Do app stores require privacy policies?

If your application transmits no data (including to advertising companies), then you may not have anything to disclose when it comes to privacy.

But if your app does transmit data, you should consider these provisions:

Apple App Store Review Guidelines, Section 7.1:

Apps cannot transmit data about a user without obtaining the user’s prior permission and providing the user with access to information about how and where the data will be used.

Android Market Developer Distribution Agreement, Section 4.3:

You agree that if you use the Market to distribute Products, you will protect the privacy and legal rights of users. If the users provide you with, or your Product accesses or uses, user names, passwords, or other login information or personal information, you must make the users aware that the information will be available to your Product, and you must provide legally adequate privacy notice and protection for those users. Further, your Product may only use that information for the limited purposes for which the user has given you permission to do so.

Microsoft App Hub Application Provider Agreement, Section 4(d):

If your Application enables access to and use of Internet-based or mobile services or otherwise collects and/or transmits user information to you or a third party, you are responsible for informing Purchasers of your terms of use and privacy policy that apply. At a minimum, your privacy policy must (i) comply with applicable laws and regulations, (ii) inform users of the information collected by your Application and how that information is used, stored and disclosed, and (iii) describe the controls that users have over the use and sharing of their information.

Amazon App Store for Android Distribution Agreement, Section 5(b):

If you have access to any name, password, other login information, or personally identifiable information of any end user of our program based on any use of or interaction with the Apps, you will (i) provide legally adequate privacy notices to such end user, (ii) use and authorize others to access and use it only for the purposes permitted by the end user, and (iii) treat, store and use the information in accordance with the applicable privacy notice and applicable laws, rules, regulations, orders, and other requirements of governmental agencies …

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