Apple recently rolled out a [new affiliate program](https://phgconsole.performancehorizon.com/login/itunes) managed by PHG. Unfortunately, I cannot figure out whether this program does or does not require a privacy policy on new applicants’ websites. In Apple’s [FAQ about the new program](http://www.apple.com/itunes/affiliates/resources/documentation/faq_en.html) Apple says reasons for a rejected application may include:
> [The site] [f]ails to clearly state an online privacy policy to visitors.
and in the Terms and Conditions associated with the program, Apple and PHG state that:
> (g) [the Publisher of the website] shall provide a clear and conspicuous link to its privacy policy from each page on its Site;
> (h) [the Publisher of the website] shall include a statement in its privacy policy that PHG and/or Advertiser (or another third party, where applicable) may use code or cookies on Publisher’s website to track the performance of Advertiser’s marketing efforts, and that no personally identifiable information is collected in such process;
Yet, a [number](http://shawnblanc.net) of [prominent](http://www.macdrifter.com) [sites](http://david-smith.org/about/), that I assume are part of the new program, seem to have no privacy policy. Does this mean that Apple and PHG are not enforcing this part of the Terms and Conditions? I cannot tell.[^fn1]
[^fn1]: Before I submitted my site to join the new affiliate program, I added a basic [privacy policy](https://johnkiv.us/privacy-policy/) to my site that include the required language from the Terms and Conditions.