An iOS app privacy policy must cover six Apple-specific requirements: privacy nutrition labels that match your App Store Connect declarations, App Tracking Transparency disclosure, data handling for any Apple frameworks you use (HealthKit, HomeKit, Sign in with Apple, Core Location), a privacy manifest declaration for required reason APIs, user data deletion instructions, and your contact information with an effective date. Your policy must be consistent with the privacy nutrition labels displayed on your App Store listing. Mismatches between your policy and your nutrition labels are one of the most common reasons for App Store rejection.
Building a privacy policy for your iOS app from scratch is time-consuming. You need to satisfy Apple's App Store Review Guidelines, fill out privacy nutrition labels correctly, handle App Tracking Transparency disclosures, and potentially cover GDPR and CCPA requirements. Missing any of these can get your app rejected during review or removed from the App Store after publication.
This page provides a complete, free template built specifically for iOS apps. The template covers every section Apple expects, follows App Store privacy requirements, and includes sections for HealthKit, App Tracking Transparency, privacy manifests, and GDPR compliance.
If you want to understand the broader context of why apps need privacy policies and what triggers the requirement, read the complete app privacy policy guide first. For a template that covers both iOS and Android, see the mobile app privacy policy template. This page focuses specifically on Apple-specific requirements.
What Apple Requires in Your Privacy Policy
Apple requires every iOS app to have a privacy policy, regardless of whether the app collects user data. The App Store Review team checks your policy against your privacy nutrition labels and your actual app behavior. Here is the complete checklist of required and recommended sections.
Required Sections
- Data collection statement: What personal data your app collects, including data accessed through system frameworks like Core Location, Contacts, Photos, HealthKit, and any third-party SDKs.
- Purpose of data use: Why your app collects each type of data. Every data point must have a clear purpose tied to your app's functionality or a legitimate business need.
- Third-party sharing: Whether your app shares data with any third parties, who those parties are, and why data is shared. This includes analytics SDKs, advertising networks, and crash reporting services.
- Data retention and deletion: How long data is stored and how users can request deletion. Apple requires apps that create accounts to offer account deletion within the app itself.
- Privacy nutrition label consistency: Your policy must match the privacy nutrition labels you declare in App Store Connect. Every data type in the labels must appear in your policy and vice versa.
- Contact information: A way for users to reach you with privacy questions. An email address is the minimum requirement.
- Effective date: When the policy was last updated. This helps users and reviewers verify the policy is current.
Recommended Additional Sections
- App Tracking Transparency disclosure: If your app uses the ATT framework, explain what tracking occurs and what happens when users opt out.
- HealthKit and sensitive data handling: If your app accesses HealthKit, HomeKit, or other sensitive frameworks, specific disclosures about how that data is handled.
- GDPR compliance section: Legal basis for processing, data retention periods, and EU user rights including access, rectification, and erasure.
- Privacy manifest reference: If your app includes a PrivacyInfo.xcprivacy file, a reference to the required reason API categories declared in it.
Did you know?
Apple compares your privacy policy content against your privacy nutrition labels during App Store review. If your nutrition labels declare that you collect precise location data for analytics, but your privacy policy does not mention location tracking, the inconsistency will flag your app for manual review and likely rejection. Your template must cover every data type you declare in App Store Connect.
Full Template Preview
Below is the complete privacy policy template with each section shown. Bracketed text like [Your App Name] indicates placeholders you need to replace with your specific details. Remove any sections that do not apply to your app.
Privacy Policy for [Your App Name]
Effective Date: [Date]
1. Introduction
This privacy policy describes how [Your App Name] ("the App") collects, uses, stores, and shares data. The App is an iOS application available through the Apple App Store. By downloading and using the App, you agree to the data practices described in this policy.
2. Data We Collect
The App collects the following types of data:
- [Data type 1, e.g., "Precise location data when you use the map feature"]
- [Data type 2, e.g., "Health data from HealthKit with your explicit permission"]
- [Data type 3, e.g., "Email address and name when you create an account"]
- [Data type 4, e.g., "Usage analytics and crash reports"]
The App does NOT collect: [list data types you do not collect, e.g., "financial information, browsing history, or contacts data"].
