App Store Compliance

iOS privacy policy generator: what to use and why most options fail App Review

Most generic privacy policy generators fail App Review because they miss 5 specific sections Apple cross-checks. What an iOS, iPadOS, macOS, tvOS, or visionOS app actually needs.

By · · 9 min read

You search “iOS privacy policy generator” because Apple won’t let you submit your app without one, and you don’t want to write 1,500 words of legalese from scratch. The first ten Google results are generic privacy-policy SaaS tools — Termly, iubenda, TermsFeed, Get Terms, plus a long tail of free templates.

Most of them won’t pass App Review on the first try.

Not because the legal content is wrong. It’s usually fine. They fail because Apple cross-references your privacy policy URL against three other things — your Info.plist permission strings, your App Privacy Details questionnaire in App Store Connect, and your PrivacyInfo.xcprivacy file — and a generic generator has no idea what any of those say. So your policy ends up declaring data practices that don’t match what your app actually does, and App Review flags it.

This post is what an iOS privacy policy actually has to do, why generic generators miss the mark, and what to look for in a generator that’s specifically built for App Store submission.

If you’re working through your full submission, see the broader checklist of every URL and file Apple requires for an iOS App Store submission.

What App Review actually checks

App Review’s tooling visits your privacy policy URL automatically on every submission. The page must:

  1. Load on a public URL — no login wall, no IP allowlist, no expired SSL.
  2. Be reachable as long as the app is in the App Store — so the URL has to outlive your marketing site redesigns.
  3. Disclose every category of data the app collects — using terminology that maps to Apple’s 14 App Privacy Details categories.
  4. Match what your app actually does — App Review cross-references the policy against the permission strings in your Info.plist, the answers in App Store Connect’s privacy questionnaire, and the declarations in your bundled PrivacyInfo.xcprivacy.

The fourth one is where generic generators fail. They generate plausible legalese, but they don’t know whether your app uses CLLocationManager, what your third-party SDKs do, or which Required Reasons APIs your binary touches. Apple does — they’ve literally scanned your binary by the time they read the policy.

The 5 sections every iOS privacy policy needs

Below are the five sections that have to exist in some form for an iOS, iPadOS, macOS, tvOS, or visionOS app’s privacy policy to clear App Review without clarification requests.

1. Identity of the data collector

Who is collecting the data — your legal entity name, contact email, optionally a postal address. Apps from individual developers can name themselves; apps from a company need the registered business name that matches the App Store Connect “Seller” field.

App Review checks that this section exists and that the contact email actually receives mail. Some reviewers send a test email; if it bounces, the submission gets flagged.

2. Categories of data collected, mapped to Apple’s taxonomy

Apple’s 14 data categories from the App Privacy Details questionnaire:

Contact Info · Health & Fitness · Financial Info · Location · Sensitive Info · Contacts · User Content · Browsing History · Search History · Identifiers · Purchases · Usage Data · Diagnostics · Other Data

Your privacy policy should declare each category your app or its SDKs collect, using these exact category names where natural. Generic generators use their own taxonomy (“Personal Information”, “Technical Data”, etc.) which doesn’t map cleanly. App Review can match either, but the cleaner the mapping, the faster the approval.

We have a category-by-category guide to what each one actually means if you want to know what counts as “Identifiers” vs “Diagnostics” vs “Other Data”.

3. Purposes for each data type

For every data category you declared in section 2, your policy must state why you collect it. Apple’s seven sanctioned purposes:

  • App Functionality
  • Analytics
  • Product Personalization
  • App Marketing
  • Developer’s Advertising or Marketing
  • Third-Party Advertising
  • Other Purposes

Same as the categories, your policy doesn’t have to use these literal labels — but it has to declare a purpose that maps clearly to one of them. “We collect your email address” without a purpose statement gets bounced.

4. Account deletion (if your app supports account creation)

This is the Apple Guideline 5.1.1(v) requirement. As of June 30, 2022, any iOS or macOS app that supports account creation must also support account deletion — and the privacy policy must explain how to initiate it, what gets deleted, what gets retained, and on what timeline.

