Mobile App Privacy Policy Template

Masha Komnenic CIPP/E, CIPM, CIPT, FIP

by Masha Komnenic CIPP/E, CIPM, CIPT, FIP

May 10, 2023

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Mobile-App-Privacy-Policy-Template-01-01

Some data privacy legislation, like the General Data Protection Regulation (GDPR), require privacy policies for mobile apps that collect data, but they may also be mandated by app hosting platforms themselves, including Apple and Google.

Read on to learn if you need a mobile app privacy policy, what the requirements are for iOS and Android and, how to add one to your app.

Then you can download our free mobile app privacy policy template.

Table of Contents
  1. What Is a Mobile App Privacy Policy? 
  2. Do You Need a Privacy Policy for Your Mobile App?
  3. Current Applicable Laws for Mobile App Privacy Policies 
  4. Privacy Policy Requirements for iOS Apps 
  5. Privacy Policy Requirements for Android Apps
  6. General Privacy Policy Requirements for All Apps
  7. How To Give Users Access to Your App’s Privacy Policy
  8. Examples of a Good App Privacy Policy 
  9. How Do You Create a Mobile App Privacy Policy?
  10. Mobile App Privacy Policy Template for iOS and Android [Full Text and Download]
  11. Mobile App Privacy Policy FAQ
  12. Summary

What Is a Mobile App Privacy Policy? 

A mobile app privacy policy informs people about your data collection practices and discloses how your app gathers, stores, and uses personal information. 

Privacy policies for mobile apps should be accessible at all times and explicitly detail: 

  • What personal information (PI) is collected
  • How the personal information is collected 
  • Why you’re collecting the personal data 
  • Who you might share the data with or sell it to 
  • How users can control their data 

Clear, conspicuous, and easy-to-read privacy policies are mandated by all of the following data privacy laws from around the world:

  • General Data Protection Regulation (GDPR)
  • California Online Privacy Protection Act (CalOPPA)
  • California Consumer Privacy Act (CCPA)
  • California Privacy Rights Act (CPRA)
  • Virginia Consumer Data Protection Act (CDPA)
  • Children’s Online Privacy Protection Act (COPPA)
  • Personal Information Protection and Electronic Documents Act (PIPEDA)

Additionally, some app hosting platforms like Apple and Google require developers to post a privacy policy before publishing mobile apps. 

What Is Personal Information (PI)?

Personal information is a legal category of data protected by several data privacy laws. While the technical definition changes under each rule, it typically refers to any information that can directly or indirectly identify an individual

Read our personal information guide for more info.

How to Know If Your App Collects Personal Information

To know if your app collects personal information, conduct a privacy audit to identify each step within your app that requires PI, which might include the following instances:

  • Checkout process 
  • Email signup forms
  • Account registration page 

To ensure you don’t miss anything, take into consideration:

  • Each type of data category your mobile app collects
  • What data any third parties might collect that your app relies on
  • Specific common locations where data collection often occurs
  • Areas where consumers give voluntary consent to share the data

Here’s a helpful checklist of data questions to answer as you conduct your audit to create a compliant mobile app privacy policy:

  • Where it’s collected
  • Why it’s collected
  • How it’s stored
  • How it may be shared 
  • Who it’s shared or sold to

Do You Need a Privacy Policy for Your Mobile App?

The simple answer is yes.

You need a privacy policy if your mobile app falls under the following situations:

  • Your app collects personal data
  • Your app uses a third-party service provider
  • You fall under the jurisdiction of any data privacy laws
  • The iOS or Android platform requires one
  • You want to reassure your app’s users
  • You want to err on the side of caution

A privacy policy for your app isn’t just a way to meet legal requirements. It’s also a good way to:

  • Reassure your users
  • Anticipate changes

Mobile App Privacy Policies Reassure Your Users

Recently, we’ve seen an increase in data breaches, so it makes sense that privacy is a growing concern among consumers. Posting a mobile app privacy policy helps ease your users’ concerns and give them confidence in your app because they’ll know their personal information is safe.

Just take a look at these alarming data privacy statistics emphasizing the importance for companies to be honest about their data collection practices:

  • 84% of users are more loyal to companies with strong security controls. (Salesforce)
  • 54% of users say it’s harder than ever for companies to earn their trust. (Salesforce)
  • 39% of users would likely turn away from a company that required them to provide highly personal information. (Akamai)

Transparency builds trust. Retain more customers by publishing a privacy policy for your app. 

Mobile App Privacy Policies Anticipate Changes

As data protection laws related to mobile applications continue to expand, the definition of PI can change, and privacy policies are a great place to explain that information to your consumers.  

For example, the CPRA came into force on January 1, 2023, and introduced a new category of sensitive personal information subject to stricter privacy requirements. 

Similarly, ways to determine an individual’s identity through an IP address have progressed far enough that it was added to the GDPR’s list of protected personal information.

Do You Need a Privacy Policy for iOS Apps?

Yes, you’re required to post a privacy policy when developing apps for iOS.

Regardless of if you fall under any privacy laws, Apple mandates in their App Store Review Guidelines that all mobile app developers must include a privacy policy in an iOS application. 

We’ve highlighted the relevant text in a screenshot for you below.

Apple-App-Store-Review-Guidelines

Do You Need a Privacy Policy for Android Apps?

Yes, as of April 22, 2022, every application published by the Google Play Store must have a privacy policy that declares how it collects, protects, and handles private user data.

Below, see a screenshot of Android’s mobile app privacy policy guidelines from the Google Play Console help center.