3. How We Use Your Data
We use the collected data for the following purposes:
- [Purpose 1, e.g., "To provide the App's core functionality"]
- [Purpose 2, e.g., "To personalize your experience based on preferences"]
- [Purpose 3, e.g., "To improve the App based on usage patterns"]
We do NOT use your data for purposes not listed above. HealthKit data, if collected, is used solely to provide health and fitness features within the App and is never used for advertising or shared with data brokers.
4. Third-Party Data Sharing
[Option A: "The App does not share your data with any third parties."]
[Option B: "The App shares data with the following third-party services: [Service Name] for [purpose, e.g., analytics, crash reporting]. These services have their own privacy policies."]
5. Data Storage and Security
[Option A: "All data is stored locally on your device. No data is transmitted to external servers."]
[Option B: "Data is stored on secure servers using [provider, e.g., AWS, Firebase]. Data synced via iCloud is governed by Apple's iCloud terms and stored in your personal iCloud account."]
We implement [describe security measures, e.g., "encryption at rest and in transit, App Transport Security, and Keychain storage for sensitive credentials"] to protect your data.
6. Tracking and App Tracking Transparency
[Option A: "The App does not track you across other companies' apps or websites. We do not use advertising identifiers or participate in cross-app tracking."]
[Option B: "The App requests your permission to track your activity across other companies' apps and websites via the App Tracking Transparency prompt. If you allow tracking, we use [describe what tracking occurs]. If you deny tracking, we do not collect any cross-app data and advertising shown to you will not be personalized based on your activity across other apps."]
7. Your Rights and Data Deletion
You can delete all App data at any time by [describe deletion method, e.g., "deleting the App, which removes all locally stored data" or "using the Delete Account option in the App settings"]. To request deletion of any server-side data, contact us at [your email].
8. GDPR Compliance (EU Users)
If you are located in the European Union, we process your data under the legal basis of [legitimate interest / consent / contract performance]. You have the right to access, rectify, erase, restrict processing, and port your data. To exercise these rights, contact us at [your email].
9. Changes to This Policy
We may update this privacy policy from time to time. Changes will be posted at this URL with an updated effective date. Continued use of the App after changes constitutes acceptance of the updated policy.
10. Contact Us
If you have questions about this privacy policy or the App's data practices, contact us at: [your email address].
This template gives you the foundation. The sections below walk you through privacy nutrition labels, iOS-specific data disclosures, App Tracking Transparency wording, and privacy manifests so you can customize the template for your specific app.
Q: Can I remove sections from the template that do not apply to my app?
Yes. If your app does not use HealthKit, remove the HealthKit-specific language. If your app does not track users, keep section 6 but state clearly that no tracking occurs. Remove sections only if they are truly irrelevant. When in doubt, keep them and customize the wording.
Q: Should I add sections not covered in this template?
If your app does something unusual, like processing biometric data, handling payments through custom processors, collecting data from children, or using CallKit or SiriKit, you need additional sections. This template covers standard iOS app use cases. Apps with specialized data handling should add custom sections and consider legal review.
Privacy Nutrition Labels Guide
Privacy nutrition labels are the data disclosures you fill out in App Store Connect. They appear on your App Store listing and tell users what data your app collects before they download it. Your privacy policy must be consistent with these labels. Here is how to fill out each category.
Apple organizes data into 14 categories. For each category, you must declare whether data is collected, whether it is linked to the user's identity, and whether it is used for tracking. Here is what each category covers and how to reflect it in your privacy policy.
| Category | What It Covers | Privacy Policy Language |
|---|---|---|
| Contact Info | Name, email, phone number, physical address | "We collect your [name/email] to [purpose]." |
| Health & Fitness | Health data, fitness data, clinical records | Must include HealthKit-specific restrictions (no ads, no selling) |
| Financial Info | Payment info, credit score, salary | "Financial data is processed by [provider] and not stored on our servers." |
| Location | Precise location, coarse location | Specify precise vs. coarse and when/why it is collected |
| Sensitive Info | Racial/ethnic data, sexual orientation, biometric data | Requires explicit consent language and strict purpose limitation |
| Contacts | Address book contacts | "We access your contacts only to [purpose] and do not store them on our servers." |
| User Content | Photos, videos, audio, gameplay content | Describe what content is stored and whether it leaves the device |
| Usage Data | Product interaction, advertising data | "We collect usage analytics to improve app performance." |
| Diagnostics | Crash data, performance data | "Crash reports and performance data are collected anonymously." |
| Identifiers | User ID, device ID, IDFA | Disclose whether identifiers are linked to the user's identity |
For each category you declare in App Store Connect, your privacy policy must include a corresponding section that describes the data collected, the purpose, and whether it is linked to the user's identity. If you declare a category as "Data Not Linked to You," your policy should explain that the data is collected anonymously or not associated with your identity.
