iOS 14 & App Tracking Transparency

  • Updated

 

Disclaimer: This is not legal advice. Please consult your legal team.

Do we need both App Tracking Transparency and Osano SDK?

  • Do you use app data for personalization/analytics?
    • If yes, you must use both App Tracking Transparency (ATT) framework and Osano SDKs. ATT provides compliance with Apple requirements, while Osano SDKs provides compliance with global privacy laws.
    • If no, you may use only the ATT framework by turning off all marketing if a user rejects ATT
  • Do you want to differentiate between marketing data for tracking and non-tracking marketing data (1st party marketing, non-targeted 3rd party marketing?
    • If yes, you must use both App Tracking Transparency (ATT) framework and Osano SDKs
    • If no, you may use only the ATT framework by turning off all marketing if a user rejects ATT

Information to gather:

  • Do you do any 1st party marketing?
    • Data used only for 1st party marketing, or only for 1st party marketing analytics is not defined as “tracking” in the App Tracking Transparency framework
    • If the data is ever used downstream for 3rd party targeted marketing, this is tracking data that falls under ATT
  • Do you use app data for any non-targeted 3rd party marketing (eg manually buying billboard placement in zip codes where you have a lot of app usage)
    • Do any of the 3rd party vendors that provide non-targeting marketing re-use the data for their own targeted ads, or share/sell the data with a data broker?
    • If you are not sure, treat them as a targeted 3rd party marketing vendor
    • Data used only for non-targeted 3rd party marketing is not defined as “tracking” in the App Tracking Transparency framework

Osano recommendation:

  • Launch ATT when the user opens the app for the first time
  • Show Osano cookie banner on the splash screen
  • In settings, provide user-links to settings to change ATT as well as Osano’s Storage Preferences
Standard Implementation
 

Osano Cookie Categories

  Marketing On Marketing Off
ATT Authorized
  • User consents to all marketing.
  • Use marketing data as usual.
  • User has opted out of all marketing.
  • Block data & SDKs used for marketing & tracking.
ATT Denied
  • Block data & SDKs for 3rd party targeted ads.
  • Allow data used only for 1st party marketing.
  • Allow data used only for 3rd party untargeted ads.
  • Block data & SDKs used for both 3rd party untargeted and targeted ads.
  • User has opted out of all marketing.
  • Block data & SDKs used for marketing and tracking.