App privacy policy: key requirements, must-have sections, and common mistakes
Apps that directly collect and use personal data directly, or data from third-party apps such as Google Analytics, need to provide users with their app privacy policy.
This policy has to provide specific information about how personal data is collected and used, as well as users’ rights regarding these activities. Most policies will have similarities, but each is unique for types of data collected, purposes for use, business operations, active technologies, and jurisdictional legal requirements.
Users’ increasing expectations are another driver, and developers, marketers, and product managers need to demonstrate an open commitment to dealing with users’ personal information with respect. This way, they will align their data privacy practices with the requirements and expectations of users, app stores, and relevant regulations.
In this article, we will show how to create a privacy policy for mobile apps that clearly communicates this commitment and is aligned with the key legal and app store requirements.
At a glance
- App privacy policy essentials that are for international regulatory compliance
- Key requirements for app privacy policies (including the GDPR, CCPA, and COPPA)
- Must-have sections in a mobile app privacy policy
- App Store and Google Play privacy policy requirements comparison
- How to display and maintain your app’s privacy policy URL
- Common app privacy policy mistakes to avoid (e.g., non-transparency, copying)
- Necessary data collected by mobile apps, and required user consent
- Importance of transparency in app data collection and usage
Key regulations that govern privacy policies for an app
Your apps’ privacy policy should comply with the requirements of the data protection regulations relevant to your users. This could include:
- General Data Protection Regulation (GDPR) in the European Union
- California Consumer Privacy Act (CCPA) in the state of California (and other US states)
- Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada
- The Privacy Act in Australia
Every time your app launches in a new region, you’re likely to face new regulatory requirements. Even though many of them share similar principles regarding data protection, handling, and transparency about user rights, there are some differences.
- The GDPR requires obtaining informed prior consent from users before collecting or processing any personal data.
- In the United States, to date, state-level laws like the CCPA do not require prior consent for data processing in most cases, but do require clearly notifying users about data collection and use, and their rights, including the ability to opt out at any time.
- The Children’s Online Privacy Protection Act (COPPA), which is a federal US law, obligates apps to get verifiable parental or guardian consent before collecting the personal data of children under 13 years of age. (Many state-level privacy laws to date defer to COPPA’s requirements with regard to children’s data protection and handling.)
- Many global data privacy regulations require prior, informed user consent similar to the GDPR, or use hybrid models that delineate when and how consent is required.
Personal information apps collect
Name and email address
Telephone and physical address
IP address and log data
Health and tracking data
Location information
Device information
Payment and banking information
Cookies
Social media
What personal information do apps use and how?
Personal information is at the core of all data privacy regulations, but what does that refer to, exactly? While not exhaustive, this list includes many of the most common types of data that can be categorized as personal data or personal information under data privacy laws.
Some of these types of data can also be categorized as “sensitive” when there is greater risk to individuals if they are misused, and thus have even more stringent requirements and restrictions for access and use.
Name
Email address
Telephone number
Physical address
IP address
Log data
Data collected via cookies
Geolocation and biometric data
Financial and payment information
Health and healthcare data
Learn more about the differences and nuances of PII vs personal data.
What does an app privacy policy say about personal data and its use?
An app privacy policy discloses what will be done with users’ personal information, as well as how data will be protected and deleted.
Collection
This includes when, where, and how personal data is collected, and under what circumstances consent for that is required and how it can be changed or revoked. If multiple laws apply regarding data privacy, this can be complex in some jurisdictions.
Processing
This includes storing, analyzing, and otherwise using data generated or provided through the app to improve its functionality and personalize the user experience, among other uses. This can include personal information about users, usage data, device information, and location data. Also included would be when and how data is shared, e.g., with third-party vendors, for what purposes, and what their obligations for data protection and use are.
Storage
Regulations have requirements both for personal data use and storage. These requirements also apply when app data is provided to third parties, including service providers, advertisers, partners, or legal authorities. This data can be used for targeted advertising, payment processing, customer support, fraud prevention, or legal compliance, among other functions.
