Building a mobile app is already complicated enough—design, development, testing, deployment. Then someone mentions you need a privacy policy, and suddenly you're navigating App Store guidelines, Play Store requirements, and platform-specific privacy features you barely knew existed.
I've seen app launches delayed over privacy policy issues. I've seen apps removed from stores for non-compliance. The stakes are real, and the requirements are more specific than what you'd need for a simple website.
Why Mobile Apps Face Different Requirements
Mobile apps have access to more data than websites. Your website can see what browser visitors use. Your app can potentially access contacts, photos, camera, microphone, precise location, health data, calendar, call logs, and much more.
This access makes privacy even more critical—and makes app stores very interested in ensuring users understand what they're agreeing to.
Additionally, apps have persistent presence on devices. A website visit is ephemeral; an installed app is always there, potentially collecting data in the background. This ongoing relationship demands ongoing transparency.
App Store Requirements
Apple App Store (iOS)
Apple has become increasingly aggressive about privacy. Their App Store Review Guidelines require a privacy policy for any app that collects user data—which is essentially every app.
Privacy Policy Requirement: You must have a privacy policy accessible from within the app and on your App Store listing. The policy must clearly explain what data is collected and how it's used.
App Privacy Labels: Since December 2020, all apps must provide privacy "nutrition labels" that appear on the App Store listing. These labels disclose data linked to the user, data used for tracking, and data not linked to the user.
You self-report this information, but Apple verifies submissions and can reject apps with inaccurate labels. Getting this wrong can result in app removal.
App Tracking Transparency (ATT): Apps must request user permission through the ATT framework before tracking across other apps and websites. Users can refuse, and a significant percentage do. Your privacy policy should explain any tracking you do.
Purpose Strings: When your app requests permission to access sensitive features (camera, location, contacts), you must provide a clear explanation of why. These "purpose strings" appear in the permission dialog. Vague or misleading explanations are grounds for rejection.
Google Play Store (Android)
Google has similar requirements, though the implementation differs:
Privacy Policy Requirement: Apps that handle personal or sensitive user data must have a privacy policy. This is enforced during submission, and apps without compliant policies can be rejected or removed.
Data Safety Section: Google introduced its own version of privacy labels in 2022. You must disclose what data your app collects, whether it's shared with third parties, security practices, and whether data can be deleted.
Permission Best Practices: Google expects apps to request only permissions they need and to request them contextually (when the feature is used) rather than upfront. Excessive permission requests can trigger review scrutiny.
Families Policy: Apps targeting children face additional requirements under Google's Families policy, including restricted data collection and advertising limitations.
What Your App Privacy Policy Must Cover
Beyond general privacy policy content, app-specific disclosures should include:
Device Permissions
Explain why you request each permission. Camera access for taking photos, location for mapping features, contacts for sharing content with friends—whatever you're asking for, explain it.
Local vs. Cloud Storage
Where does user data live? On the device only, on your servers, on third-party cloud services? Users increasingly want to know whether their data stays on their device.
Background Data Collection
If your app collects data while not actively in use—location tracking, health data monitoring, background sync—this needs explicit disclosure.
Push Notifications
If you send push notifications, explain what triggers them and how users can control them.
In-App Purchases and Subscriptions
While primarily a terms of service issue, the data collected for billing and subscription management should be disclosed in your privacy policy.
Third-Party SDKs
Mobile apps often include SDKs from analytics providers, advertising networks, crash reporting services, and other third parties. These SDKs collect data that your privacy policy needs to cover.
Major SDKs (Firebase, Facebook, Adjust, Crashlytics) each have their own data collection practices. You're responsible for disclosing what they collect through your app.
Account and Login
If users create accounts, explain what account data you collect and how it's used. If you support social login (Sign in with Apple, Google Sign-In), explain what data you receive from those services.
Platform-Specific Considerations
Apple's Privacy Focus
Apple has positioned privacy as a competitive advantage. Their requirements are stringent and getting stricter:
- Limit tracking enables users to disable ad tracking device-wide
- App Tracking Transparency creates friction for user tracking
- Sign in with Apple must be offered if other social logins are available
- Mail Privacy Protection affects email tracking for Apple Mail users
Your iOS privacy strategy needs to account for users who maximize these privacy features. Your app should function well even when users deny tracking and location access.
Android Privacy Features
Google has been following Apple's lead, though with somewhat less aggressive timelines:
- One-time permissions let users grant location or camera access for a single session
- Approximate location provides area-level rather than precise location
- Privacy dashboard shows users what permissions apps have used
- Auto-reset permissions remove permissions from unused apps
Design your app to work with minimal permissions and request sensitive access only when necessary.
Children's App Requirements
Apps directed at children face additional scrutiny on both platforms:
COPPA Compliance: If your app is directed at children under 13, COPPA applies. This means verifiable parental consent before collecting personal information, restrictions on advertising, and limitations on data sharing.
Apple's Kids Category: Apps in Apple's Kids category must not include advertising, analytics that track individual users, or links that navigate outside the app without parental gate.
Google's Designed for Families: Apps in this program must meet specific requirements around advertising, data collection, and content appropriateness.
Keeping Your Privacy Policy Accessible
Mobile privacy policies need to be genuinely accessible:
In-app access: Users should be able to find your privacy policy from within the app—typically in settings or a "Legal" section. Don't force them to go to a website.
Mobile-optimized: If linking to a web page, make sure it's mobile-friendly. A privacy policy that requires zooming and side-scrolling is technically accessible but practically useless.
Pre-download availability: Both app stores display your privacy policy on the app listing. Users can review it before downloading.
Updating for App Changes
Apps evolve faster than websites. New features, new SDK versions, new data collection—each can require privacy policy updates.
Feature releases: When adding features that collect new data or require new permissions, update your privacy policy before the release.
SDK updates: Third-party SDK updates can change data collection practices. Monitor major SDK changes for privacy implications.
Platform changes: When Apple or Google introduce new privacy requirements, you may need to update your policy (and potentially your app functionality) to comply.
User notification: For significant changes, consider in-app notifications that inform users and prompt them to review updated policies.
Common App Privacy Mistakes
Over-collecting permissions: Requesting permissions your app doesn't need is a red flag for reviewers and users alike.
Ignoring SDK data collection: You're responsible for what your SDKs collect. "We didn't know Firebase Analytics was tracking that" isn't an excuse.
Forgetting the app store listing: Having a great in-app policy but forgetting to link it in your store listing causes avoidable rejection.
Using a website policy template: Website privacy policies don't address app-specific concerns. Your app needs app-specific disclosures.
Missing privacy labels: Inaccurate or incomplete App Store privacy labels or Play Store data safety sections trigger review problems.
Final Thoughts
Mobile app privacy requirements might seem like bureaucratic overhead, but they exist because apps have significant access to personal information. Users deserve to understand what they're agreeing to when they install and use your app.
Get it right, and privacy compliance becomes a trust signal. Get it wrong, and you risk app rejection, removal, or user backlash. The investment in doing privacy properly is worthwhile.