Privacy & Information Security Law Blog

On August 30, 2018, Apple Inc. announced a June update to its App Store Review Guidelines that will require each developer to provide its privacy policy as part of the app review process, and to include in such policy specific content requirements. Effective October 3, 2018, all new apps and app updates must include a link to the developer’s privacy policy before they can be submitted for distribution to users through the App Store or through TestFlight external testing.

The privacy policy must detail what data the app gathers, how the data will be collected and how such data will be used. The policy also must confirm that third parties with whom an app shares user data will provide the same or equal protection of user data as stated in the app’s privacy policy and the App Store Review Guidelines. Lastly, the policy must explain the developer’s data retention policy, as well as include information on how users can revoke consent to data collection or request deletion of the collected user data. Developers only will be able to edit an app’s privacy policy when submitting a new version of the app.