Google-Play-Console-help-center

Current Applicable Laws for Mobile App Privacy Policies 

Currently, all of the following data privacy laws from across the globe impact or require you to have a privacy policy:

  • The General Data Protection Regulation (GDPR)
  • The California Consumer Privacy Act (CCPA)
  • The California Privacy Rights Act (CPRA)
  • The California Online Privacy Protection Act (CalOPPA)
  • The Virginia Consumer Data Protection Act (CDPA)
  • The Children’s Online Privacy Protection Act (COPPA)
  • Privacy Rights for California Minors in the Digital World 
  • Student Online Personal Information Protection Act

Let’s discuss the requirements of each of these laws in the following sections.

The General Data Protection Regulation (GDPR)

If your app is available to those in the EU, you’re subject to comply with the GDPR. Compliance starts with a comprehensive mobile app privacy policy that details what, how, when, with whom, and where data is collected.

Below, see an example of how the Walt Disney Company complies with the GDPR rules by creating an easy-to-read menu that can be quickly found and understood.

Walt-Disney-Company-GDPR

 

The GDPR also mandates that businesses give users the capability to revoke consent, and access or delete data.

Below see how Google outlines easily accessible methods for their users to export their data or delete it entirely.

Google-outlines-accessible-methods-users-export-data

 

Ignoring the GDPR and not having a privacy policy for your app can get you fined up to €24 million ($23 million) or 4% of your app’s annual global revenue. 

The California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA)

In January 2023, the California Privacy Rights Act (CPRA) amended the California Consumer Privacy Act (CCPA), and together these make a single data privacy law that regulates how businesses worldwide can handle the personal information of California residents.

Under the amended CCPA, businesses must provide app users with a privacy policy that discloses:

  • All consumer rights
  • How consumers can request to delete, access, or change their personal data
  • How minors or their legal guardians under age 16 can opt out of the sale of their personal data

All companies that serve California residents must comply with the CCPA as amended if they:

  • Have at least $25 million or more in annual revenue
  • Collect, share, buy, or sell the personal data of 100,000 or more consumers or households
  • Collect more than half of their revenues from the sale of personal consumer data

The CCPA with the CPRA amendments carries fines of $2,500 per unintentional violation, up to $7,500 per intentional violation, or any violation involving minors. 

Consumers also have the right to pursue private legal action against you if their data is breached or their login credentials have been compromised due to your lack of security measures. 

The California Online Privacy Protection Act (CalOPPA)

The original US law that privacy policies was the California Online Privacy Protection Act or CalOPPA. It applies to any business, including those running mobile apps. 

According to CalOPPA, a privacy policy for a mobile application must:

  • Provide information about modifications and how they will be made
  • Give information about any third-parties collecting user data
  • Be presented as a link from the mobile app’s homepage, which must contain the word “privacy”

Failure to comply with CalOPPA results in fines of up to $2,500 per each individual violation, meaning fines over a quarter of a million dollars can easily be levied against a small mobile app company that reaches only 100 users per week.

The Virginia Consumer Data Protection Act (CDPA)

In January 2023, the US state of Virginia introduced the Consumer Data Privacy Act (CDPA), requiring mobile app developers to post a clear, reasonably accessible, and meaningful privacy notice.

To comply with the CDPA, your mobile app privacy policy must specify all of the following:

  • The purpose of processing personal information
  • Categories of data processed
  • Types of data shared with third parties
  • Categories of data sold to third parties
  • Disclose the categories of third parties themselves
  • Information about how consumer requests can be submitted
  • A mechanism for appealing decisions related to consumer requests
  • Clearly disclose the processing of personal data for targeted advertising
  • The right to opt out of the processing of personal data

Your app falls under the CDPA if you do business in Virginia and meet one of the following:

  • Handle or control the personal data of 100,000 Virginia consumers
  • Derives 50% of your gross annual revenue from selling personal data and handling or controlling the personal data of 25,000 Virginia consumers

Fines for non-compliance include potential injunctions and civil penalties up to $7,500 per violation, plus attorney fees.

The Children’s Online Privacy Protection Act (COPPA)

To help protect children’s privacy and keep them safe online, the Federal Trade Commission (FTC) enforces the Children’s Online Privacy Protection Act (COPPA), which requires websites, mobile apps, and other online services to post compliant privacy policies and obtain consent from parents before collecting PI from minors.

‌COPPA is why many websites and apps don’t allow users under 13 to access the content or register an account.

In addition to requiring privacy policies, COPPA imposes fines on companies that fail to follow the guidelines. In 2019, YouTube was issued a COPPA fine of $170 million for illegally harvesting children’s personal data and targeting ads at kids without consent from legal guardians. 

Privacy Rights for California Minors in the Digital World 

The Privacy Rights for California Minors in the Digital World Act, also called the Eraser Button law, applies to websites and mobile applications that allow users under 18 to register and post content.

It states that these websites and mobile apps must allow users under 18 to remove their content or information whenever they want and they must be clearly informed of their rights to do so.

Student Online Personal Information Protection Act 

The Student Online Personal Information Protection Act or SOPIPA applies to the online collection of the personal information of K-12 students in California.

The law states that any information gathered from students cannot be used for targeted advertising and can’t be sold or disclosed without express authorization.

Privacy Policy Requirements for iOS Apps 

To help you make a privacy policy for an iOS app, we’ve created this step-by-step guide following the requirements outlined by Apple.

