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Even if your iOS app doesn't collect or manage any user data, you nonetheless need to have a Privacy Policy. If your app doesn't collect any personal data, simply say in your Privacy Policy about it. Users should know if their data is collected or not, and for what reasons.
We're going to break those requirements down into six steps: Check Which Privacy Laws Apply to You. ... Identify What Data Your App Collects. ... Explain How You Collect User Data. ... Explain How You Use User Data. ... Confirm Recipients of User Data are Compliant with Apple's Policies. ... Explain Your Data Retention and Deletion Policies.
Summary: There is currently no comprehensive data privacy legislation in Puerto Rico; however, Puerto Rico has enacted data breach and data disposal laws in recent years. The Citizen Information of Data Banks Security Act under §4051 of Chapter 310 of Title 10 P.R. Laws Ann.
Under the User Data policy, you must link to a privacy policy on your app's store listing page and within your app. Apps that do not access any personal and sensitive user data must still submit a privacy policy.
Most major countries and their privacy laws require you to include a privacy policy, but read on. The Attorney General of California made it clear that its Online Privacy Protection Act would be enforced on apps (CalOPPA).
How to write a privacy policy? Include your business name and contact information. Mention what type of information you collect. Explain how and why you collect data. Describe how users can opt-out. Mention if user data is shared with third-parties. Specify how long you will retain user data.
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.
Data privacy laws require privacy policies, and having one helps you avoid fines. Posting one helps build consumer trust and keeps them properly informed. Having a privacy policy may help your SEO and marketing efforts. Being honest about what data you collect, process, and use is ethical.