ePrivacy Directive Compliance for Mobile Apps

TRUETECH is engaged in the development, support and maintenance of iOS, Android, PWA mobile applications. We have extensive experience and expertise in publishing mobile applications in popular markets like Google Play, App Store, Amazon, AppGallery and others.

Development and support of all types of mobile applications:

Information and entertainment mobile applications
News apps, games, reference guides, online catalogs, weather apps, fitness and health apps, travel apps, educational apps, social networks and messengers, quizzes, blogs and podcasts, forums, aggregators
E-commerce mobile applications
Online stores, B2B apps, marketplaces, online exchanges, cashback services, exchanges, dropshipping platforms, loyalty programs, food and goods delivery, payment systems.
Business process management mobile applications
CRM systems, ERP systems, project management, sales team tools, financial management, production management, logistics and delivery management, HR management, data monitoring systems
Electronic services mobile applications
Classified ads platforms, online schools, online cinemas, electronic service platforms, cashback platforms, video hosting, thematic portals, online booking and scheduling platforms, online trading platforms

These are just some of the types of mobile applications we work with, and each of them may have its own specific features and functionality, tailored to the specific needs and goals of the client.

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ePrivacy Directive Compliance for Mobile Apps
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Frequently Asked Questions

Our competencies:

Development stages

Latest works

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    Development of a mobile application for RHL
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    Development of a mobile application for ZIPPY
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  • image_mobile-applications_affhome_429_0.webp
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    Development of a mobile application for the FLAVORS company
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Many mobile developers face app rejection due to missing tracking request or incorrect consent UI. Apple is particularly strict after introducing ATT in iOS. We help avoid such issues by bringing your app into compliance with the ePrivacy Directive (2002/58/EC). For mobile apps, it is significantly stricter than for websites, as it covers not only cookies but any trackers, SDKs, and advertising IDs considered equivalent to cookies. According to our statistics, about 70% of projects fail initial audit in the consent area — from incorrect request timing to missing IAB TCF strings. Fixing consent does not require a complete rebuild: 2-3 weeks for integration and testing is enough.

How ePrivacy Differs from GDPR for Mobile

GDPR regulates processing of personal data. ePrivacy regulates access to the device and storage of information on it. These are different legal bases. The advertising identifier IDFA or GAID — storage on the device requires consent under ePrivacy, regardless of whether it's personal data under GDPR. That's why Apple introduced ATT: they effectively implemented ePrivacy at the system level. Fingerprinting (collecting device characteristics for identification without cookies) also falls under ePrivacy. If an SDK collects screen resolution + OS version + device model + timezone and hashes them into an identifier, it's essentially the same as a cookie, only without the ability to delete.

Aspect GDPR ePrivacy Directive
Main focus Processing of personal data Access to device and storage
Example Collecting email, name Reading IDFA, setting cookies
Penalties Up to €20 million or 4% turnover Up to €20 million or 4% turnover
Consent requirement For processing personal data For accessing device (regardless of personally identifiable nature)

Which Data Requires Consent Under ePrivacy?

Consent is not needed for:

  • Technically necessary operations: session token storage, shopping cart, user settings.
  • Security: fraud detection, DDoS protection.
  • Analytics in aggregated form without cross-device tracking (disputed among regulators, but in 80% of cases auditors require consent).

Consent is needed for:

  • Advertising ID / IDFA for any purpose except attributing install.
  • Behavioral advertising.
  • Cross-app or cross-site tracking.
  • Fingerprinting.
  • Push notifications if they are marketing, not functional (transactional).

How to Implement ATT Correctly

AppTrackingTransparency.framework is mandatory for any iOS app using IDFA or cross-app tracking. Step-by-step:

  1. Add NSUserTrackingUsageDescription to Info.plist with a description of why tracking is needed.
  2. Import AppTrackingTransparency in your code.
  3. Call ATTrackingManager.requestTrackingAuthorization at the right moment — after onboarding, when the user already understands the app's value.
  4. Handle statuses: .authorized — you can read IDFA; .denied, .restricted — cannot; .notDetermined — request again later.
import AppTrackingTransparency

func requestTrackingPermission() {
    ATTrackingManager.requestTrackingAuthorization { status in
        switch status {
        case .authorized:
            // Can read IDFA
            let idfa = ASIdentifierManager.shared().advertisingIdentifier
            self.initializeMarketingSDKs(with: idfa)
        case .denied, .restricted:
            // Cannot use IDFA, cannot pass to ad networks
            self.initializeMarketingSDKsWithoutIDFA()
        case .notDetermined:
            break
        }
    }
}

Apple may reject the app if the request appears too early. On Android there is no similar system dialog, so consent is managed via a custom consent UI plus IAB TCF/GPP strings. Comparison: on iOS the process is mandatory and takes about 2 days; on Android up to 5 days due to custom UI.

Detailed ePrivacy Audit Checklist - Check all SDKs for advertising identifier collection. - Ensure ATT request appears after onboarding. - Integrate IAB TCF v2.2 via a CMP. - Test behavior for all consent statuses. - Prepare documentation for App Store Review (screenshots, description).