  • Step 1: Determine which data privacy laws apply to your app
  • Step 2: Identity what personal information your app collects
  • Step 3: Outline how and why you collect and use personal information
  • Step 4: Verify any third parties you rely on comply with Apple’s policies
  • Step 5: Outline your data retention and deletion policies 
  • Step 6: Where to display your iOS mobile app privacy policy

Let’s go over each step in more detail. 

Step 1: Determine Which Data Privacy Laws Apply To Your App

When developing a mobile app for iOS, you need to follow the guidelines outlined by Apple and any relevant data privacy laws your business falls under, so you must determine what those laws are.

To help you get started, check out our guides to learn about the different data privacy laws in the US and the major privacy laws from around the globe

Step 2: Identity What Personal Information Your App Collects

The highlighted text in the screenshot below comes from Apple’s App Store Review Guidelines and clearly states that it’s your responsibility to identify what data your app collects.

Apple-App-Store-Review-Guidelines-states-responsibility-identify-data-app-collects


To do this, perform a privacy audit following the instructions we covered previously. Once you’ve determined all types of information you collect from users, you can move on to Step 3. 

Step 3: Outline How And Why You Collect And Use Personal Information

As part of their App Store Review Guidelines, Apple still requires that you explain how and why your app collects and uses personal data, even if you don’t fall under any data privacy laws.

To comply, include these details within a clause in your mobile app privacy policy. 
Below, see how Uber explains what information their app collects, how it collects that data, and all uses of the data in their iOS app privacy policy.

Uber-iOS-app-privacy-policy

Step 4: Verify Any Third Parties You Rely On Comply With Apple’s Policies

Apple states that it’s up to the app developer to confirm if third parties your app shares data with provide the same level of privacy protection and comply with the App Store Review Guidelines, shown for you in the screenshot below.

Apple-App-Store-Review-Guidelines

 

Put a clause in your mobile app privacy policy that clearly explains who you share the data with and what privacy precautions they provide over that user data.

Step 5: Outline Your Data Retention And Deletion Policies 

To abide by Apple’s App Store Review Guidelines, you must also explain your data retention and deletion policies and inform consumers how they can redact consent or request to delete their data.

Look at the screenshot below to read the exact phrasing from Apple.

Apple-App-Store-Review-data-retention


You can achieve this by creating distinct clauses in your app’s privacy policy that explains how long you securely store data, how users can request to delete that data, and how they can update their opt-out preferences. 

Below, see how Zoom handles their data retention clause in their mobile app privacy policy.

Zoom-data-retention-mobile-app-privacy-policy

Step 6: Where to Display Your iOS Mobile App Privacy Policy 

Once you’ve made your iOS mobile app privacy policy, you should post it in the following places:

  • In the Apple App store
  • Directly within the app itself

Common places to put a privacy policy within a mobile app include a Legal page, within the account Settings, or on an About page. Whenever possible, you should also link to your privacy policy wherever any data collection occurs, like:

  • Payment screens
  • New user account creation pages 

You’re required to link to your privacy policy in the App Store itself, which must be hosted in a URL. 

To do this, paste the link to your privacy policy in the Privacy Policy URL field in your App Store Connect dashboard. Once approved, your iOS app will be able to officially go live. 

Privacy Policy Requirements for Android Apps

To help you post a compliant privacy policy for Android apps, we’ve outlined steps to follow when publishing an app on the Google Play Store.

  • Step 1: Determine which data privacy laws apply to your app
  • Step 2: Identity what personal information your app collects
  • Step 3: Outline how and why you collect and use personal information
  • Step 4: Verify any third parties you rely on comply with Google’s policies
  • Step 5: Follow additional guidelines if you collect sensitive personal information
  • Step 6: Pay attention to the Google Play Policies updates timeline
  • Step 7: Where to display your Android mobile app privacy policy

Step 1: Determine Which Data Privacy Laws Apply To Your App

When developing an app for an Android device, you must follow the guidelines outlined by the Google Play Store and any data privacy laws that apply to you.

So take the time to research and identify all relevant laws that affect how your app collects, stores, and uses personal user data. 

Step 2: Identity What Personal Information Your App Collects

According to Google’s Developer Policy Center, all app developers must clearly and accurately complete a Data Safety Section that details the collection, use, and sharing of personal data.  

As shown in the screenshot below, it’s your responsibility to maintain the accuracy of that information and keep it up-to-date.

Google-Data-Safety-Section

Step 3: Outline How And Why You Collect And Use Personal Information

Google clearly states that app developers are responsible for disclosing the access, collection, use, handling, and sharing of personal user data, as shown in the screenshot below.

Google-disclosing-access-collection-use-handling-sharing-personal-user-data

 

Later on, they distinctly state that all apps must post a privacy policy link that comprehensively explains the relevant details, shown below.

Google-apps-post-privacy-policy-link

 

So even if you don’t fall under any privacy laws or your app doesn’t collect PI, you still need a privacy policy stating as much for your app to pass Google’s security and privacy requirements. 

Step 4: Verify Any Third Parties You Rely On Comply With Google’s Policies

Like Apple, Google also states that it’s up to the app developer to verify that any third parties that gain access to user data comply with the policies outlined in their Developer Policy Center, shown in the screenshot below.

app-developer-third-parties-gain-access-user data

 

Put this information in a clause in your privacy policy and explain what process you use to ensure the services your app relies on also protect and respect your users’ data. 

Here’s an example of this type of clause from TikTok, who hosts an app on the Google Play Store.

TikTok-type-of-clause-Google-Play-Store

Step 5: Follow Additional Guidelines If You Collect Sensitive Personal Information

Google also explains how app developers must handle collecting, processing, and using sensitive personal information, which refers to a category of data that is more vulnerable than basic personal information. 