Did you know?
Apple audits privacy nutrition labels by comparing them against your app's actual network traffic and SDK usage. If your app includes the Facebook SDK but your nutrition labels do not declare advertising data collection, Apple may reject your app or request corrections. Third-party SDKs must now include their own privacy manifests, and the data they collect counts toward your app's nutrition label requirements.
iOS-Specific Data Disclosures
iOS apps often use Apple-specific frameworks that have their own privacy requirements. If your app uses any of the frameworks below, your privacy policy must include specific disclosures. Here is what to include for each one.
| Framework | Data Accessed | Required Privacy Policy Language |
|---|---|---|
| HealthKit | Health data, fitness data, clinical records | Must state data is not sold, not used for advertising, and not shared for advertising or data mining. List specific HealthKit data types read and written. |
| HomeKit | Smart home device data, automation data | Must state HomeKit data is used solely to provide home automation features. Cannot be shared with third parties for advertising. |
| Sign in with Apple | Apple ID, email (real or relay), name | Disclose what data is received from Apple, whether the relay email is used, and how the Apple ID is stored. |
| Core Location | Precise or coarse GPS coordinates | Specify whether precise or coarse location is used, when it is collected (always vs. while using), and whether coordinates are sent to servers. |
| Push Notifications | Device token, notification preferences | Disclose that a device token is sent to your server for push delivery. Explain what notification data is stored. |
| App Clips | Limited data scoped to the App Clip session | Explain that App Clip data is ephemeral and what, if anything, transfers when the user installs the full app. |
| iCloud Sync | App data synced via CloudKit or iCloud containers | Disclose what data is synced, note that iCloud storage is governed by Apple's terms, and explain that synced data is tied to the user's Apple ID. |
| StoreKit | Purchase history, subscription status | Explain that purchase data is processed by Apple and what transaction information your app accesses via StoreKit receipts or Transaction API. |
Only include disclosures for the frameworks your app actually uses. Delete rows for frameworks that are not relevant to your app. If your app uses frameworks not listed here, such as ARKit, CallKit, or EventKit, add a corresponding disclosure section following the same pattern: what data is accessed, why your app needs it, and how it is handled.
For a broader look at mobile app requirements across both platforms, see the do mobile apps need a privacy policy guide. For Android-specific disclosures, see the Android app privacy policy template.
App Tracking Transparency Wording
If your app uses the App Tracking Transparency (ATT) framework to request permission to track users across other companies' apps and websites, your privacy policy must include specific language about this tracking. Here is the exact wording to include.
If your app DOES track users:
"[Your App Name] requests your permission to track your activity across other companies' apps and websites. We use this data to [describe purpose, e.g., deliver personalized advertising, measure ad effectiveness]. When you see the tracking permission prompt, you can choose to Allow or Ask App Not to Track. If you choose not to allow tracking, we will not collect cross-app identifiers and any advertising shown will not be personalized based on your activity in other apps. You can change this setting at any time in Settings > Privacy & Security > Tracking."
If your app does NOT track users:
"[Your App Name] does not track your activity across other companies' apps or websites. We do not use the Identifier for Advertisers (IDFA) or any other cross-app tracking mechanism. All analytics data collected is first-party and not shared with advertising networks."
The ATT disclosure in your privacy policy must be consistent with two other things: the purpose string you display in the ATT prompt (the NSUserTrackingUsageDescription in your Info.plist) and the tracking declaration in your privacy nutrition labels. If your nutrition labels say "Data Used to Track You," your policy must explain that tracking.