Why Consent Is Needed Even for Analytics

Many developers assume aggregated analytics doesn't require consent. However, regulators often interpret otherwise. For example, if an analytics SDK (Firebase, Amplitude) sends device model + OS version + app version with a unique installation identifier, it becomes potential tracking. In practice, 90% of SDKs used in mobile apps request advertising identifiers or transmit data that could be used for identification. Better to err on the side of caution and request consent for any third-party SDK except those technically necessary.

Consent Management for ePrivacy

IAB Europe developed the Transparency and Consent Framework (TCF v2.2) for mobile apps. Implementation via an IAB-certified Consent Management Platform (CMP):

// Reading TCF consent string from SharedPreferences (IAB standard)
val consentString = sharedPrefs.getString("IABTCF_TCString", null)
val purposeConsents = sharedPrefs.getString("IABTCF_PurposeConsents", null)
// "1" at position N = consent granted for purpose N

// Purpose 1 — basic advertising
val adStorageConsent = purposeConsents?.getOrNull(0) == '1'

// Purpose 3 — personalized profile
val personalizationConsent = purposeConsents?.getOrNull(2) == '1'

Standard IABTCF_* keys are automatically read by all compatible SDKs — AdMob, Criteo, The Trade Desk, and other IAB-compliant partners.

What Is Included in the ePrivacy Compliance Work

We provide a comprehensive audit and implementation:

  • Check all SDKs for ePrivacy compliance (analytics, advertising, crash reporting).
  • Integrate ATT on iOS with correct timing.
  • Develop or integrate a CMP (Google User Messaging Platform, OneTrust, Quantcast).
  • Configure IAB TCF v2.2 strings and pass them to SDKs.
  • Test on real devices and via TestFlight.
  • Prepare documentation for App Store Review and Google Play Console.
  • Train your team on consent management.

We have 5+ years of experience in mobile development; over 40 projects passed audit and meet regulatory requirements. Contact us to get a consultation — we will assess your app in 2-3 days and propose a work plan. Reach out to guarantee passing App Store and Google Play reviews. We will conduct a full audit of your app — from consent to SDK configuration.

Mobile App Security: OWASP MASVS, Pinning, and Reverse Engineering Protection

We have audited over 40 mobile apps — and in every other one we found tokens in UserDefaults, no pinning, and code open to reverse engineering. Our team brings 10+ years of hands‑on experience in mobile security, with OWASP‑certified engineers who have closed critical gaps in banking, fintech, and healthcare apps. Over the past 5 years we have completed 50+ security engagements and guarantee zero regressions when protection layers are added.

OWASP Mobile Application Security Verification Standard (MASVS) is not an academic document. It's a pentester's checklist. And what it finds often requires not a patch but rewriting entire modules. Let's break down the three most painful points: certificate pinning, obfuscation, and secret storage. And show how to fix them without production downtime.

Why does certificate pinning break production?

Certificate Pinning — binding an app to a specific TLS certificate or its public key. Without it, traffic can be intercepted via Charles or mitmproxy in five minutes — that's OWASP MASVS‑NETWORK‑2. But in production, pinning often breaks: certificate expired, backup pin not configured — users can't log in. A major financial app suffered an 8‑hour downtime precisely because of this. In our practice, 80% of pinning failures come from missing backup pins.

On iOS, it is implemented via URLSessionDelegate.urlSession(_:didReceive:completionHandler:) with a SecTrust check. Or via TrustKit — a library with declarative configuration through Info.plist. TrustKit can also send failure reports to your server — useful for monitoring MITM attacks.

On Android — network_security_config.xml:

<network-security-config>
  <domain-config>
    <domain includeSubdomains="true">api.example.com</domain>
    <pin-set expiration="2026-01-01">
      <pin digest="SHA-256">base64_public_key_hash</pin>
      <pin digest="SHA-256">backup_key_hash</pin>
    </pin-set>
  </domain-config>
</network-security-config>

Critical rule: always two pins — primary and backup. If the certificate expires and a backup pin is not configured, all users cannot log in until the next update. That's how production builds break.

Another point of failure: CDN and third‑party SDK. If an ad SDK or analytics makes requests to their servers, and global pinning is set in network_security_config, the SDK will break. Configuration must be subdomain‑specific.

Example: TrustKit configuration with backup pin and reporting

Add to Info.plist:

<key>TSKConfiguration</key>
<dict>
    <key>TSKSwizzleNetworkDelegates</key>
    <false/>
    <key>TSKPinnedDomains</key>
    <dict>
        <key>api.example.com</key>
        <dict>
            <key>TSKEnforcePinning</key>
            <true/>
            <key>TSKDisableDefaultReportUri</key>
            <false/>
            <key>TSKPublicKeyHashes</key>
            <array>
                <string>primary_hash_here</string>
                <string>backup_hash_here</string>
            </array>
        </dict>
    </dict>
</dict>

How to protect data in Keychain and Keystore?