Some data privacy legislation, like the GDPR and the amended CCPA, have stricter requirements for collecting and using this type of data, and users have more rights over how and if that information gets tracked or used. 

Google’s policies, pictured below in a screenshot, seem to reflect these guidelines.

Google-Sensitive-Personal-Information

Step 6: Pay Attention To The Google Play Policies Updates Timeline

If you’re developing Android apps, pay close attention to the policy change timeline outlined in the Updates to Google Play Policies, as they’re updated frequently. 

The screenshot below explains new requirements Google is introducing throughout 2023.

Android-apps-policy-change-timeline

Step 7: Where To Display Your Android Mobile App Privacy Policy

According to Google’s guidelines, pictured in the screenshot below, you must display your Android app privacy policy in the designated field within the Play Console and link to it within the app itself.

Google-guidelines-display-Android-app-privacy-policy


According to their guidelines, your mobile app’s privacy policy must be hosted on an active, publicly accessible, non-geofenced URL that is non-editable, so this means no PDFs. 

You can host your policy on a page on your website or use a Privacy Policy Generator that hosts it for you, like ours. 

Then, follow these four easy steps:

  1. Once you’ve made your app’s privacy policy, log into your Google Play Console, then click on the app you wish to add the policy to. 
  2. Locate the Policy section in the menu bar on the left side of the screen, and select the App content option. There you will find a Privacy Policy section and should choose Start.
  3. On the next page, there will be a field where you can copy and paste your mobile app’s privacy policy URL. 
  4. Then all you need to do is hit Save in the top left corner of your screen, and your privacy policy is officially added to the correct field in the Google Play Store.  

Remember, you also need to post a link to your privacy policy URL in the app itself or at least share the text version of the policy. So we recommend putting it on a Legal page, About page, or within the app’s Settings.  

Depending on the type of app you create, you might also consider posting it wherever any data collection occurs, including any payment screens or new user account creation pages. 

General Privacy Policy Requirements for All Apps

To make your app’s privacy policy comprehensive and user-friendly, it should contain the following information in distinct clauses:

  • Types of personal information you collect
  • How you use and share personal information
  • Disclosure of your use of any third-party services
  • Explain users’ control and rights over their data
  • Describe how you’ll update users about changes to your policy

Let’s further discuss these clauses in the next sections. 

Types of Personal Information You Collect

Privacy policies often begin by explaining the types of data that an app collects from users. Be as detailed as possible about the PI you collect.

In the screenshot below, see a great example of this clause from Spotify’s privacy policy. They structure the PI they collect into categories within an easily readable table.

Spotify-privacy-policy


The Spotify example above presents a sweeping model for structuring such a clause within your privacy policy for mobile apps. 

How You Use and Share Personal Data

In addition to revealing the type of data you collect, you must explain how it gets used, which must fit the specific legal basis outlined by data privacy regulations like the GDPR. 

Be sure to organize this information in a clear, understandable way, perhaps by using a table or a bullet list.

Below, see an example of this clause from Uber’s mobile app privacy policy.

Uber-mobile-app-privacy-policy

Third-Party Services

If you share data with third-party services, your mobile app privacy policy must reveal how and why.

Third-party tools and providers can enhance your apps through:

  • Content optimization 
  • Better customer service
  • Data Analytics
  • Affiliate marketing
  • Lead generation

See how Twitter’s privacy policy outlines the kinds of data they share with third-parties.

Twitter-privacy-policy-outline

 

If you use similar services, like Google Analytics, disclose those details in a clause in your app’s privacy policy, or you risk non-compliance with regulations like the GDPR.

Describe How Users Can Control Their Data

You must outline how users can control their personal information in a clause within your mobile app privacy policy.

Control over a user’s data has become a key concern for online businesses as they strive to comply with regulations like the GDPR and the amended CCPA. Almost by default, privacy policies have become instruction manuals for how users can exercise their data rights.

Include steps your users can take to access, transfer, change, delete, correct, amend, export, or limit the use of their information.

Below, see another example from Zoom, as they clearly describe the rights users have under the CCPA and other laws.

Zoom-users-rights-CCPA-and-other-laws

Update Users of Policy Changes

Establish a process for how you’ll inform your app users about any changes you make to your privacy policy, and explain those details in a specific clause. 

Data privacy laws change often, and as a result, you may need to update your policy. 

Publish the date of the last changes near the top of your policy, and reassure users that any significant changes will be presented prominently and emailed to the user.

Below, see the way TikTok explains how they update users about changes to their privacy policy.

TikTok-update-users-changes-to-privacy-policy

Inform Mobile Users If They Are Being Tracked

You need to explain if your mobile app uses cookies or other trackers, which ones, what data they collect, and why in a clause in your privacy policy because cookies qualify as personal information under legislation like the GDPR and the amended CCPA. 

You should also post a cookie policy on your website and link it in your mobile app privacy policy and vice-versa to help consumers find answers to questions regarding their personal information.

Below, see an example clause from the Walt Disney Company, who are careful to inform their users of their tracking policies.

Walt-Disney-Company-inform-users-tracking-policies

How To Give Users Access to Your App’s Privacy Policy

To give users access to your mobile app privacy policy, link to it in the following locations:

  • Embedded directly in your app
  • Linked to a dedicated webpage
  • On the app store

Embed Directly in the App

Dedicate a space within your mobile app to display your privacy policy so users can easily navigate to it at any time.

Sharing the link like this ensures that users are aware of its presence, that all legal policies are only a few clicks away, and they can consult it at any time without being inconvenienced.

