It is now 2024 and we are still experiencing this issue, here is my experience and resolution process, I hope this helps someone in need.
We removed the IDFA in the new app version, however were unable to change the privacy setting to not tracking in AppStoreConnect. we chose to leave it as it is for now and attempted to submit it for review, unsurprisingly the reviewer asked the same question as the OP, so we submitted the following response:
Hello, in this app version we removed everything related to AppTrackingTransparency including NSUserTrackingDescription. However, we can not update the app privacy information to "Not tracking users" in AppStoreConnect since it's related to the current app binary on the AppStore, not the one we are trying to update. Please approve this then we will be able to update the privacy information later.
The reviewer understood the issue and passed this review. However, we are still unable to change the settings in AppStoreConnect. When I change the privacy, an implicit error occurred, if I select Not tracking, the setting doesn't take effect and the page doesn't change.
We then submitted this issue to Apple Support and the support team said it had been referred to the appropriate department. After another week of waiting they replied that my issue had been fixed and I was finally able to edit my privacy settings properly.
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Same for me with WKWebView