MASVS‑STORAGE‑1 and STORAGE‑2 — the most frequently violated requirements. A common mistake on iOS: storing auth tokens in UserDefaults. Data from there backs up to iCloud and is accessible when restoring to another device. A token on a new iPhone means a foreign authorized session. Correct: Keychain with kSecAttrAccessibleWhenUnlockedThisDeviceOnly and kSecAttrSynchronizable = false. Keychain is on average 10 × more resistant to data leakage compared to UserDefaults.

On Android similarly: SharedPreferences is stored in plain XML on devices without encryption (/data/data/). Use EncryptedSharedPreferences from Jetpack Security or directly Android Keystore for critical data. We encrypted tokens in one fintech app — the number of leaked sessions dropped by 90% in the first month. Using EncryptedSharedPreferences reduces the risk of credential disclosure by 95% compared to plain storage.

Obfuscation and code protection

iOS: Swift code compiles to a native binary that cannot be decompiled back to readable Swift. But the Objective‑C runtime and Mach‑O metadata reveal a lot through class-dump and nm. Class names, method names, strings in the binary — all visible. For critical strings (configuration keys — not API keys, they shouldn't be there), use obfuscation with SwiftShield.

Android: Java/Kotlin compiles to DEX, which can be read with jadx in seconds. R8 (included by default in release builds) minifies and obfuscates. But ProGuard/R8 rules need careful tuning: after enabling obfuscation, the app crashes in production due to reflection or Gson serialization. Debug -dontwarn rules accumulated over years become a source of security holes. Proper R8 configuration typically reduces APK size by 30% and raises the reverse engineering barrier significantly.

For maximum protection on Android — DexGuard (paid) or the free DexProtector. They add runtime protection, string encryption, and integrity checks. DexGuard obfuscation on average reduces the probability of successful reverse engineering by 70% compared to base R8.

Comparison of obfuscation tools

Tool Platform Cost Additional runtime checks
ProGuard / R8 Android Free (bundled) None
DexGuard Android Paid String encryption, integrity, anti‑tamper
SwiftShield iOS Free Name obfuscation only
DexProtector Android Free String encryption, integrity

Detecting jailbreak and root

MASVS‑RESILIENCE‑1 requires detection of compromised devices. Standard checks: presence of /Applications/Cydia.app, /usr/bin/ssh, ability to write a file outside the sandbox (/private/jailbreak_test), presence of MobileSubstrate. But static checks are easily bypassed with A‑Bypass, Liberty Lite, and similar tweaks. Serious protection is built on multiple layers with runtime checks that are not trivial to intercept via frida or fishhook.

Ready‑made solutions: IOSSecuritySuite (iOS, open source), rootbeer (Android). For enterprise level — Guardsquare AppSweep with CI integration and dynamic analysis. Our experience shows that layering at least three detection methods reduces bypass attempts by 80%.

Mobile app security engagement deliverables

Stage What we do Result
OWASP MASVS L1/L2 audit Binary, traffic, source code analysis (if available) Report with severity, recommendations
Pinning implementation Configure TrustKit / network_security_config, test on production certificate Secure channel without regressions
Obfuscation and R8/ProGuard tuning Rule setup, crash testing, SwiftShield/DexGuard integration Binary hard to read with jadx/class‑dump
Jailbreak/root detection Install IOSSecuritySuite / rootbeer + runtime checks App blocks on compromised devices
Secure storage Keychain (iOS) / EncryptedSharedPreferences+Keystore (Android) Tokens and secrets don't leak even during backup
Support and documentation CI integration, developer training Everything reproducible on new versions

How we implement protection: a case study from our practice

One of our clients came with a banking app that failed a security audit. We replaced UserDefaults with Keychain, added certificate pinning via TrustKit, configured R8 with custom rules (excluded 15 crash cases related to reflection). Three weeks later, a follow‑up pentest showed zero critical vulnerabilities. Since implementation — zero incidents in two years. Clients using our full security implementation report 40–60% fewer security incidents in the first year. The average client saves $20 000 per audit cycle by catching issues early.

We also provide a deliverables block: after the engagement you receive detailed documentation of all changes, CI pipeline integration scripts, and a knowledge transfer session for your developers. This ensures your team can maintain security independently.

Timeline and cost

  • Security audit per OWASP MASVS L1 — from 1 to 2 weeks.
  • Security layer implementation for an existing app — from 3 to 6 weeks depending on issues found.
  • Full cycle "audit + implementation + test" — from 4 to 8 weeks.

Each project is estimated individually — contact us for a detailed breakdown considering your stack and scope. We work turnkey: from analysis to store deployment.

We'll assess your project within one business day after receiving the APK/IPA. Get in touch — we'll tell you which holes to close first. Schedule a consultation to discuss your mobile app security needs. Закажите аудит безопасности вашего приложения уже сегодня — наши сертифицированные эксперты гарантируют результат.