In the past, we have recommended that all mobile app
operators have a privacy policy that is readily-available to
consumers. Apple is now taking this advice one step further and requiring that all new apps, and any updates
to pre-existing apps, provide the app's privacy policy in the
app's metadata. The new app privacy policy rules will be
implemented on October 3, 2018, and, most likely, are being made in
response to Europe's new General Data Protection Regulation
("GDPR").
What should App Privacy Policies include?
Mobile App Privacy Policy Data Collection
If a mobile app collects any user personal information, the app
provider is required by applicable law to have an associated
privacy policy that discloses: 1) what personal information is
collected by the app; 2) what control the consumer has over how
this personal information is used; 3) what access the consumer has
to, and her/his ability to edit/delete, this information, if
necessary; 4) how the personal
