Apple App Store & Google Play Both Mandate a Privacy Policy
Before your app is approved for the App Store or Google Play, both platforms require a publicly accessible Privacy Policy. This is not optional — apps without one are rejected.
Your Privacy Policy must:
- Be publicly accessible: Linked from your app store listing, not hidden behind login
- Be specific to your app: Generic templates won't pass review
- Cover all data collection: Device permissions, analytics, third-party SDKs, everything
- Be updated regularly: If you add new features or integrations, update the policy within 30 days
COPPA: Children's Apps Have Stricter Rules
If your app is intended for or could be used by children under 13, the federal Children's Online Privacy Protection Act (COPPA) applies. This is serious — FTC violations carry fines up to $43,792 per violation.
COPPA Requires
- Parental consent: You must get verifiable parental consent before collecting data from anyone under 13
- Comprehensive Privacy Policy: Written in language parents can understand
- No tracking for advertising: You cannot use behavioral data to target ads to children
- Limited data collection: Collect only data necessary for the app to function
- Parental access rights: Parents can request access to or deletion of their child's data
If your app might appeal to children (even indirectly): Disclose in your Privacy Policy: "This app is suitable for children ages 8+. If your child uses this app, parental supervision is recommended."
Apple's App Privacy Labels & Your Privacy Policy
Apple requires all apps to complete "App Privacy Labels" — a standardized disclosure of data practices. Your Privacy Policy should align with what you claim in these labels:
Apple Privacy Label categories:
- Health and fitness
- Financial information
- Location
- Contacts
- User IDs (account identifiers)
- Search and browse history
- Usage data
For each category you declare, your Privacy Policy must explain specifically what data you collect and why.
CalOPPA: California's App Privacy Law (Most Apps Are Affected)
California's Online Privacy Protection Act (CalOPPA) applies to commercial websites and apps that collect personal information from California residents. Since most apps have CA users, this likely applies to you.
CalOPPA requires:
- A Privacy Policy linked from your app
- Disclosure of categories of personal information collected
- Disclosure of third-party sharing practices
- A way for users to request and obtain disclosure of data practices
If you have any significant user base, assume CalOPPA applies and write your Privacy Policy accordingly.
Device Permission Data: Location, Camera, Microphone Sensitivity
Mobile app permissions are legally sensitive in the US. Users must grant explicit permission, and you must explain why you need each one:
Location Data
"This app requests access to your precise location to [specific purpose]. Location data is stored [locally/on our servers] and used only for [purposes]. You can disable location access in Settings."
Camera and Microphone
"This app requests camera/microphone access to enable [feature]. Audio and video are not recorded unless you explicitly start recording. No data is stored or shared."
Contacts and Calendar
"If you grant access, we can import contacts/events. This data is used only for [purpose] and not shared with third parties."
Health and Fitness Data
Extremely sensitive. Disclose clearly: "This app accesses your Health/Fitness data only to [specific purpose]. Data is stored [locally/encrypted on servers] and never shared with third parties. You can revoke access anytime in Settings."
Analytics SDKs: Firebase, Amplitude, Mixpanel Disclosure
Most apps use analytics to track usage. You must disclose all SDKs:
- Google Firebase: Collects crash logs, event data, device identifiers, performance metrics
- Amplitude, Mixpanel, Segment: Behavioral analytics — track feature usage, user flows, custom events
- AppsFlyer, Adjust: Attribution and marketing analytics
- Sentry, Bugsnag: Error tracking and crash reporting
For each SDK: "We use [SDK Name] to track app analytics. This collects [data types]. See [SDK]'s Privacy Policy."
Advertising SDKs: AdMob, AppLovin, Unity Ads
If you show ads in your app, disclose the ad networks:
- Google AdMob: Collects device IDs, IP addresses, app usage. Google uses this for ad targeting.
- AppLovin: Collects behavioral data for personalized ads
- Unity Ads: Device ID, usage patterns for ad serving
"This app displays personalized ads from [Ad Network]. [Network] may collect data about your app usage for ad targeting. You can limit ad personalization in [app settings/device settings]."
In-App Purchases & Data Handling
If you offer in-app purchases (subscriptions, consumables):
- Who processes payments: "In-app purchases are processed by Apple/Google. We do not store payment details."
- What you receive: "We receive transaction IDs and subscription status to manage your account"
- Data retention: "Purchase data is retained for [12 months] for account management and support"
Push Notifications & Consent
Push notifications require system-level permission (iOS/Android shows a dialog). Your Privacy Policy should explain:
"We use push notifications to [purpose]. You can enable/disable notifications in [app settings/device settings]. Device tokens are collected to deliver notifications and are not shared with third parties."
Information to Prepare Before Generating
- Your app name and company name
- Platform(s): iOS, Android, or both?
- Target age group: Is it for children, teens, adults, or mixed?
- All device permissions requested: Location, camera, microphone, contacts, health, etc.
- All SDKs and libraries: Firebase, Amplitude, AppsFlyer, ad networks, crash reporters, etc.
- In-app purchases? What types (subscriptions, consumables)?
- Push notifications? What for?
- California users: Estimate what percentage of your user base is in CA
- User account features: Can users delete accounts? Export data?
- Third-party logins: Google Sign-In, Apple Sign-In, Facebook Login?
Official US Resources on Privacy Law & Compliance
The following government sources provide authoritative guidance on US privacy law requirements for your Privacy Policy:
- FTC Business Guidance: Privacy & Security — the Federal Trade Commission's official guidance on privacy notices, data security, and consumer protection obligations
- California AG: CCPA Official Text & Guidance — the California Attorney General's office resource on California Consumer Privacy Act requirements and enforcement
- FTC: COPPA Rule — required reading if your service may be used by children under 13