Link to a Dedicated Webpage

Many developers use an app privacy policy URL to link to the policy within the app itself, and give users access to it by publishing a hyperlink containing the word “privacy.”

Clicking the link opens the privacy policy in a new internet browser window which may be hosted by a third party or part of the company’s website.

If your company has a website, using the same policies for both is good practice.

In The App Store

You can also include a link to your policy on your app’s profile page in whichever app store you choose to sell your product. 

Not only is this required by both Apple and Google, but it also allows users to view your policy before downloading your application.

iOS

For iOS apps, remember that Apple requires developers to include a link to a privacy policy in the following locations:

  • In the Apple App store
  • Directly within the app itself

This applies to any app developed for Apple, even if you don’t fall under any data privacy laws.

Android

Google requires anyone who develops apps for Android devices to put a privacy policy in the following locations:

  • The designated field within the Play Console
  • Link to or put the actual text of the policy within the app itself

According to their guidelines, you must host your privacy policy on an active, publicly accessible, non-editable, and non-geofenced URL. 

Examples of a Good App Privacy Policy 

We’ve outlined several examples of privacy policies for mobile apps in the following sections. 

Instagram’s Mobile App Privacy Policy

The first mobile app privacy policy example we’re showcasing comes from Instagram. Owned by Meta, they use identical policies for all of their services and mobile applications. 

To find their privacy policy in the app, navigate to the Settings section and select About.

Once there, select Privacy Policy to view the current version of the agreement directly within the app itself, screenshotted for you below.

Instagram-Mobile-App-Privacy-Policy


Meta as a whole adopted a more up-front, user-friendly approach to its legal policies in response to public concerns over the sharing of personal information.

The policy is now formatted in a frequently asked questions (FAQ) format, which is easy to read.

Below, see an example of a clause in their policy outlining what information they collect, which even features a short video.

Instagram-policy-clause-outlining-information-they-collect-short-video

 

The policy then explains how that personal information gets used by Instagram, Facebook, and Meta, which is still organized in an FAQ style, as shown below.

Instagram-Facebook-Meta-FAQ-style

 

While adding videos is a nice touch, it’s unrealistic for most businesses. However, when you make your privacy policy for your mobile app, try to be consistent with your formatting, like Instagram. 

Spotify

The next mobile app privacy policy sample comes from Spotify, a music streaming service.

You can find Spotify’s privacy policy in the app by navigating to Settings and selecting About, pictured below.

Spotify-privacy-policy-in-app-Settings


We like how Spotify organizes the information in their privacy policy using very easy-to-read tables. 

Below, see what their clause featuring a table explaining what data they collect looks like through their app.

Spotify-privacy-policy-easy-to-read-tables


We also like how Spotify clearly informs their users how they’ll be updated about any changes to the policy, shown for you in the screenshot below.

Spotify-informs-users-updated-changes-to-policy


This is a necessary clause to add to your mobile app privacy policy, especially because under laws like the amended CCPA, you must update your policy at least once every 12 months.  

Snapchat

Next, we’ll look at the mobile app privacy policy from Snapchat, a service that is exclusively on mobile devices and allows for taking, editing, and sharing photos. 

To navigate to their privacy policy within the app, go to your Settings and scroll down until you see the following options we’ve screenshotted below.

Snapchat-mobile-app-privacy-policy


If you click on Privacy Policy, you’ll find that it’s clearly laid out and very approachable. 

Below, see an example of Snapchat’s clause explaining what they do with data they collect that is provided by the consumer.

Snapchat-clause-data-collection


We like how Snapchat includes a clause covering their use of cookies and other trackers directly in their privacy policy, shown below.

Snapchat-clause cover-cookies-trackers-privacy-policy


Off-screen, there’s a live link to their cookie policy. If your mobile app uses cookies or trackers, understand that some of that data qualifies as personal information under data privacy laws and is subject to legal requirements and guidelines. 

Like Snapchat, it’s in your best interest to provide a link to your cookie policy within your privacy policy for your mobile app. 

Pizza Hut

Lastly, let’s consider the Pizza Hut mobile app privacy policy, which you can find within the app by navigating to your Profile and selecting Legal Information.

Once there, you can also access the CCPA-compliant “Do Not Sell My Personal Information” link, pictured below.

Pizza-Hut-mobile-app-privacy-policy


Because Pizza Hut has physical locations, they include a clause in their policy outlining what information is collected about their consumers who come into their brick-and-mortar storefronts, shown below.

Pizza-Hut-policy-outlining-information-collected-consumers

 

Pizza Hut includes a clause outlining what parents and guardians can do if they suspect the company accidentally collected information about children, because they don’t target services to minors.

Pizza-Hut-collected-children-information

 

Even if you don’t market to minors, follow Pizza Hut’s lead and put a similar clause in your mobile app privacy policy.

This helps remove liabilities from your plate and creates a straightforward, easy-to-follow process if you ever find out you’ve accidentally collected information about children.

How Do You Create a Mobile App Privacy Policy?

There are a few common ways you can make a mobile app privacy policy, including trying a:

  • Managed solution
  • Mobile app privacy policy template
  • Do-it-yourself (DIY) approach

Let’s go over each method in a little more detail.

Managed Solution

If you want to create a mobile app privacy quickly and efficiently, use a managed solution like our Privacy Policy Generator

Privacy policies are long documents that must follow strict legal requirements, and our generator simplifies the entire process for you.

All you need to do is answer a few simple questions about your app, and it’ll create a privacy policy for your app that abides by all of the laws and regulations we covered in this guide. 

See a screenshot of our generator below.

