App rejected Guideline 5.1.2

I tried to submit my app to the app store but my app got rejected. This is the explanation I got from Apple:

Guideline 5.1.2 - Legal - Privacy - Data Collection and Storage



We noticed that your app collects information about the user’s friends, contacts, or other third-party persons without the knowledge or consent of those parties.


Specifically, the app is collecting and saving license plate numbers which can be used to look up car owners and their private contact details and address.


Next Steps


To resolve this issue, please remove any features that collect personal third-party user data from your app.


The app lets you find the owner, phone number and address of any Swedish car with the license plate. In the app, you can call the owner from the app.


The app also lets you save this information as user defaults.


Exactly which features do I need to remove or is it something wrong with my privacy policy?


Here is my privacy policy:

https://snokivag.herokuapp.com

Replies

The privacy policy in your app is 'agreed to' by the user of the app. App Review is pointing out that the data you are collecting refers to the owner of the car, not the user of the app.


I am not familiar with privacy law in Sweden. But perhaps you could rely on the specificity of "...that collect" in App Reviews suggestion:

"To resolve this issue, please remove any features that collect personal third-party user data from your app."


Don't save the information in the app. Tell App Review you will only use the publicly available third-party user data to "call the owner from the app" and that you are not violating the owner's privacy because you are not collecting the information.

>Exactly which features do I need to remove or is it something wrong with my privacy policy?


Seems this isn't about the PP, but just about the app's basic premise. if the only thing your app does is track car owners, and you do what review wants, your app will apparently no longer have a purpose, and there would be nothing to require a PP. The rejection is in fact saying you do not have an app, if that is the case.


in the US, as an example, this type of information could be used to stalk a car's owner. Is it common in Sweden to be able to track people so easily?


Have you made any appeals and/or received multiple rejections, yet?

Thanks! I will remove the feature that allows the user to save the information.

Is it any way I can save the data legally?

The issue is not 'legally' it is 'app reveiw'. Your app is collecting (aka 'compiling') personal information of people who drive by the user of the app.


Herein lies your rub -

5.1.1 (viii) Apps that compile personal information from any source that is not directly from the user or without the user’s explicit consent, even public databases, are not permitted


You could try this approach with app review:


1) App review - the data saved by this app is based on publicly displayed license plate data. It is viewed and recorded by the user of the app. Therefore, upon recording, this data is the property of the user of the app not the owner of the license plate. The user of the app further clarifies their data by accessing a public database. The user of this app has given permission to compile this data. This app is not in violation of 5.1.1 (viii) because the data is obtained directly from the user with the user's explicit consent.


(IMHO - App Review should reject the app because of 5.1.1 (viii) if you do anything other than display the personal information of the license plate owner. Even displaying it may be questionable.)

I'm surprised Sweden has a publically available database of license plate numbers such as this. It seems like that would encourage stalking or other crimes.

My app was rejected for the same reason. Could you get your application accepted?