Apple defines "tracking" specifically as linking data collected from your app with data from other companies' apps, websites, or offline properties for targeted advertising or advertising measurement purposes, or sharing data with data brokers. If your app does not meet this definition, you do not need to show the ATT prompt, but you should still include a no-tracking statement in your privacy policy for clarity.
Privacy Manifests
A privacy manifest is a PrivacyInfo.xcprivacy file that declares why your app or SDK uses certain APIs that Apple classifies as "required reason APIs." Apple requires this file for apps that use specific system APIs and for all third-party SDKs distributed as XCFrameworks or Swift packages.
The required reason API categories include:
- File timestamp APIs: APIs that access file creation or modification dates (e.g., NSFileCreationDate, NSFileModificationDate)
- System boot time APIs: APIs that read the system boot time (e.g., systemUptime, mach_absolute_time)
- Disk space APIs: APIs that check available disk space (e.g., volumeAvailableCapacity)
- UserDefaults APIs: APIs that access shared UserDefaults containers across app groups
Your privacy policy should reference the API usage declared in your privacy manifest. For example, if your manifest declares that you use file timestamp APIs for the purpose of displaying file modification dates to the user, your privacy policy should mention that your app accesses file metadata for display purposes. This consistency across your privacy manifest, nutrition labels, and privacy policy reduces the risk of rejection during App Store review.
Third-party SDKs in your app must also include their own privacy manifests. When Xcode builds your app, it aggregates all privacy manifests into a single privacy report. Review this report (Product > Generate Privacy Report in Xcode) to make sure your privacy policy covers the data practices of every SDK in your app, not just your own code.
Did you know?
Apple now blocks App Store submissions that use required reason APIs without a valid privacy manifest. If your app or any third-party SDK uses UserDefaults across app groups, file timestamp APIs, system boot time APIs, or disk space APIs without declaring the reason in a PrivacyInfo.xcprivacy file, your build will be rejected with an ITMS-91053 error. Check all your dependencies, not just your own code.
Common Mistakes
Using a template saves time, but only if you avoid these common mistakes that cause iOS apps to get rejected during App Store review.
Mistake: Privacy policy does not match nutrition labels
The most common reason for rejection. Your nutrition labels in App Store Connect say you collect location data, but your privacy policy does not mention location. Or your policy describes collecting health data, but you did not declare it in the nutrition labels. Apple reviewers compare the two directly. Before submitting, place your policy and your nutrition labels side by side and verify every data type matches.
Mistake: Using HealthKit data for advertising or selling it
Apple strictly prohibits using HealthKit data for advertising, data mining, or selling to third parties. If your app accesses HealthKit data and your privacy policy does not explicitly state these restrictions, your app will be rejected. Even if you have no intention of misusing health data, the policy must include the explicit prohibition. Apple looks for this specific language during review.
Mistake: Missing the account deletion requirement
If your app allows account creation, Apple requires that users can also delete their account from within the app. Your privacy policy must describe this deletion process. Simply saying "contact us to delete your data" is not sufficient if your app has account creation. You need an in-app deletion flow and your policy must reference it.
Mistake: Not disclosing third-party SDK data collection
Every third-party SDK in your app collects data on your behalf. Firebase Analytics, Facebook SDK, AdMob, Crashlytics, and similar SDKs all collect user data. Your privacy policy must disclose what each SDK collects and for what purpose. Saying "we do not collect data" when your app includes analytics or advertising SDKs is a contradiction that Apple reviewers will catch.
Mistake: Missing the privacy manifest for required reason APIs
If your app uses required reason APIs (UserDefaults across app groups, file timestamps, boot time, or disk space) without a PrivacyInfo.xcprivacy file, your submission will fail. But beyond the technical requirement, your privacy policy should also explain why your app accesses these system resources. A complete privacy story means your manifest, nutrition labels, and policy all tell the same story about your app's data practices.
How to Customize This Template
The template above is a starting point. To make it accurate and compliant for your specific iOS app, follow these six steps. Each step tells you what to look for in your app and what to change in the template.
Audit your app's data collection
Go through every feature and list every piece of data your app collects, accesses, or processes. Include data from system frameworks (HealthKit, Core Location, Contacts, Photos, Camera, Microphone) and from third-party SDKs (analytics, crash reporting, advertising). This list drives the content of every section in the template.
