This article covers the implementation steps involved with regards to the "Right To Erasure" and "Right To Restriction of Processing" requests that your app/website users raise with you.
Right To Erasure
Under "Right To Erasure" of GDPR, we have exposed an API which will remove all the personal data associated with specific users who have requested to be erased.
For information on using this API, please refer our implementation docs here.
The API accepts one of the following parameters as input:
- ID (required for logged in users)
- Mobile Number
- GAID (required for anonymous users)
- IDFA (required for anonymous users)
Removing a user’s personal data will erase personal data from MoEngage. In order to maintain the integrity of campaign and application usage analytics, anonymous aggregated data will not be modified when an end user is removed (for example, MoEngage will not decrement an app’s MAU numbers or Campaign Stats when an end user is deleted. However, this data will not be connected in any way to the profile of the forgotten end user, ensuring that this anonymized and aggregated data cannot be tied back to any individual user.
Once the API request is made to remove personal data for specific users, it will take up to 7 days for completing this request. It may, however, take 60 days to remove this data from all our logs and backups. We need to maintain the data for 60 days to justify our processing of erasure requests of personal data related to every user.
You can refer this article for more details on the GDPR erasure API.
Right To Restriction of Processing
To comply with the data tracking opt-out requests of users under "Right To Restriction of Processing" of GDPR, our latest SDKs are now shipped with the methods to opt out of data tracking.
For information on leveraging the capabilities of our new SDKs to restrict data processing, please have a look at the below implementation docs:
Once the above data processing is stopped from the SDK, SDK will not track any events except the ones which can be tracked anonymously like
- Push (Notification Received Android, Notification Clicked Android, Notification Swiped Android)
- iOS Push (Notification Sent iOS, Notification Clicked iOS)
- web Push (Notification Received web, Notification Clicked web)
- InApp (InApp Shown Android, InApp Clicked Android, InApp Closed Android, App Rated)
- InApp (InApp Shown iOS, InApp Clicked iOS, InApp Closed iOS, App Rated)
- Anonymous Lifecycle Events (MOE_APP_EXIT, TOKEN_EVENT, App/Site Opened, Viewed Web Page)
- Stats Events (NOTIFICATION_OFFLINE_MOE,DT_CAMPAIGN_SCHEDULED, EVENT_ACTION_COPY_COUPON_CODE)
Please note the below points when implementing the data tracking opt-out methods of our SDK-
- Opting-out of data tracking does not ensure erasure of data. To restrict processing of data and also erase it completely, please make the erase API request separately.
- Opting-out of data tracking does not ensure that push notifications will not be sent. In order to suppress push notifications on devices/users, please refer the Opt-out of push notifications section below.
Opt-out of Push Notifications
You may be required to take consent from your users before sending them push notifications. In case you want to restrict notifications for a few users or devices, we recommend the below options:
- Track Push Preference as a user attribute: You can take the push permission from every user and set it as a user attribute. Once this is done, you can exclude the users who have opted out of push notifications from campaign segmentation. Please refer this doc on segmentation for more information on how to go about this.
- ANDROID: The new Android SDK of MoEngage is shipped with a method to restrict push notifications on a particular device. Please refer this implementation doc for more information on opting out of push notifications.
- iOS: By default, iOS Platforms support push permissions for specific apps. This is a device level setting and you can redirect your users to this device setting to enable/disable push notifications.
- Web: By default, web push notifications need an explicit opt-in from users. To disable push notifications for specific browsers, you can leverage the existing browser functionality to disable notifications.
In case you have any queries around GDPR, please have a look at our blog post or write to us at email@example.com