Yes, on both stores. Apple requires a privacy policy link for every app, both in App Store Connect and inside the app, and Google Play says apps that don't access any personal or sensitive user data must still submit one. A no-data policy is short, though. This guide covers what each store requires, how to confirm your app really collects nothing (third-party SDKs are the usual catch), and what the policy should say.
Guideline 5.1.1(i) says all apps must include a link to their privacy policy in the App Store Connect metadata field and within the app in an easily accessible manner. There's no exception for apps that collect nothing. App Store Connect lists the Privacy Policy URL as required for iOS and macOS apps.
Separately, the App Privacy section asks whether you or your third-party partners collect data from the app. If the honest answer is no, select 'No, we do not collect data from this app' and Apple asks no further questions. Keep your privacy policy consistent with that answer.
Google's User Data policy says all apps must post a privacy policy link in the designated Play Console field, plus a link or the policy text inside the app. It also states that apps that don't access any personal and sensitive user data must still submit a privacy policy.
The Data safety form works the same way. Google says even apps that collect no user data must complete the form and provide a privacy policy link, and both can state that no data is collected or shared. Our Google Play Privacy Policy URL guide shows where the field lives in Play Console.
Both stores define collection as data leaving the device. Apple counts data as collected when it's transmitted off the device in a way that lets you or your third-party partners access it for longer than it takes to service the request in real time. Google counts any user data your app transmits off the device. Data your app only processes on the device isn't collected under either definition.
The catch is third-party code. Both stores count data sent by SDKs and libraries in your app, not just your own code. Firebase Analytics, Crashlytics, Sentry, AdMob, and most attribution SDKs send device identifiers, usage data, or diagnostics off the device, so an app that includes any of them doesn't qualify as no-data even if your own code never touches user information. Google's definition also covers data collected through a web view your app opens when you control the code it loads.
Keep it short and specific. Name the app. State that it doesn't collect personal information, usage data, device identifiers, or location data, and that it doesn't use third-party analytics, advertising, or tracking services. Give users a way to contact you, since Google's policy asks for a privacy point of contact or a way to submit inquiries. Label the page as a privacy policy in its title.
Revisit the policy whenever you add an SDK. Adding analytics or ads changes your App Privacy answers and your Data safety form, and the policy has to change with them.
BaseTerms starts with every feature box unchecked, and that default generates a no-data privacy policy. It has a No Data Collection section listing what the app doesn't collect (personal information, usage data, device identifiers, location) and a No Third-Party Tracking section confirming the app uses no analytics, advertising, or tracking services. It names your app and links to a Support page where users can reach you. Check any box (analytics, location, accounts, ads, payments) and the No Data Collection section is replaced with a disclosure of what the app does collect.
The policy is hosted at yourapp.baseterms.com/privacy, ready to paste into App Store Connect and Play Console and to link from your app's settings screen. Copy the raw Markdown free, or host on the subdomain for $9 one-time.
Ready to ship?
Privacy Policy, Terms, Support, plus Data Deletion if your app has accounts — ready to paste into App Store Connect and Google Play Console. Copy the raw Markdown free or host on a custom subdomain for $9 one-time.
One-time payment. No subscription. No renewal fees.