Mobile App Privacy Policy

Mobile App Privacy Policy

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1st document free
4.6 (32)
Under 5 minutes
Under 5 minutes
Last updated December 2018
Last updated August 26, 2021
Suitable for all Australian states and territories
Suitable for all Australian states and territories

A Mobile App Privacy Policy allows you to communicate to customers and users how your application collects and uses the information collected. Customisable and ready to use in under 5 minutes.

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Document Overview


You may be required to have a Mobile App Privacy Policy to stay compliant with Australian Privacy laws, including the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs), International Privacy laws, as well as App Store guidelines. As people are increasingly cautious about personal information being collected while using applications, implementing a Mobile App Privacy Policy is a great mechanism to assure users that your application is legally compliant. This compliance will not only ensure that you stay within the legal parameters but also eliminate the risk of having your application being rejected during the submission process.

What is a Mobile App Privacy Policy?

This Mobile App Privacy Policy covers and informs your application users about how your application collects, uses, manages and stores personal information. This usually includes information about what type of information will be collected based on the users interaction with your applications or platforms. Having a Mobile App Privacy Policy ensures that your users are well informed and consent to your applications collection of personal data. 

Even if your App does not collect data directly, you may still be required to have a Mobile App Privacy Policy if your application utilises third-party tools, such as Google Analytics, or third-party App providers, such as Apple, Google and Android App stores.

Note: If you application has been or will be released on both iOS and Android platforms, you will not need two seperate Mobile App Privacy Policies. You must simply ensure your Policy is comprehensive enough to cover both service providers guidelines.

Other names for a Mobile App Privacy Policy

A Mobile App privacy Policy may also be known as a Privacy Statement, App Privacy Statement or App Privacy Guidelines.

Why Use this Mobile App Privacy Policy?

Use this Mobile App Privacy Policy if:

  • You developed an application and want to tell customers and users how their information is collected and used,
  • You would like to ensure your application is compliant with Australian Federal Privacy laws,
  • You want to ensure your application is compliant with third-party App Store providers, such as Google Play services and Apple App Store services. 
  • You want to ensure your application is compliant with any third-party tools, such as Google Analytics.

What does this Mobile App Privacy Policy cover?

This Mobile App Privacy Policy covers the following provisions. Please note, this Overview does not outline all the provisions include in this Mobile App Privacy Policy. This is merely an Overview of the most popular provisions in the Policy.

Collection of Personal Information 

Your Mobile App Privacy Policy should outline the type of data and personal information that may be collected, either by your business, application provider or third-party service providers. It is common for personal data to make up a user's personal identifiable information such as the user's name, email address or physical address, phone number, date of birth etc. Your Mobile App Privacy Policy should also stipulate the type of usage data or log data that may be collected, such as internet provider, signals, browser settings, internet protocol address (IP address), operating system, camera data, microphone data etc.

Use of Personal Information 

The Mobile App Privacy Policy must explain how this personal information will be received, stored and shared. For instance, the data may be used for marketing or advertisement purposes (ads) and to improve, enhance and maintain the quality of the App's services etc. If you application will be listed on an App Store, such as Apple's App Store, the Google Play Store or any other service, you must include this in your Mobile App Privacy Policy. 

Disclosure of Personal Information 

Similar to a standard Privacy Policy, your Mobile App Privacy Policy should have provisions surrounding the disclosure of personal information to third-party service providers, agents, developer or suppliers. Your Policy must explain why, when and how this information may be disclosed, for instance, for third-party advertising.

Use of Cookies and Related Technologies 

If you application uses cookies or similar technologies, your Policy must inform its users. Your Policy should outline that the users has the right to consent or refuse consent to the applications use of cookies.

Third Party access to Personal Information 

This provision is an extension of the "usage" provision, however it is specifically tailored to third party service access to a users personal data. These third parties usually include the Store provider, such as iOS or Android services. Your Policy should explain how and when such personal information may be disclosed to these third parties. 

Commonly Asked Questions

Do I have to include a Mobile App Privacy Policy for my App?

Under Australian law, it is required that you have a Privacy Policy for your app. If your app is also launched internationally, a Privacy Policy is required in many overseas countries as well. A Privacy Policy is required when you collect information such a personal data from your users or utilizing third-party analytics or other tools to collect such personal data.

I have advertising on my App. Am I required to have a Mobile App Privacy Policy?

In many cases where there is advertising on an app, under Australian Law you will be required to have a Privacy Policy that deals with this aspect of advertising. For example, if there is advertising in the form of direct marketing, it is required that this is complied with under the Australian Privacy Principles.

Does my Mobile App Privacy Policy need to be GDPR compliant?

The GDPR is formally known as the European Union General Data Protection Regulation and contains new data protection requirements that will come into effect on the 25th May 2018. There are many provisions under the GDPR that overlap with current Australian Privacy Law and as such, need to be complied with. These common legal requirements include how information is handled and ensuring privacy by design.

Most importantly, the GDPR will need to be complied with within the Privacy Policy, if it is found that the business is established in the EU, the business offers the app or monitors the behaviour of users in the EU.

Do I need a Mobile App Privacy Policy to be published on an App Store?

Majority of the time, app stores such as Apple's App Store and the Google Play App Store will explicitly require developers to implement a Mobile App Privacy Policy in order to be accepted for publication on their stores. Apple has clear and strict requirements that all apps must have a Privacy Policy. This is stated within the Apple App Store Review Guidelines. Google is slightly more lenient, stating that you are required to have a Privacy Policy if you app collects personal and sensitive information.

What else will my App need to be published in the App Store?

There are a few things you will need to complete before launching your app. In regards to legal considerations, you will need to get an ABN for your business and create an App End User License Agreement. Apple’s End User License Agreement will automatically be applicable if you do not provide your own EULA, which can potentially be problematic as Apple’s EULA is governed by the Law of the State of California and not Australian Law.

Next, it is best to consider the best ways to market your app. This will include target keywords, app descriptions and creating a supporting web page. Thirdly, look at the distribution of your app. This includes ensuring that the app is adequately configured to launch, analyzing crash reports and testing the app across numerous devices.

Where should I publish my application Privacy Policy?

The Privacy Policy should be available as a link on the page from which the app is downloaded from, on the app store itself. In addition, some apps require you to tick a box in which you agree with the terms and conditions of use, in addition to the Privacy Policy. Both of these legal documents are often hyperlinked and can be reviewed by the user if they so wish. Some apps also have a separate legal tab in which users can access on their app or on the publishing business’s website.

Related Documents:

Further Information:


 

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