Termly-Privacy-Policy-Generator

Mobile App Privacy Policy Template

You can also use our free mobile app privacy policy template

Templates are convenient and easy to use. After downloading the policy, you just need to fill in the blanks with information about your mobile app. 

Why Use a Mobile App Privacy Policy Template?

We recommend using a template to make a privacy policy for your app, because it benefits you in the following ways:

  • Benefit #1: Mobile app privacy policy templates are free to download and customize, which allows you to save money but still create a policy that fits your app’s needs
  • Benefit #2: Using a template for your mobile app privacy policy ensures that some initial writing is done for you, saving you time
  • Benefit #3: A good template, like ours, includes the most common mobile app clauses and are already structured in a way that’s easy for users to read and follow along with

Remember, if you’re short on time or need help adhering to multiple data privacy laws, try out our Privacy Policy Generator. All you need to do is answer a few questions about your business, and it creates a compliant policy for you in minutes. 

If you get stuck, you can always reach out to our support team or hit save and come back at a more convenient time. 

DIY Approach

You can always try writing your app’s privacy policy on your own, but this is only recommended if you have extensive knowledge about data privacy legislation.

You can access our guide to learn how to write a privacy policy on your own, but we recommend working with a data privacy expert or lawyer.

Mobile App Privacy Policy Template for iOS and Android [Full Text and Download]

You can download our free mobile app privacy policy template below in Word Doc, PDF, or Google Doc format. You can also just copy & paste the HTML directly to your website.

Before using it, read through the entire mobile app privacy policy template – fill in all of the [brackets], remove any sections that do not apply to your app, and tweak any language as needed.

App Privacy Policy [Text Format]

PRIVACY NOTICE

Last updated [Date]

This privacy notice for [Company Name] (doing business as [Company Short Name]) ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at [Website URL], or any website of ours that links to this privacy notice
  • [Download and use our application(s), such as our mobile application — [Mobile App Name], our Facebook application — [Facebook App Name], or any other application of
Full View


Mobile App Privacy Policy Template HTML

You can copy our app privacy policy template HTML code or download it using the options below.

App Privacy Policy [Text Format]

PRIVACY NOTICE

Last updated [Date]

This privacy notice for [Company Name] (doing business as [Company Short Name]) (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

  • Visit our website at [Website URL], or any website of ours that links to this privacy notice
  • [Download and use our application(s), such as our mobile application — [Mobile App Name], our Facebook application — [Facebook App Name], or any other application of ours that links to this privacy notice]
  • Engage with us in other related ways ― including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [Email Address].

This privacy policy was created by Termly’s Privacy Policy Generator.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with [Company Name] and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? [We do not process sensitive personal information. / We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.]

Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here: [DSAR Form URL], or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what [Company Name] does with any information we collect? Review the notice in full below.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you [register on the Services,] express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • [Personal Info Collected]
  • [Personal Info Collected]
  • [Personal Info Collected]

Sensitive Information. [We do not process sensitive information. / When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • [Sensitive Info Collected]
  • [Sensitive Info Collected]
  • [Sensitive Info Collected]]

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by [Vendor Name]. You may find their privacy notice link(s) here: [Vendor Privacy Policy].

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

[Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, own, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.]

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: [Cookie Notice URL].

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
  • [Other]

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

[Information collected when you use our Facebook application(s). We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.]

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: [Cookie Notice URL].
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
  • [Other]

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Send users information about special offers and discounts on our products and services
    • Develop and display personalized and relevant advertising content for our users
    • Analyze how our services are used so we can improve them to engage and retain users
    • Support our marketing activities
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and services so we can improve user experience
    • [Other]
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

  • Ad Networks
  • Affiliate Marketing Programs
  • Cloud Computing Services
  • Communication & Collaboration Tools
  • Data Analytics Services
  • Data Storage Service Providers
  • Finance & Accounting Tools
  • Government Entities
  • Order Fulfillment Service Providers
  • Payment Processors
  • Performance Monitoring Tools
  • Product Engineering & Design Tools
  • Retargeting Platforms
  • Sales & Marketing Tools
  • Social Networks
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers
  • [Other]

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: [List of Information Collected], and other similar information. A full list of what we use information for can be found in this section and in the previous section titled “HOW DO WE PROCESS YOUR INFORMATION?”. [We obtain and store on your device (‘cache’) your location for [#] months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein and Norway) or the United Kingdom, please take a look at our Cookie Notice, which can be found at this link: [Cookie Notice URL].
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users. When you share personal information [(for example, by posting comments, contributions, or other content to the Services)] or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
  • Offer Wall. Our application(s) may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services, [including our offer wall], may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: [Cookie Notice URL].

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in [Countries where Server is Located]. If you are accessing our Services from outside [Countries where Server is Located], please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in [Countries where Third-Party Servers are Located], and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: [Standard Contractual Clauses URL]. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Binding Corporate Rules:

These include a set of Binding Corporate Rules (“BCRs”) established and implemented by [Company Name]. Our BCRs have been recognized by EEA and UK data protection authorities as providing an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here: [BCRs URL].

[EU-US] and [Swiss-US] Privacy Shield Framework[s]

[Company Name] and the following entities and subsidiaries: [List of Entities/Subsidiaries] comply with the [EU-US] and [Swiss-US] Privacy Shield Framework[s] as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from [the European Union (EU)], [the UK], and [Switzerland] to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of [EU] and [Swiss] data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, [Company Name] will continue to comply with the principles of the [EU-US] and [Swiss-US] Privacy Shield Framework[s]. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To view our certification, please visit [Privacy Shield Certification URL].

