “app-like,” it doesn’t belong on the App Store. If your App doesn’t provide some sort of lasting entertainment value, it may not be accepted. Apps that are simply a song or movie should be submitted to the iTunes Store. If your App doesn’t provide some sort of lasting entertainment value, it may not be accepted. Apps that are simply a song or moviebook or game guide should be submitted to the iTunes Store. Apps that are simply a book or game guide should be submitted to the Apple Books Store.

4.8 Sign in with Apple

Apps that exclusively use a third-party or social login service (such as Facebook Login, Google Sign-In, Sign in with Twitter, Sign In with LinkedIn, Login with Amazon, or WeChat Login) to set up or authenticate the user’s primary account with the app must also offer Sign in with Apple as an equivalent option. A user’s primary account is the account they establish with your app for the purposes of identifying themselves, signing in, and accessing your features and associated services.

Sign in with Apple is not required if:

  • Your app exclusively uses your company’s own account setup and sign-in systems.
  • Your app is an education, enterprise, or business app that requires the user to sign in with an existing education or enterprise account.
  • Your app uses a government or industry-backed citizen identification system or electronic ID to authenticate users.
  • Your app is a client for a specific third-party service and users are required to sign in to their mail, social media, or other third-party account directly to access their content.
5.1 Privacy
  • 5.1.1 Data Collection and Storage
    • (i) Privacy Policies:
      • Confirm that any third party with whom an app shares user data (in compliance with these Guidelines) — such as analytics tools, advertising networks and third-party with whom an app shares user data (in compliance with these Guidelines) — such as analytics tools, advertising networks and third-party SDKs, as well as any parent, subsidiary or other related entities that will have access to user data — will provide the same or equal protection of user data as stated in the app’s privacy policy and required by these Guidelines.
5.1.4 Kids

For many reasons, it is critical to use care when dealing with personal data from kids, and we encourage you to carefully review all the requirements for complying with laws like the Children’s Online Privacy Protection Act (“COPPA”), the European Union’s General Data Protection Regulation (“GDPR”), and any international or local equivalentsother applicable regulations or laws.

Apps may ask for birthdate and parental contact information only for the purpose of complying with these statutes, but must include some useful functionality or entertainment value regardless of a person’s age.

Apps intended primarily for kids mayshould not include third-party analytics or third-party advertising or. This provides a safer experience for kids. In limited cases, third-party analytics and third-party advertising may be permitted provided that the services adhere to the same terms set forth in Guideline 1.3.

Moreover, apps in the Kids Category or those that collect, transmit, or have the capability to share personal information (e.g. name, address, email, location, photos, videos, drawings, the ability to chat, other personal data, or persistent identifiers used in combination with any of the above) from a minor must include a privacy policy and must comply with all applicable children’s privacy statutes. For the sake of clarity, the parental gate requirement for the Kid’s Category is generally not the same as securing parental consent to collect personal data under these privacy statutes. Collecting and transmitting data to third parties from apps in

As a reminder, Guideline 2.3.8 requires that use of terms like “For Kids” and “For Children” in app metadata is reserved for the Kids category isCategory. Apps not allowedin the Kids Category cannot include any terms in app name, subtitle, icon, screenshots or description that imply the main audience for the app is children.