According to a recent study released by the Future of Privacy Forum (FPF), the number of mobile apps with privacy policies has grown rapidly since September 2011. The study examined the top 25 free and 25 paid apps in the Apple iOS, Google Play, and Kindle Fire app stores, for a total of 150 apps. 

Of the apps reviewed, the study found that 69.3% of the free apps and 53.3% of the paid apps had privacy policies. This marked a significant improvement since FPF last conducted the study, which was more limited in scope.  

In addition, the study found that fewer apps today provide access to the privacy policy on the app store landing page (22.7% of free apps, 13.3% of paid apps) than they do from within the app itself or through a link provided within the app (48% of free apps, 32% of paid apps).  Some apps have begun to provide a short form notice that links to a more detailed privacy policy.

The rise in mobile app privacy policies may be attributable to increased attention by regulators at the federal and state level and various self-regulatory industry initiatives to improve mobile app transparency over the last several months.  (See, for example, our posts here, herehere, here, and here.)  While some of these efforts have focused on the process and format of app developers’ privacy policies, others are beginning to look at the substance of the disclosures and how the disclosures compare to the company’s actual practices. 

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Photo of Lindsey Tonsager Lindsey Tonsager

Lindsey Tonsager helps national and multinational clients in a broad range of industries anticipate and effectively evaluate legal and reputational risks under federal and state data privacy and communications laws.

In addition to assisting clients engage strategically with the Federal Trade Commission, the…

Lindsey Tonsager helps national and multinational clients in a broad range of industries anticipate and effectively evaluate legal and reputational risks under federal and state data privacy and communications laws.

In addition to assisting clients engage strategically with the Federal Trade Commission, the U.S. Congress, and other federal and state regulators on a proactive basis, she has experience helping clients respond to informal investigations and enforcement actions, including by self-regulatory bodies such as the Digital Advertising Alliance and Children’s Advertising Review Unit.

Ms. Tonsager’s practice focuses on helping clients launch new products and services that implicate the laws governing the use of endorsements and testimonials in advertising and social media, the collection of personal information from children and students online, behavioral advertising, e-mail marketing, artificial intelligence the processing of “big data” in the Internet of Things, spectrum policy, online accessibility, compulsory copyright licensing, telecommunications and new technologies.

Ms. Tonsager also conducts privacy and data security diligence in complex corporate transactions and negotiates agreements with third-party service providers to ensure that robust protections are in place to avoid unauthorized access, use, or disclosure of customer data and other types of confidential information. She regularly assists clients in developing clear privacy disclosures and policies―including website and mobile app disclosures, terms of use, and internal social media and privacy-by-design programs.