Apple Eases Push Notification And Other Privacy Restrictions

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Sheppard Mullin Richter & Hampton
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Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
Apple recently revised its review guidelines to allow push notifications that include "advertising, promotions, or direct marketing."
United States Privacy
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Apple recently revised its review guidelines to allow push notifications that include "advertising, promotions, or direct marketing." This changes a prior -and longstanding- prohibition on push notices that contain such content. Customers must affirmatively opt in to get promotional push notices, though ("through consent language displayed in your app's UI"). They must also be able to opt out through an in-app mechanism. Although promotional push notices were previously prohibited, many apps sent them. These modifications may be a step by Apple to acknowledge this use and put requirements in place around it.

The review guidelines also include other changes with an impact on information collection, use and sharing. These include for apps that provide services in "highly-regulated fields." Such apps must be submitted by the regulated entity (i.e., the one providing the regulated services) rather than the app developer. For example, if a bank hires an app developer to create an app for the bank, the bank should submit the app to the Apple App Store, not the developer it hired to make the app.

Another change are the provisions for apps that provide users with Mobile Device Management (MDM) tools. Previously those apps were prohibited from "disclosing to third parties" any data. Now those apps can share information but only if it is about the "performance of the developer's MDM app" and does not include user data ("data about the user, the user's device, or other apps used on that device").

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Apple Eases Push Notification And Other Privacy Restrictions

United States Privacy
Contributor
Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
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