Deletion
Responsible apps keep personal data only as long as it’s needed, limit data sharing to necessary parties (that also comply with privacy and security requirements), and employ safeguards such as encryption and anonymization. A variety of laws can regulate data retention and deletion, so a clear policy outlining these functions, and strict adherence to them, is important.
Once apps follow these requirements and clearly communicate about them to users, it contributes to privacy compliance and provides users with important information and control over access and use of their data. A compliant privacy policy for mobile apps clearly and simply explains what data is collected, how it is used, with whom it is shared, and user rights related to the data.
An app privacy policy also needs to be regularly updated as laws, technologies in use, and business operations change, in order to meet legal requirements and provide accurate information to users.
Essential sections for an app privacy policy to include
Each app store has its own set of apps privacy policy requirements. They share essential sections and information requirements that your draft policy needs to include. The policy should be clear and in plain language, no technical jargon or legalese.
| Essential sections | What to communicate |
| Types of data collected | Specify what personal data is collected, e.g., name, email, device info, location, usage data, cookie use, camera/microphone access. |
| Purpose of data collection and usage | Explain why data is collected and used, e.g., improving services, analytics, or marketing). |
| Data security, storage, and retention practices | Describe how data is stored or shared securely, your encryption measures, retention periods, and deletion practices. |
| Information sharing and third-party disclosures | Disclose if data is shared with third parties, including partners or service providers, for what purposes, and how the processing complies with privacy requirements. |
| User rights regarding personal data | Outline users’ rights to their data, including (depending on the law) access, correction, deletion, or changes to or withdrawal of consent. |
| Contact information for privacy inquiries | Provide a direct way for users to ask privacy-related questions, request support, or exercise their rights. |
| Compliance with relevant legal frameworks | Explain the requirements of relevant laws (e.g., GDPR, CCPA, COPPA) and platform-specific requirements (Apple App Store, Google Play) and how your organization complies. |
Use our straightforward 12-step instruction on how to write a privacy policy that is customized for your business.
Privacy policy for mobile apps: app stores requirements
Most mobile apps are published on Apple’s App Store and/or Google Play. Apple’s App Store requires clear disclosure of data usage, tracking practices, and user consent mechanisms. Google Play states that appearing on the platform means adhering to the core principles of transparent data collection, sharing, and security practices with sufficient user control.
Apple’s App Store requirements focus on aligning apps’ privacy practices with App Privacy labels and guidelines, while Google Play doesn’t have the same explicit guidelines in place, yet requires apps to align with Google’s data collection, sharing, and security practices.
Apple App Store privacy requirements
Per App Store policy, apps need to:
- Include a link to their privacy policy in the App Store Connect metadata and within the app
- Request user consent before collecting personal information
- Obtain explicit user permission for tracking activity via the App Tracking Transparency APIs
- Clearly identify how personal data is collected and for what purposes
- List all third-party tools (including marketing analytics and AI) that collect users’ personal information and their user data protection practices
- Explain their data retention and deletion processes
For Apple, user consent is key before any personal data collection — even if anonymous and deleted immediately — and it should be possible for users to easily withdraw it.
Data minimization is also a key principle, as app developers are asked to collect personal data only if it’s necessary for the core app functionality. Forcing or manipulating users into consenting is unacceptable and can result in apps being declined by the App Store.
According to App Store principles, information tracked in health and fitness apps may not be used or disclosed to third parties for marketing purposes other than improving health management, and only with permission. The only use encouraged by Apple is to provide direct benefit to users.
Other important App Store documentation:
- App Review Guidelines that include all the technical, content, and design criteria for publishing an app on App Store
- Protecting the User’s Privacy standards on App Store
- App Store privacy policy you can use for reference while writing your app’s privacy policy
Google Play requirements for Android apps
If you develop an Android app, there are essential terms and agreements regarding personal data collection to be aware of:
- Google Play Developer Distribution Agreement (DDA): Outlines your responsibilities as a developer and explains how Google may use personal data it collects through your app.
- Google Privacy Policy: States that all personal data collected or used under the agreement must be managed in accordance with Google’s Privacy Policy.