[Company Name] adheres to and complies with the Privacy Shield Principles when processing personal information from [the EU], [UK], or [Switzerland]. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework[s], [Company Name] is subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have any questions or concerns relating to [Company Name]’s Privacy Shield certification, please write to us at the contact details below. We commit to resolving any complaints or disputes about our collection and use of your personal information under the Privacy Shield. [However, if you have an unresolved complaint in connection with our certification, we commit to cooperating with the panel established by [the EU data protection authorities (DPAs)], [the UK Information Commissioner], and [the Swiss Federal Data Protection and Information Commissioner], as applicable, and to comply with the advice given by them in respect of the complaint. Click here for a list of EU DPAs. / However, if you have an unresolved complaint in connection with our certification, you may contact our independent dispute resolution provider based in the [EU/United States], [Dispute Resolution Provider Name]. Please visit [Dispute Resolution Provider URL] for more information or to file a complaint. These services are provided to you free of charge.]

In limited situations, [EU], [UK], and [Swiss] individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Please be sure to review the following sections of this Privacy Notice for additional details relevant to [Company Name]’s participation in the [EU-US] and [Swiss-US] Privacy Shield:

  • WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data [Company Name] collects.
  • HOW DO WE PROCESS YOUR INFORMATION? To learn more about the purposes for which [Company Name] collects and uses personal information about you.
  • WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? To learn more about the type or identity of third parties to which [Company Name] discloses personal information, and the purposes for which we do so.
  • WHAT ARE YOUR PRIVACY RIGHTS? To learn more about the right of individuals to access their personal data.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than [the period of time in which users have an account with us / [#] months past the termination of the user’s account / [#] months past the start of the idle period of the user’s account / other].

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [Email Address].

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, [Other] or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.
  • [Other]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: [Cookie Notice URL].

If you have questions or comments about your privacy rights, you may email us at [Email Address].

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

 

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name [YES/NO]
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information [YES/NO]
C. Protected classification characteristics under California or federal law Gender and date of birth [YES/NO]
D. Commercial information Transaction information, purchase history, financial details, and payment information [YES/NO]
E. Biometric information Fingerprints and voiceprints [YES/NO]
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements [YES/NO]
G. Geolocation data Device location [YES/NO]
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities [YES/NO]
I. Professional or employment-related information Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us [YES/NO]
J. Education Information Student records and directory information [YES/NO]
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics [YES/NO]
L. Sensitive personal information Account login information, drivers’ licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation [YES/NO]

 

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A – [Retention Period]
  • Category B – [Retention Period]
  • Category C – [Retention Period]
  • Category D – [Retention Period]
  • Category E – [Retention Period]
  • Category F – [Retention Period]
  • Category G – [Retention Period]
  • Category H – [Retention Period]
  • Category I – [Retention Period]
  • Category J – [Retention Period]
  • Category K – [Retention Period]
  • Category L – [Retention Period]

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

[Company Name] collects and shares your personal information through:

  • Targeting cookies/Marketing cookies
  • Social media cookies
  • Beacons/Pixels/Tags
  • Click redirects: [Click Redirects]
  • Social media plugins: [Social Media Plugins]. We use social media features, such as a “Like” button, and widgets, such as a “Share” button in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.
  • [Other]

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: [Cookie Notice URL].

[You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage.]

You may contact us by email at [Email Address], by calling toll-free at [Phone Number], by visiting [Contact Form URL], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

[Company Name] has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

  • Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
  • Category E. Biometric information, such as fingerprints and voiceprints.
  • Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
  • Category G. Geolocation data, such as device location.
  • Category H. Audio, electronic, visual, and similar information, such as images and audio, video, or call recordings created in connection with our business activities.
  • Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
  • Category J. Education information, such as student records and directory information.
  • Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
  • Category L. Sensitive personal information, such as account login information, drivers’ licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“.

[[Company Name] has not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. / [Company Name] has sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

  • Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
  • Category E. Biometric information, such as fingerprints and voiceprints.
  • Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
  • Category G. Geolocation data, such as device location.
  • Category H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
  • Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
  • Category J. Education information, such as student records and directory information.
  • Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
  • Category L. Sensitive personal information, such as account login information, drivers’ licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation.

The categories of third parties to whom we sold personal information are:

  • Ad Networks
  • Affiliate Marketing Programs
  • Data Analytics Services
  • Retargeting Platforms
  • Social Networks
  • User Account Registration & Authentication Services
  • [Other]

The categories of third parties to whom we shared personal information with are:

  • Ad Networks
  • Affiliate Marketing Programs
  • Data Analytics Services
  • Retargeting Platforms
  • Social Networks
  • User Account Registration & Authentication Services
  • [Other]]

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, sharing, or selling personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

[We do not process consumer’s sensitive personal information. / If the business collects any of the following:

  • social security information, drivers’ licenses, state ID cards, passport numbers
  • account login information
  • credit card numbers, financial account information, or credentials allowing access to such accounts
  • precise geolocation
  • racial or ethnic origin, religious or philosophical beliefs, union membership
  • the contents of email and text, unless the business is the intended recipient of the communication
  • genetic data, biometric data, and health data
  • data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal Information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal Information, please email [Email Address] or visit: [DSAR Form URL].]

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

      • You may object to the processing of your personal information.
      • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
      • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
      • [You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.]

To exercise these rights, you can contact us by email at [Email Address], by calling toll-free at [Phone Number], by visiting [Contact Form URL], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Financial Incentives

“Financial incentive” means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sharing, or sale of personal information.

