We are next to launch an iOS app in App Store which is asking us for a privacy policy url as part of process when this app is being uploaded to app store.

We and most of our users are outside USA and our local privacy information regulations might not be equivalent to USA.One of the questions of our team is that under our local regulations geolocation is not sensitive information.If our app collects that kind of information from our users, are we forced to establish a privacy policy?

Is there any regional aspect we should take into account when we decide to establish a privacy policy for our application? Must we apply USA privacy regulations criteria to establish a privacy policy?

thank you

2 Answers 2


You should indeed consider local privacy regulations. The EU, in particular, has stringent privacy regulations.

Here are some good websites where to get additional information:


Even though the U.S. has no federally mandated privacy policy requirements, creating a policy to cater to the 'least privilege' is going to help you ensure your app is legal in all jurisdictions. Only CA and CT have a mandate for privacy policies within the U.S.. As it stands right now, the EU has more stringent privacy protection requirements than the U.S. (i.e. they allow you as a business the 'least privilege' to data). The European Commission's Article 29 Working Group put out an opinion on geolocation back in 2011 but now it is being addressed in draft General Regulation Data Protection (Art. 4.1 & Art. 20.1 in relation to Art. 33)(due to be adopted in late 2014).

Geolocation is also an issue that is on the Congressional floor under the Geolocation Privacy and Surveillance Act (aka GPS Act; H.R. 1312 & S.639). This may be something you want to follow. As it stands now The International Association of Privacy Professionals recommends you minimize your risk by collecting data that is "not immediately indentifiable as belonging to a particular individual" and, when possible, get an affirmative opt-in before collecting or sharing geolocation information.

Right now, whether you are being forced or not seems to depend on how geolocation data is classified and how you are using it. Overall, it seems in your best interest to develop the policy. Remember this is all coming down to reducing your risk of being sued. Depending on your app and its reach you may want to contact an attorney to develop a EULA to protect your interests.

Much success to you with your app!

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