Map data to privacy nutrition label categories
Apple organizes data into 14 categories for nutrition labels. Map every data point from step 1 into these categories: Contact Info, Health & Fitness, Financial Info, Location, Sensitive Info, Contacts, User Content, Browsing History, Search History, Identifiers, Usage Data, Diagnostics, Purchases, and Other Data. This mapping drives both your nutrition labels and your privacy policy.
Replace all placeholders with your app specifics
Go through the template and replace every bracketed placeholder. Replace [Your App Name] with your actual app name. Replace example data types with the real data your app collects. If a section offers Option A and Option B, choose the one that matches your app and delete the other. Remove entire sections for frameworks you do not use.
Add your App Tracking Transparency disclosure
If your app displays the ATT prompt, add a section explaining what tracking occurs and what happens when users opt out. If your app does not track, add a clear statement confirming that. Your ATT disclosure must match the tracking declaration in your nutrition labels.
Add your privacy manifest declarations
If your app uses required reason APIs, make sure your PrivacyInfo.xcprivacy file is in place and your privacy policy references the same API categories. Run Xcode's Generate Privacy Report to see the aggregated privacy manifest for your app and all its SDKs. See our GDPR privacy policy template for the full GDPR section format.
Verify against your App Store Connect nutrition labels
Before submitting, compare your finished privacy policy against the privacy nutrition labels in App Store Connect. Every data type and purpose declared in the nutrition labels must appear in your policy. Every data practice in your policy should match what you declared in the labels. Mismatches are the top reason iOS apps get flagged during review.
Frequently Asked Questions
Is a free iOS app privacy policy template enough for App Store approval?
A free template can pass App Store review if you customize it to accurately describe your app's data practices. Apple reviewers check that your policy matches your nutrition labels. The template must cover every data type you collect, how you use it, and whether it is linked to the user. Apps handling sensitive data like HealthKit should have their policy reviewed by a legal professional.
What must an iOS app privacy policy include to pass Apple review?
Your policy must include: what data your app collects, how it uses that data, whether it shares data with third parties, how data is stored, how users can delete their data, your contact information, and the effective date. You must also disclose ATT status, explain HealthKit data handling if applicable, and ensure everything matches your nutrition labels.
Do all iOS apps need a privacy policy?
Yes. Apple requires every app submitted to the App Store to have a privacy policy, regardless of whether the app collects user data. This applies to free apps, paid apps, apps with in-app purchases, and apps that collect no data at all. You must provide a privacy policy URL in App Store Connect before submission.
How do privacy nutrition labels relate to my privacy policy?
Privacy nutrition labels are the data disclosures in App Store Connect that appear on your listing. They summarize what data your app collects, whether it is linked to the user, and whether it is used for tracking. Your privacy policy must be consistent with these labels. Apple reviews both for consistency, and mismatches lead to rejection.
Does my iOS app privacy policy need to cover App Tracking Transparency?
If your app tracks users across other companies' apps or websites, yes. You must explain what tracking occurs, why the ATT prompt appears, and what happens if the user denies permission. Even if your app does not track, stating that explicitly in your policy is good practice.
How do I handle HealthKit data in my privacy policy?
Your policy must state that HealthKit data is not sold, not used for advertising, and not shared for data mining. List the specific HealthKit data types your app reads and writes, why access is needed, and how the data is stored. Apple explicitly prohibits using HealthKit data for anything other than health or fitness services.
What is a privacy manifest and does my app need one?
A privacy manifest (PrivacyInfo.xcprivacy) declares why your app uses required reason APIs like UserDefaults, file timestamps, boot time, and disk space APIs. Apple requires it for apps using these APIs and for all third-party SDKs. Your privacy policy should reference the same API usage to maintain consistency.
Related Resources
Apple App Store Privacy Requirements
Everything Apple requires for App Store compliance
Mobile App Privacy Policy Template
Template covering both iOS and Android requirements
Privacy Policy for Apps
Complete guide to app privacy requirements
Do Mobile Apps Need a Privacy Policy?
What triggers the requirement for mobile apps
Android App Privacy Policy Template
Google Play Store specific template and requirements
Privacy Policy for Google Play
Google Play data safety section requirements
GDPR Privacy Policy Template
All 12 required GDPR sections with a compliant template
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