The flow itself has to be in the app (not just on a web page), but the policy is where the legal disclosure lives. Apple’s official page on account deletion is the canonical reference. We also have a dedicated guide to designing the account deletion flow.

5. Children & tracking disclosures

If your app is in a kids category or you allow under-13 sign-ups, COPPA-specific language is required. If your app or any third-party SDK engages in tracking as Apple defines it, the App Tracking Transparency permission requirement and tracking practices must be disclosed in the policy.

Generic generators often skip these unless you explicitly toggle “this app is for children” or “we use third-party advertising,” which most developers don’t think to do during the wizard.

Why most generators fall short for iOS

Run through the major options against the four App-Review checks:

Generator Hosted URL Apple-mapped categories Account deletion section Privacy manifest awareness
Termly yes (paid plans) partial — uses generic categories configurable but not Apple-specific no
iubenda yes (paid plans) partial configurable no
TermsFeed not by default generic optional add-on clause no
Free template generators no — you self-host generic usually missing no
App-store-built tools yes yes — designed around them yes — required path yes (link to manifest)

The first four fail one or more of the App Review cross-references. The last category — generators built specifically for App Store compliance — covers all four because the tool’s entire purpose is matching your declared data practices to what Apple expects to see.

What to look for in a privacy policy generator for iOS

If you’re picking a tool, the requirements that matter for fast App Review approval:

  1. The policy URL is hosted by the generator — your obligation is “publicly accessible URL that doesn’t break for the lifetime of the app.” Self-hosting on a custom site means another piece of infrastructure to maintain.
  2. The questionnaire maps 1:1 to Apple’s App Privacy Details fields — so what you fill out for the policy is the same thing you’ll paste into App Store Connect. No translation step.
  3. It includes account deletion language by default if you indicate the app has accounts.
  4. It outputs (or links to) a PrivacyInfo.xcprivacy file with the declared data categories — Apple cross-references the policy against this file’s NSPrivacyCollectedDataTypes field.
  5. The hosted URL works on iPhone first — App Review tests on a phone, not desktop. Mobile-broken pages get rejected.

Bonus: a generator that warns you when your declared practices conflict (e.g., “you said you collect email but didn’t declare a purpose”) catches errors before App Review does.

The OrbitKit privacy policy generator

OrbitKit was built specifically for iOS and Apple-platform App Store submission, which is why the privacy policy generator covers all five sections above by construction:

  • 12-step wizard following Apple’s exact taxonomy (14 categories × 7 purposes).
  • Hosted URL at sites.orbitkit.io/your-app (or your own custom domain) — stays live as long as your subscription does.
  • Account deletion section auto-included if you indicate the app supports accounts.
  • Pairs with the PrivacyInfo.xcprivacy generator so your policy and your manifest declare the same categories.
  • Cross-field validation flags inconsistencies before you submit.
  • Free preview before deploy — see the rendered policy without paying.

Pricing is $5/mo per app, no setup fees, no per-clause charges. Start free or see the full features list.

What about free templates?

Free templates work if you customize them carefully and self-host the result. The two reasons not to:

  1. Hosting a static HTML file forever is not free. GitHub Pages drifts, marketing sites get redesigned, custom domains expire. Apps get rejected on update because the URL that used to work now 404s. The whole point of a generator is moving that obligation off your plate.
  2. App Review treats unmodified templates as a yellow flag. Reviewers have seen the same boilerplate text from every free generator. If your policy looks identical to one of those templates and your app’s actual data practices are non-trivial, you’ll get clarification requests asking for specifics.

The shortest path to a clean approval is a generator that produces a policy specific to your app’s data practices, hosted somewhere that doesn’t depend on you remembering to renew anything.

For the full picture of what Apple checks before approval — privacy policy is one of about a dozen things — see every URL and file Apple requires for iOS and macOS App Store submission.