# Guideline 5.1.2 - Legal - Privacy - Data Use and Sharing

> Apple rejected your app under Guideline 5.1.2, Data Use and Sharing. Tracking without the ATT prompt, data sent to a third-party AI, and locked features.

Canonical: https://app369.com/fix/app-store-guideline-5-1-2-data-use-and-sharing/
Last updated: 2026-11-09

App Review rejected the app under Guideline 5.1.2, Data Use and Sharing, because of how it shares or uses personal data. The usual triggers are tracking without the App Tracking Transparency prompt, data sent to a third-party AI without permission, and a feature locked until the user turns on tracking, location or notifications.

**Short answer**

Show the App Tracking Transparency prompt before any tracking starts, and stop tracking when the user says no. Before sending personal data to a third-party AI service, say so in the app and ask for permission. Don’t lock features, content or rewards behind turning on tracking, location or notifications, and use data only for the purpose you asked for it.

Rather not fix it yourself? [**App Fix Ticket**](https://app369.com/fixed-price/flutter-firebase-bug-fix/) starts with a fixed-price diagnosis, then a fixed price for the fix before any fix work.

## **The usual causes, and the fix**

1. 01 ### **Tracking without the App Tracking Transparency prompt**
  > “You must receive explicit permission from users via the App Tracking Transparency APIs to track their activity.” [**Apple, Guideline 5.1.2(i)**](https://developer.apple.com/app-store/review/guidelines/#5.1.2) Linking data from the app with other companies’ data for ads, or sharing the advertising identifier, is tracking, and an ads or attribution SDK can do it even when your own code doesn’t. Ask with requestTrackingAuthorization before it starts, add NSUserTrackingUsageDescription to Info.plist, and make the App Privacy answers in App Store Connect match what the app does. Ask once the app is active on screen: a request made too early at launch can show no prompt.```
import AppTrackingTransparency

ATTrackingManager.requestTrackingAuthorization { status in
  if status == .authorized {
    // start the ads SDK with tracking
  }
}
```
2. 02 ### **Personal data sent to a third-party AI**
  > “You must clearly disclose where personal data will be shared with third parties, including with third-party AI, and obtain explicit permission before doing so.” [**Apple, Guideline 5.1.2(i)**](https://developer.apple.com/app-store/review/guidelines/#5.1.2) If the app sends what a user types, says or uploads to an outside AI service, tell them where it goes and get explicit permission first. Add a short screen before the first use that names the provider and what is sent, with a way to say no, and update the privacy policy to match.
3. 03 ### **A feature locked behind tracking, location or notifications**
  > “Your app may not require users to enable system functionalities (such as push notifications, location services, tracking) in order to access functionality” [**Apple, Guideline 5.1.2(i)**](https://developer.apple.com/app-store/review/guidelines/#5.1.2) A screen that blocks the app until tracking is on, or a reward for allowing notifications, breaks this rule. Ask at the moment a feature needs the permission, and keep the rest of the app working when the answer is no.
4. 04 ### **Data reused for a new purpose**
  > “Data collected for one purpose may not be repurposed without further consent unless otherwise explicitly permitted by law.” [**Apple, Guideline 5.1.2(ii)**](https://developer.apple.com/app-store/review/guidelines/#5.1.2) An email address collected for sign-in and later used for marketing, for example, needs new consent under Apple’s rule, unless the law explicitly permits it. Ask again before the new use, and keep a record of who agreed.

Checked against the vendor’s docs on November 9, 2026: [Apple: App Review Guidelines, 5.1.2 Data Use and Sharing](https://developer.apple.com/app-store/review/guidelines/#5.1.2); [Apple: App Review (replying and appeals)](https://developer.apple.com/distribute/app-review/).

## **Rather hand it over?**

Fixed scope, fixed price, paid upfront. The work happens in writing; no call needed.

**Resubmit before Apple’s holiday slowdown**

Pay for the Diagnosis and send the rejection and access to the app by Monday, December 7 (US Eastern). The Diagnosis is back by Thursday, December 10. Pay for the Fix that day and it arrives as a pull request by Thursday, December 17, in time to build and resubmit before December 20.

In past years Apple said reviews may take longer around the holidays: [December 20 to 26 in 2024 (opens in a new tab)](https://developer.apple.com/news/?id=iwvebnw2), [December 22 to 27 in 2023 (opens in a new tab)](https://developer.apple.com/news/?id=uijoypq9), [December 23 to 27 in 2022 (opens in a new tab)](https://developer.apple.com/news/?id=xpkhwg3l). Apple hasn’t posted its 2026 dates yet (checked October 30). Approval stays Apple’s decision.

- [from $450**App Fix Ticket**One reproducible bug in an existing mobile or web app, diagnosed and fixed.**See scope and start**](https://app369.com/fixed-price/flutter-firebase-bug-fix/)

[**All 127 Fiverr reviews**](https://app369.com/reviews/)

Related: [**App Store Guideline 5.1.1**](https://app369.com/fix/app-store-guideline-5-1-1-data-collection/) · [**App Store Guideline 2.1**](https://app369.com/fix/app-store-guideline-2-1-app-completeness/) · [**App Store Guideline 2.5.1**](https://app369.com/fix/app-store-guideline-2-5-1-software-requirements/) · [**App Store Guideline 5.2.1**](https://app369.com/fix/app-store-guideline-5-2-1-intellectual-property/)

Questions

## **More on this rejection**

<details>

<summary>**Should I reply to App Review or appeal? **+</summary>

Reply first. Apple says you can correspond with App Review in App Store Connect to resolve the issues before resubmitting, which is the place for a demo account, a screen recording or an explanation. Appeal to the App Review Board only if you believe App Review misunderstood the app or treated you unfairly. Apple allows one appeal per rejected submission and asks for specific reasons the app complies.

</details>

<details>

<summary>**What is the difference between 5.1.1 and 5.1.2? **+</summary>

5.1.1 covers collecting and storing data: purpose strings, account deletion and the privacy policy link. 5.1.2 covers what the app does with the data: sharing it, tracking, and using it for something new. The 5.1.1 guide covers the first.

</details>

<details>

<summary>**Do I need the ATT prompt if the app shows no ads? **+</summary>

Only if the app tracks. Check every SDK in the app, because an attribution or ads SDK can track even when the app shows no ads. If nothing links the app’s data with other companies’ data for ads, there is nothing to ask for.

</details>

<details>

<summary>**Can you fix it for me? **+</summary>

Yes, through the App Fix Ticket: you send the rejection message and access to the app, Simon writes a diagnosis of what App Review hit and how to fix it, then fixes the code so you can resubmit. Each step has a fixed price, paid upfront. Approval stays Apple’s decision; the ticket covers the fix.

</details>

A different error?

## **Describe it and get a written quote**

Send the error and what you were doing. You get a written scope, a fixed price and a timeline; Simon replies by email, usually within one business day.

[**Describe your problem **→](https://app369.com/contact/) [**All fixes**](https://app369.com/fix/)