Third-party SDK data collection declared in privacy manifests and store forms
Why it matters
Apple and Google both require that third-party SDK data collection appear in your app's privacy declarations — even data your own code never touches directly. SDKs like AppsFlyer, AdMob, and Meta Audience Network collect device identifiers, IP addresses, and app-usage signals that must be declared under GDPR Art.28 (processor relationships), GDPR Art.13 (disclosure), CCPA §1798.140(t) (sale/sharing disclosure), and COPPA §312.5 for children's data. On iOS, initialising tracking SDKs before ATT authorisation is obtained compounds the violation — the SDK reads IDFA without user consent, which is grounds for immediate rejection.
Severity rationale
High because undeclared SDK data collection creates policy violations on both platforms simultaneously and may constitute a GDPR Art.28 breach for undisclosed data processor relationships.
Remediation
For each ad or analytics SDK, find its privacy disclosure documentation and map its data types to App Store nutrition label categories and Google Data Safety types. For iOS tracking SDKs, initialise them only after ATT authorisation:
ATTrackingManager.requestTrackingAuthorization { status in
if status == .authorized {
// Initialize AppsFlyer, Meta, etc.
} else {
// Initialize with limited data mode
}
}
For GDPR contexts, integrate the Google UMP (User Messaging Platform) SDK before initialising AdMob. Run find ios/ -name PrivacyInfo.xcprivacy to confirm all SDK pods include their own manifests.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the App Store Privacy & Data Compliance Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- gdpr · Art. 28 — Processor obligations and data processing agreements
- gdpr · Art. 13 — Information to be provided where personal data are collected from the data subject
- ccpa · §1798.140(t) — Definition of 'sale' of personal information
- coppa · §312.5 — Parental consent — operators must obtain verifiable parental consent before any collection or use
Taxons
History
- 2026-04-18·v1.0.0·Initial import from app-store-privacy-data·automated