5.1.1(x) - How does Apple expect us to support user accounts without contact details?

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Created Oct ’21

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This is a massive clause change and it doesn't seem like enough people are discussing this as the update to the the anti-steering clause is the "hotter" topic (with everyone forgetting that its no longer of any benefit to them if users don't give you their email addresses anyway).

"Apps may request basic contact information (such as name and email address) so long as the request is optional for the user, features and services are not conditional on providing the information, and it complies with all other provisions of these guidelines, including limitations on collecting information from kids.”

Ok. So now, if my app has account based features, they would need to register. If they register, if we don't use a phone number or email address, we would have to use a unique identifier.

So ok, let's use a unique identifier.

Now, that user forgets their password. Well, good luck to you, you didn't give us your email or number, so we can't verify that it was you who created the account. Like how Reddit does it.

Ecommerce? How can I deliver to customers (the service) if I don't get their address (contact information)? There is 0 way to satisfy that clause in this situation.

In fact, even to pay for the item with a Credit Card, they would have to enter their Billing Address.

How do I send customers receipts of their purchases without their email address? (and don't tell me you can just show it in the app... try sharing that with an accountant)

How do I enable 2-factor authentication without SMS or Email?

Covid Tracing / Check In apps - are they exempted?

Literally cannot use any other email client other than Mail (Email Address)

Or sell a house (Address).

Is there any way to get clarity on these questions from Apple?

1 - If we offer Sign in with Apple alongside Plain Old User Email Authentication, does that satisfy Clause 5.1.1(x) - because Signing in with Apple email addresses are 'opt-in' using the Hide my Email feature", ?

2 - How does the clause support applications where the provision of a service is functionally dependent on contact details, as mentioned in Clause 5.5.1(v) "Apps may not require users to enter personal information to function, except when directly relevant to the core functionality of the app or required by law."?

3 - How does this clause satisfy other use cases that may require Proof of Identity (using Identity Verification Services) such as Government (as mentioned in Clause 4.8 "Your app uses a government or industry-backed citizen identification system or electronic ID to authenticate users.")

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Answer 1

Claude31 OP

Oct ’21

"Apps may request basic contact information (such as name and email address) so long as the request is optional for the user, features and services are not conditional on providing the information, ….”

The way I understand it:

you cannot force customer to give a contact address
and need to provide the service of the app (but clause 5.1.1(v) says differently, as you noted, for Core functionalities that need ID): so the question is "how do we define a core functionality and prove it requires ID" ? And whether 5.1.1.(v) supersedes 5.1.1.(x)
However, you could state that support like recovery of lost password for instance will not be available in such a case. As this is outside the app, I understand it is authorised.

Did you contact support ?

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Answer 2

dteo_appetiser OP

Oct ’21

As this is outside the app, I understand it is authorised.

If we are interpreting 5.1.1(x) literally as written, it would be authorised but you won't have the email address to recover the password with.

so the question is "how do we define a core functionality and prove it requires ID" ? And whether 5.1.1.(v) supersedes 5.1.1.(x)

Yes that's is probably the key question - does 5.1.1(x) only covers "non core functionalities"? And is "password recovery" a "core functionality"?

Have not contacted support yet. I thought Apple Developer Forums would be the correct place to ask these questions first. But I can see that it's kinda quiet here :D So I'll shoot them a message I guess.

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