"Do you share data with data brokers?" — the checkbox you shouldn't tick on a hunch
Google Analytics or Dynatrace are not data brokers but data processors. The one question that settles it before filling out an App Store privacy label.
"Do you share data with data brokers?"
I've seen more than one developer tick that App Store checkbox without really knowing. Partly reflex, partly caution. And almost always wrongly.
The scenario is classic: you add Google Analytics or Dynatrace to your app, App Store Connect asks the question, and you hesitate one second too long.
Nine times out of ten, the answer is no.
What is a data broker?
A data broker is someone who resells your data to third parties your user has never encountered. Selling data is their entire business.
Google Analytics or Dynatrace, used normally, play a completely different role. They are processors: they process data on your behalf, they're bound by contract, and they're not allowed to use it for themselves.
The question that settles it
Can this vendor use your data for its own benefit? If not, it's a processor, full stop. If yes, that's where you dig.
And that's precisely the trap of free SDKs. When the tool costs you nothing, the data often pays the bill. So before ticking, go read the contract.
Two confusions to avoid
- Apple's definition is narrower than the GDPR's — don't map one onto the other.
- When the CNIL went after Google Analytics, it was about data transfers outside Europe, not about data brokers. Two topics, two problems.
💡 Before filling out a privacy label: read the contract, ask the "on whose behalf" question, and don't confuse Apple with the GDPR.
And you — do you tick on a hunch, or open the contract every time?