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Privacy

SpendOwl is designed with privacy in mind. No IDFA is required, and a privacy manifest is included for App Store compliance.

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Privacy Manifest

SpendOwl includes an Apple Privacy Manifest (PrivacyInfo.xcprivacy) that declares:
  • Data collected and its purposes
  • Tracking domains used
  • Required reasons API usage
The manifest is automatically bundled with the SDK.

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Data Collection

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What SpendOwl Collects

Data TypePurposeLinked to Identity
Device IDAnalyticsNo (anonymous)
Purchase HistoryROAS calculationOptional (if user ID set)
Attribution TokenCampaign trackingNo

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What SpendOwl Does NOT Collect

  • IDFA (Advertising Identifier)
  • Location data
  • Contacts
  • Photos
  • Health data
  • Emails or messages

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No IDFA Required

SpendOwl uses Apple’s AdServices framework for attribution, which doesn’t require IDFA or App Tracking Transparency (ATT) prompt. 
// No ATT prompt needed
SpendOwl.configure(apiKey: "your-api-key")
Users who enable “Limit Ad Tracking” may still have attribution data via AdServices, though with reduced accuracy.

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App Store Privacy Questionnaire

When submitting to the App Store, you’ll answer privacy questions. Here’s how SpendOwl affects your answers:

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Data Types

Collected: Yes (anonymous device ID for analytics) Linked to Identity: No (unless you call setUserId()) Used for Tracking: No
Collected: Yes (for ROAS calculation) Linked to Identity: Optional (if you set user ID) Used for Tracking: No
Collected: Yes (app install attribution) Linked to Identity: No Used for Tracking: No

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Tracking Definition

Apple defines “tracking” as linking data with third-party data for advertising purposes. SpendOwl:
  • Does NOT link data with third-party advertising data
  • Does NOT share data with data brokers
  • Only uses data for your own analytics
Answer “No” to tracking questions unless your app has other tracking.

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User Identity

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Anonymous by Default

Without calling setUserId(), all data is anonymous: 
SpendOwl.configure(apiKey: "your-api-key")
// All data is anonymous

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Identified Users

When you set a user ID, data is linked to that identity: 
SpendOwl.setUserId("user-123")
// Attribution and purchases linked to this user
Update your privacy policy if linking data to user accounts.

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Data Retention

  • Attribution data: Stored indefinitely for ROAS reporting
  • Purchase data: Stored indefinitely for revenue analytics
  • Device IDs: Hashed before storage

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Data Deletion

To request data deletion for a user:
  1. Go to SpendOwl Dashboard
  2. Navigate to Settings → Privacy
  3. Enter the user ID
  4. Click Delete User Data
Or contact [email protected].

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GDPR Compliance

For GDPR compliance:
  1. Data Processing Agreement (DPA): Available upon request
  2. Data location: Processed in the United States
  3. User rights: Deletion requests honored within 30 days

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CCPA Compliance

SpendOwl supports California Consumer Privacy Act (CCPA):
  • SpendOwl does NOT sell personal information
  • Users can request data deletion
  • SpendOwl acts as a “service provider” under CCPA

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Privacy Policy Template

Add this to your app’s privacy policy:
Analytics and Attribution We use SpendOwl to measure advertising effectiveness. SpendOwl collects:
  • Anonymous device identifiers
  • App install attribution data
  • Purchase information (for analytics only)
This data is not used for advertising targeting or sold to third parties. For more information, see SpendOwl’s privacy policy at spendowl.io/privacy.

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Required Reasons API

SpendOwl uses these APIs that require disclosure in the privacy manifest:
APIReason
NSUserDefaultsApp preferences (C56D.1)
File timestamp APIsApp functionality (DDA9.1)
These are already declared in SpendOwl’s bundled privacy manifest.

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Questions?

Contact [email protected] for privacy-related inquiries.