Does Singular require disclosure in our privacy policy?

Yes. Singular is a third-party data processor that collects personal data including device identifiers and conversion events. Because Singular processes user data on your behalf, you must disclose its use in your privacy policy and obtain appropriate consent under GDPR and ATT (App Tracking Transparency) requirements. Clear disclosure helps users understand how their mobile data is being tracked for attribution purposes.

What specific data does Singular collect?

Singular collects install attribution data, device identifiers, ad spend information, in-app conversion events, and campaign/creative performance metrics. This data is used to attribute app installations to specific ad campaigns and measure user behavior post-installation. The platform does not use cookies, but instead relies on device-level identifiers to track attribution across advertising channels.

Does Singular require a cookie consent banner?

No. Singular does not use cookies and therefore does not require a cookie consent banner. However, you must still obtain explicit user consent under GDPR for processing personal data (such as device identifiers) and comply with Apple's App Tracking Transparency (ATT) framework, which requires user permission before tracking across apps.

Who is the data processor and where is data transferred?

Singular Labs Inc., a United States-based company, acts as your data processor. User data collected by Singular is transferred to and processed in the United States. You should have a Data Processing Agreement (DPA) in place with Singular and ensure appropriate safeguards exist for international data transfers, particularly under GDPR.

Deep Linking & Attribution

Privacy policy clauses for Singular

Singular is a mobile marketing analytics and attribution platform that tracks app installations, ad campaign performance, and in-app user actions. Websites and apps use Singular to measure how advertising drives user acquisition and conversion events across different marketing channels.

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What data Singular collects

Your privacy policy must disclose each of the following data types when you use Singular.

Install attribution and ad spend data

Device identifiers

In-app conversion events

Campaign and creative performance

When does Singular trigger privacy obligations?

Installation and Data Flow Start

The moment you integrate Singular's SDK into your mobile app or website, device identifiers, install attribution data, and in-app conversion events begin flowing to Singular Labs Inc. (a US processor). This triggers immediate compliance obligations across multiple regimes:

### GDPR (if you have EU users)

Singular collects device identifiers and processes conversion events that qualify as personal data under GDPR Article 4(1). You become the controller; Singular is the processor. This means:

–You must establish a lawful basis (Article 6) *before* SDK integration. Consent under Article 7 is typical for attribution tracking.

Privacy policy clauses for Singular

What data Singular collects

When does Singular trigger privacy obligations?

Installation and Data Flow Start

Where data goes

Common compliance pitfalls

1. No Data Processing Agreement or Incomplete SCCs

2. Vague or Missing Attribution Disclosure

3. Forgetting ATT Consent on iOS

Legal note

Sample privacy policy clause

What regulators look for

DPA Audit Priorities

US and Apple Enforcement

Frequently asked questions

Does Singular require disclosure in our privacy policy?

What specific data does Singular collect?

Does Singular require a cookie consent banner?

Who is the data processor and where is data transferred?

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