App Annie

Trust & Assurance

2021 SEC Investigation


App Annie is a Unified Data AI company providing mobile and digital market data estimates for all industries - including investors and hedge funds. On September 14, 2021, the SEC (Securities and Exchange Commission) announced a settlement with App Annie. As part of the settlement, App Annie neither admitted nor denied the findings, agreed to cease and desist from any future violations of the federal securities laws cited in the SEC order, and was fined $10 million.

Moving forward, just as we have done, we believe it is important for all companies in our industry to do the following:

  • Exclude confidential public company data from their estimate generation processes,
  • Not leverage ad-hoc manual estimate alterations using confidential public company data and
  • Accurately represent the effectiveness of internal controls and processes aimed at preventing the misuse of confidential public company data.

This investigation did not relate to our current products and services or to our current customers and partners. Additionally, App Annie implemented new internal controls and processes designed to exclude confidential public company data from its estimate generation processes. This includes: downloads, revenue, active users, session time, time spent, open rate, retention, marketing creatives across ad networks and other digital performance signals. Whether sourced from services like App Annie Connect or other analytics offerings, all confidential public company data is excluded. These controls will ensure this data is not viewed or referenced, or in any way influences, our estimate generation process.

Practically speaking, no public company would willingly and explicitly consent to share their confidential public company data (e.g. MNPI) to be used by a 3rd party to generate estimates for the purposes of trading, performance benchmarking, M&A, and partnerships.

Additionally, we have implemented controls to prevent ad-hoc manual estimate alterations. App Annie invested in building world class fully-automated AI capabilities delivering a premium market data product fueled by end-to-end data science. We believe this is the only way to protect our customers from putting their company at risk by unintentionally using confidential public company data.

In summary, App Annie believes that these material changes to our operations establish a new level of trust and transparency. We are also advising the market that they should proactively ask their data providers whether they are doing the following:

  • Leveraging confidential public company data,
  • Verifying end-to-end controls are in place to omit the use of confidential public company data,
  • Ensuring no manual data estimate alterations are taking place and
  • Proving fully authorized and explicit contractual consent for each use of confidential public company data.

To learn more, please see below for our FAQ.


Does this SEC investigation impact App Annie customers and partners?

Will there be any third party oversight required as part of the Offer of Settlement?

Why should you trust App Annie?

What if I’m not headquartered in the US?