Guideline 5.1.1 Data Collection and Storage, in plain English
“All apps must include a link to their privacy policy”
Guideline 5.1.1 is Apple's main privacy rule: every app needs a privacy policy, linked both in App Store Connect and inside the app, and it must ask before collecting people's data. It also tells apps to collect only what they need, respect people's answers to permission requests, and not demand personal details or a login the app doesn't need. Most 5.1.1 rejections come from a missing or thin privacy policy, a permission request that doesn't explain itself, or a sign-up wall.
Checked against Apple’s guidelines on (Apple’s version of ). Apple’s reviewers make the final call.
What Guideline 5.1.1 means
Part (i) says what the privacy policy must cover: what data the app collects, how it collects it and every use of it; that any third party it shares data with, such as analytics, ad networks or SDKs, protects it as well as your policy says; and how long data is kept, how it is deleted and how people can withdraw consent or ask for deletion. Apple's App Review page adds that a privacy policy link is required for all apps.
Part (ii) is about consent. Apps that collect user or usage data must get consent first, even for data that is anonymous, and must give people an easy way to withdraw it. Paid features can't depend on someone granting access to their data, and the text in each permission request, the purpose string, must say clearly and completely how the data is used.
Parts (iii) and (iv) ask for as little as possible and no pressure. Apple prefers the system's photo picker or share sheet to full access to Photos or Contacts, tells apps not to trick or force people into unnecessary access, and suggests a way round a refusal, like typing an address when someone won't share their location.
The rest covers sign-in and special cases: part (v) on account sign-in and deletion, part (ix) on apps in regulated fields such as banking, healthcare or gambling, which should be submitted by the company providing the service, and part (x), which lets apps ask for a name and email only if giving them is optional.
Why apps are turned down under Guideline 5.1.1
The privacy policy link is missing or doesn't work
The App Store Connect field is empty or points to a dead page, or the policy can't be opened from inside the app, which Apple requires as well.
The privacy policy doesn't explain enough
A generic template that doesn't name the data this app collects, the companies it shares data with, how long data is kept or how to ask for deletion.
The app asks for access it doesn't need
Full access to the photo library to pick one picture, location for a feature that doesn't use it, or required fields like a birthday that the app never uses.
The app requires personal information to work
A sign-up wall or a required form before the app does anything, when its main features don't need an account.
How to fix it and resubmit
- Write or update the privacy policy so it names the data the app collects, how and why, every company it shares data with, how long data is kept and how people can have it deleted. Host it at a public https address.
- Put that address in the privacy policy field in App Store Connect and link the same page from inside the app, somewhere easy to find, such as Settings or About.
- Check your App Privacy answers in App Store Connect against the policy and the app, so all three say the same thing.
- Go through every permission the app asks for: drop the ones the main features don't need, use the system pickers where they will do, write a clear purpose string for the rest, and give people a way forward when they say no.
- Make any sign-up or personal details optional unless the feature really needs them, then reply to App Review saying where the policy link is and resubmit.
How Borel helps
Borel writes a Privacy Policy and Terms of Use for every app it makes, hosts them at the app's own address, and fills the privacy policy address into the App Store listing. When the app reaches an outside service through Borel, the policy names it. Inside the app, the legal links Borel writes open both pages, and Borel's submit gate won't send an app to Apple if people can't open its privacy policy from inside it.
When you publish, Borel answers Apple's App Privacy questions from the app's own code. The privacy file Borel ships in each app declares no tracking, and Stamp checks that every permission the app asks for has a purpose string that says something, and that the code uses nothing that privacy file doesn't declare.
Questions people ask
Does every iPhone app need a privacy policy?
Yes. Guideline 5.1.1(i) says all apps must link to their privacy policy, in App Store Connect and inside the app, even an app that collects little or nothing.
What does Apple require a privacy policy to say?
What data the app collects, how and for what, that third parties it shares data with protect it equally, and how long data is kept, how it is deleted and how people can withdraw consent or ask for deletion.
Can my app make people sign up before using it?
Only when its main features depend on an account. Apple says that if an app doesn't include significant account-based features, people should be able to use it without a login.
What is the difference between 5.1.1 and 5.1.2?
5.1.1 is about collecting and storing data: the policy, consent and asking for as little as possible. 5.1.2 is about what happens to the data afterwards: using it, sharing it with third parties including AI services, and tracking.
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