App Privacy Policies

Our app privacy infographic provides both tips and a flow chart to help guide you on app privacy laws.

Note: A special thanks goes out to EvenSpring for helping create and doing the heavy lifting on this infographic.

3 Information Privacy Tips

  1. Don’t copy another privacy policy. This could result in you making false representations.
  2. Your employees, contractors, and agents must understand and follow both your privacy policy and practices.
  3. Speak with legal counsel ASAP if you access or store information of children under 13.

App Privacy Policy Requirements

At a minimum, privacy policies should address the following:

– what information is collected?

– how will information be used?

– who will have access to the information?

While it may be tempting to use a privacy policy generator or template, it’s a good idea to consult a professional if you’re investing a lot of money in your project, it your app accesses personal information, or if your app has unique features.

Apps that access or store consumers’ personal information (e.g. name, email address, location) must include a privacy policy to comply with Federal law. The Federal Trade Commission investigates companies and developers that release apps and either fail to notify or misinform consumers about company information privacy practices. Consequences can include a lawsuit, civil penalties, injunctions and years of administrative compliance requirements. Similarly, California and other states pursue claims against companies that mislead consumers.

10 App Privacy Scenarios

Review the following 10 scenarios to help determine whether a privacy policy may be required or not.

Scenario 1

  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is no, does your app integrate social media?
  • If the answer is no, a privacy policy may not be required.

Scenario 2

  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is no, does your app integrate social media?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

 Scenario 3

  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is yes, can you contact users with this info?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.
  •  Scenario 4
  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

Scenario 5

  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is no, does your app integrate social media?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

Scenario 6

  • Does your app access or store user info?
  • If the answer is no, does your app track user behavior (analytics)?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is no, does your app integrate social media?
  • If the answer is no, a privacy policy may not be required.

 Scenario 7

  • Does your app access or store user info?
  • If the answer is yes, can you contact users with this info?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

 Scenario 8

  • Does your app access or store user info?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

 Scenario 9

  • Does your app access or store user info?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is no, does your app integrate social media?
  • If the answer is yes, seek counsel regarding creating a privacy policy and developing privacy practices.

Scenario 10

  • Does your app access or store user info?
  • If the answer is yes, can you contact users with this info?
  • If the answer is no, can you identify users with this information?
  • If the answer is no, does your app integrate social media?
  • If the answer is no, a privacy policy may not be required.

Of interest: