iOS 14.5 and the MMP’s responsibility to Do No Harm
Our digital advertising ecosystem is going through unprecedented changes. It’s at times like these, when marketers need to be able to have faith and absolute trust in their partners, particularly their MMP. Marketers wear enough hats as it is and not only look to, but also rely on, their partners to be the experts in their respective marketing functions and help steer them in the right direction to help their business succeed. However, what happens when a partner puts your business in jeopardy?
A hill to die on with probabilistic attribution
While Apple for a time maintained a moving target with respect to what would or would not be allowed for certain advertising measurement practices, the general sentiment is that they have now brought clarity to the discussion. The use of fingerprinting and/or probabilistic forms of attribution in the absence of a user opting in to tracking via the AppTrackingTransparency (ATT) framework was believed to be viable until Apple updated the FAQ section of their User Privacy & Data Use Policy.
Q: “Can I fingerprint or use signals from the device to try to identify the device or a user?”
A: “No. Per the Developer Program License Agreement, you may not derive data from a device for the purpose of uniquely identifying it. Examples of user or device data include, but are not limited to: properties of a user’s web browser and its configuration, the user’s device and its configuration, the user’s location, or the user’s network connection. Apps that are found to be engaging in this practice, or that reference SDKs (including but not limited to Ad Networks, Attribution services and Analytics) that are, may be rejected from the App Store.”
Excerpt from Apple’s privacy FAQ
Apple has drawn a line in the sand, removing ambiguity and bringing specificity where it was previously lacking. While it can certainly be argued that the writing is on the wall, some partners in the measurement space are digging in and holding their ground—making the case for a continuation of attribution practices that by all accounts rely on the very methods Apple has prohibited. This puts you and your app business in jeopardy.
But wait, probabilistic attribution is not fingerprinting. So what’s the problem?
While this argument is being used, it’s misleading. Apple has been clear in their guidance that “tracking” in the context of the ATT framework refers to linking data collected from your app with third-party data. This means that even if a conversion attribution is made via probabilistic algorithms, the attribution is specifically performed by linking data collected from your app with data from another company. As such, regardless of the defining language behind fingerprinting or probabilistic attribution, Apple’s position is clear that any app developer that links impressions or clicks to the actions that happen in an advertiser’s app is not in compliance.
Stepping into the responsibility void left by your MMP
What are you as the marketer to do when your MMP appears to be breaking rank with Apple’s guidelines? What Apple has also made clear is that you (the marketer/app developer) are responsible for the data collection and tracking practices of any third-party software development kit (SDK) in your app—no exceptions.
Q: “I have integrated an SDK from another company. Am I responsible for the data collection and tracking of users of my app by that company?”
A: “Yes. Developers are responsible for all code included in their apps. If you are unsure about the data collection and tracking practices of code used in your app that you didn’t write, we suggest contacting the developer of the SDK.”
Excerpt from Apple’s privacy FAQ
And from the prior FAQ answer, Apple has clarified that your app can be rejected/removed from the App Store if an integrated SDK is engaging in restricted measurement practices.
“Apps that are found to be engaging in this practice, or that reference SDKs (including but not limited to Ad Networks, Attribution services and Analytics) that are, may be rejected from the App Store.”
Excerpt from Apple’s privacy FAQ
This means you’re the captain of your own ship and the future of your app’s success in the App Store is in your hands alone. Here’s what you can do now to make sure your ship doesn’t sink with you on it.
- Ask for a transparent accounting of how your MMP will handle attribution post-ATT enforcement and how they’re respecting Apple’s policies in both spirit and letter. If something seems off, it probably is.
- Contact us for a consultation on the ATT framework and your privacy-compliant attribution strategy. Kochava experts are here to help you navigate these changes and understand your responsibilities, whether you choose Kochava or another MMP that’s measuring responsibly.