- Firebase Data Processing and Security Terms: These terms are applicable when you use Google’s Firebase platform for your app development.
Similar to the Apple App Store requirements, Google Play requires developers to add an app privacy policy, referring to it as a “legally adequate privacy notice and protection for users.”
It should comply with both Google’s requirements and data protection laws relevant to where your app’s users are located, as well as following data minimization principles. User consent is also needed before collecting or processing personal information.
Google’s platform also gives app developers an option to make a separate contract with users regarding personal information access and use, which can override their privacy policy for mobile app. Also, Google Play asks developers to add a prominent disclosure in case users’ information is collected in the background without it being obvious that it’s happening.
The prominent disclosure should:
- Be placed in the app, in the app description, and on the website (as an app privacy policy) in a way that’s easy to access and for users to understand
- Describe data collection, usage, and sharing mechanisms
Where to place app privacy policy
App Store Connect & Google Play Console setup
In-app onboarding and menus
Website and app metadata
Consent banners and pop-ups
How to display and maintain your app privacy policy
Both Apple’s and Google’s app stores require developers to provide a link to a publicly accessible app privacy policy page or a text version within your app’s settings:
- Apple App Store: via App Privacy in the Apps menu
- Google Play: in the designated field in the Play Console
Here are the necessary steps to complete in Apple’s App Store Connect:
- Add your app privacy policy link in the Privacy URL field.
- Follow the instructions to provide details about your and third-party data collection practices.
- Select the exact personal information types used.
In the Google Play Console:
- In the Policy and Programs menu, go to the App Connect page and click Start to add the privacy policy URL.
- Add information about app security practices, along with details about ads, instructions for getting to the restricted parts of the app, and other information.
Upon publishing, both platforms require developers or publishers to regularly update the policy to reflect changes in apps’ functionality and data practices, and to ensure the language is clear and information provided is comprehensive and kept up to date.
Ways to display your apps privacy policy URL
Ways to display your apps privacy policy URL
In the Privacy policy URL field
While setting the app in Apple App Store Connect or Google Play Console.
In-app onboarding
Include a consent banner with the app privacy policy URL before users start sharing or submitting personal data.
Within the app
Add a link inside the app in Settings, About, Legal, or in the Privacy menu.
On the website
Host the privacy policy on a public website with an accessible URL linked from your app and any related web pages.
In pop-ups or consent banners
Request user consent and provide relevant information and links to additional details.
Common app privacy policy mistakes developers make
Adding a privacy policy for mobile app may seem an easy and quick task, but in practice, developers can disregard its importance or fail to provide relevant, up-to-date information for users and other stakeholders.
In this section, we’ll disclose the most common app privacy policy failures and misinterpretations with the ways to avoid them.
No app privacy policy URL
Some apps tend to keep the task of developing a privacy policy in their backlog, disregard its importance, or consider it too hard to make without legal input (which can be expensive).
Still, disclosing your app privacy policy is key to avoiding penalties and building user trust. It just needs to be clear and provide the required information to get you started, as well as be easily accessible. It can be updated as often as necessary.
Privacy policy for app copied and pasted from a competitor
Just because another organization’s apps or business is similar to yours doesn’t mean it’s a good idea to just copy their policy. Blind copying or making minimal edits on a policy from another source is not good practice. The risk of missing a necessary change or omitting important information for your users is high.
The best way to avoid this mistake is to engage qualified legal counsel or a privacy expert to help you draft a policy tailored to your needs. A solid foundation also makes updates easier.
You can start with a template, but be sure to customize it carefully and ensure it includes all the required sections and information.
Privacy policy is not clear or transparent
In many cases, apps struggle with making their privacy policy transparent, easy to understand, and to maintain accuracy. A policy that is vague, confusing, or hard to access means your apps privacy policy is unlikely to encourage user trust, and could put you in violation of regulatory requirements.
To avoid this mistake, make sure the language is clear and easy to understand, include all the essential information and keep it up to date, and ensure the privacy policy and/or URL are easily accessible from relevant places.