The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data. The explanation must include:

      • a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
      • a description of the method the business used to calculate the value of the consumer’s data.

We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention, sale or sharing of a consumer’s personal information.

If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference.

If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at [Email Address], by calling us toll-free at [Phone Number], by visiting [Contact Form URL], or by referring to the contact details at the bottom of this document.

Metrics

Our metrics for all CCPA requests received for the previous calendar year can be found here: [Metrics URL].

15. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with [Company Name] and our Services. To find out more, please visit the following sections above:

  • 1. WHAT INFORMATION DO WE COLLECT?
  • 2. HOW DO WE PROCESS YOUR INFORMATION?
  • 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Your rights with respect to your personal data

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ([“profiling”/’profiling’])

[[Company Name] has not sold any personal data to third parties for business or commercial purposes. [Company Name] will not sell personal data in the future belonging to website visitors, users, and other consumers. / [Company Name] sells personal data to third parties or processes personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.]

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: [Cookie Notice URL].

[You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.]

You may contact us by email at [Email Address], by visiting [Contact Form URL], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [Email Address]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), [DPO Name], by email at [Email Address], by phone at [Phone Number], or by post to:

[Company Name]
[DPO Name]
[Street Address]
[City, State ZIP Code]
[Country]

If you are a resident in the European Economic Area, the “data controller” of your personal information is [Company Name]. [Company Name] has appointed [EEA Representative Name] to be its representative in the EEA. You can contact them directly regarding the processing of your information by [Company Name], by email at [Email Address], by visiting [EEA Representative URL], by phone at [Phone Number], or by post to:

[Street Address]
[City, State ZIP Code]
[Country]

If you are a resident in the United Kingdom, the “data controller” of your personal information is [Company Name]. [Company Name] has appointed [UK Representative Name] to be its representative in the UK. You can contact them directly regarding the processing of your information by [Company Name], by email at [Email Address], by visiting [UK Representative URL], by phone at [Phone Number], or by post to:

[Street Address]
[City, State ZIP Code]
[Country]

If you have any further questions or comments, you may also contact us by post at the following corporate address:

[Company Name]
[Street Address]
[City, State ZIP Code]
[Country]
Phone: [Phone Number]
Fax: [Fax Number]

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: [DSAR Form URL].

Mobile App Privacy Policy FAQ

Below, see some of the most frequently asked questions we get about mobile app privacy policies. 

Do I need a privacy policy for iOS apps?

Yes, Apple requires that all iOS apps link to a privacy policy regardless of if you fall under the jurisdiction of any data privacy laws.

Do I need a privacy policy for Android apps?

Yes, Google requires all Android apps to have a link to a privacy policy and declare how they collect and handle user data in the Data Safety section of the Google Play store.

What laws require a mobile app privacy policy?

Some of the data privacy laws that require mobile apps to have privacy policies are the: 

  • General Data Protection Regulation (GDPR)
  • California Online Privacy Protection Act (CalOPPA)
  • California Consumer Privacy Act (CCPA)
  • California Privacy Rights Act (CPRA)
  • Virginia Consumer Data Protection Act (CDPA)
  • Children’s Online Privacy Protection Act (COPPA)
  • Personal Information Protection and Electronic Documents Act (PIPEDA)

What should my mobile app privacy policy include?

Your mobile app privacy policy should include all of the following information in distinct clauses:

  • Types of personal information you collect
  • How you use and share personal information
  • Disclosure of your use of any third-party services
  • Explain users’ control and rights over their data
  • Describe how you’ll update users about changes to your policy

Customize your agreement to reflect the unique aspects of your mobile app. 

How often do I need to update my mobile app privacy policy?

You should update your mobile app privacy policy once every 12 months if you fall under the jurisdiction of the amended CCPA.

Otherwise, update it whenever you change any of your privacy practices. 

Can I copy someone else’s mobile app privacy policy?

No, don’t copy someone else’s mobile app privacy policy, as that’s plagiarism, and the policy won’t reflect your privacy practices.

Is a privacy policy template enough for my mobile app?

Downloading and customizing a privacy policy template is enough for most mobile apps.

But if your app collects highly sensitive information or requires a more comprehensive privacy policy, consider using a Generator or reaching out to a lawyer or data privacy expert. 

When do I need a privacy policy for an app?

You need a privacy policy for your app if it falls under the jurisdiction of data privacy legislation like the GDPR or the CCPA, or if you use third-party app platforms that require privacy policies as a condition for publication. 

Legally, your app may also need a privacy policy if it markets to specific demographics, like minors.

Summary

If you develop mobile apps, you likely need a privacy policy due to regional data privacy laws or the guidelines outlined by third-party app hosting platforms like Apple and Google. 

Even if your app doesn’t collect personal data or isn’t under the umbrella of any legislation, both Apple and Google require you to link to a privacy policy stating as much. It’s clearly outlined in their developer guidelines that all responsibilities and liabilities fall on you, the app developer.

Luckily, privacy compliance doesn’t have to be complicated. You can make a policy that complies with Apple and Google’s developer guidelines in minutes by downloading and customizing our free privacy policy template for mobile apps

Masha Komnenic CIPP/E, CIPM, CIPT, FIP
More about the author

Written by Masha Komnenic CIPP/E, CIPM, CIPT, FIP

Masha is an Information Security and Data Privacy Specialist and a Certified Data Protection Officer. She has been a Data Protection Officer for the past six years, helping small and medium-sized enterprises achieve legal compliance. She has also been a privacy compliance mentor to many international business accelerators. She specializes... More about the author

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