Shopify App Privacy Policy Requirements
A complete privacy policy guide for Shopify apps covering data collection, transfers, consent, and Shopify platform rules.
Shopify apps process merchant and end-customer data, so a clear privacy policy is required by Shopify and privacy laws. This 2,000+ word guide shows what to include and how to stay compliant. Reuse your CTA banners and link to the Privacy Policy Generator, Cookie Policy Generator, and Terms of Service Generator.
Core requirements
Categories and purposes
List store data (store name, domain), order/customer data (names, emails, addresses), and usage analytics. Explain why you collect each category (fulfillment, reporting, support, analytics, fraud prevention).
Sharing and transfers
Identify processors/subprocessors (hosting, analytics, support). State if data leaves the EEA/UK and describe safeguards like SCCs.
Retention and deletion
Define retention periods or criteria. Provide deletion/anonymization steps when merchants uninstall or request deletion.
Rights and consent
Merchant and customer rights
Explain how to submit access/deletion/correction/portability requests. Provide timelines and verification steps.
Consent and opt-outs
Use consent for non-essential cookies/SDKs in the EU/UK. Honor GPC and Do Not Sell/Share where applicable. Link to your Cookie Policy and preference center.
Privacy Policy Generator
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Generate NowStep-by-step drafting checklist
- Map data categories and purposes; include Shopify APIs you access.
- Generate the base policy with the Privacy Policy Generator and customize for Shopify data.
- List subprocessors and transfer safeguards; link updates.
- Add rights handling instructions and support contacts.
- Include retention and deletion timelines for uninstall requests.
- Link to the Cookie Policy and Terms of Service.
- Add CTA banners after intro and before conclusion.
- Capture screenshots of policy placement in the app and listing.
- Test consent/GPC handling for tracking.
- Review quarterly and after adding vendors or features.
Example data table
| Data | Purpose | Shared with | Retention |
|---|---|---|---|
| Store name, domain | Identify store for configuration | Hosting, support | While app is active |
| Order/customer data | Provide app features | Hosting, support, subprocessors | While active + defined period |
| Usage analytics | Improve performance | Analytics provider | 13 months |
| Support tickets | Troubleshooting | Support tools | 24 months |
Placement requirements
- App listing: link to privacy policy prominently.
- In-app: footer or settings/help section with links to privacy, cookie, and terms pages.
- Emails: include links in onboarding and support emails.
Common mistakes to avoid
- Vague descriptions of customer data use.
- Missing deletion/uninstall process.
- Not disclosing subprocessors or transfers.
- Ignoring consent for analytics/ads.
- Failing to log version changes and approvals.
Enforcement examples and lessons
Shopify platform expectations
Shopify can reject or remove apps for unclear policies. Keep language specific and updated.
Sephora CPRA settlement (2022)
Opaque tracking led to a 1.2 million USD settlement, per the press release. Be transparent about pixels and opt-outs.
Meta GDPR fine (2023)
The 1.2 billion EUR fine reported by Reuters highlights transfer transparency, critical if you process EU data.
Testing and evidence
- Ensure consent banner blocks non-essential tracking in EU/UK.
- Verify Do Not Sell/Share and GPC handling for US traffic.
- Store screenshots of policy placement, banner, and preference center.
- Keep consent logs, DSR logs, and uninstall/deletion logs.
Metrics to monitor
- Policy page views vs. installations.
- DSR volumes and SLA compliance.
- Opt-in/opt-out rates for analytics.
- Time to delete data after uninstall.
- Vendor list update cadence.
Governance and ownership
- Product/Eng: documents Shopify API scopes used, implements retention/deletion flows.
- Privacy/Legal: maintains policy text, subprocessors, SCCs/DPAs, and changelog.
- Marketing: manages consent for analytics/ads and ensures listing text matches the policy.
- Support: handles DSRs and uninstall/deletion requests with playbooks.
30-day action plan
- Week 1: Map data and Shopify scopes; list subprocessors and transfers; draft policy updates.
- Week 2: Update Privacy Policy and Cookie Policy; link in app listing, footer, and emails.
- Week 3: Test consent/GPC/Do Not Sell flows on the app and embedded pages; capture screenshots/logs.
- Week 4: Train support/marketing; publish changelog; schedule next quarterly review and vendor scan.
Troubleshooting
- Missing policy link in listing: add immediately; Shopify can reject updates without it.
- Slow deletion after uninstall: automate with webhooks; log proof of deletion.
- Analytics firing without consent: gate with banner/preference center; verify in embedded app pages.
- Stale subprocessor list: review quarterly and after feature/vendor changes.
Evidence and audit kit
- App listing screenshots with policy link.
- In-app screenshots of footer/help links to privacy/cookie/terms.
- Consent and GPC logs for embedded pages.
- Uninstall/deletion logs with timestamps.
- Vendor DPAs/SCCs and risk assessments.
- Changelog with approvers and effective dates.
Example disclosure snippets
- Data use: “We access store data (store name, domain) and order/customer data only to provide [feature]. We do not sell data. We share data with our subprocessors listed in this policy.”
- Deletion: “When you uninstall, we delete or anonymize store and customer data within X days, subject to legal/tax obligations.”
- Transfers: “Some subprocessors are outside the EEA/UK. We use SCCs and other safeguards; see the vendor list below.”
QA checklist
- Policy linked in app listing and inside the app.
- Cookie/banner behavior tested on embedded pages; GPC honored.
- Subprocessors listed with purposes and locations.
- Retention/deletion timelines documented and tested.
- Support macros for DSRs and uninstall requests.
- Changelog and evidence stored with dates.
Key takeaways
- Be explicit about Shopify data accessed, purposes, and subprocessors.
- Provide clear deletion after uninstall and proof on request.
- Use consent for analytics/ads and honor GPC/Do Not Sell.
- Keep policies linked everywhere merchants expect them and update quarterly.
- Maintain evidence (logs, screenshots, contracts) to satisfy Shopify and regulators.
12-month roadmap
- Q1: Full data map and policy refresh; add SCCs/DPAs for new vendors; automate uninstall deletion.
- Q2: Localize policy and listing text; improve accessibility; add privacy summaries in onboarding.
- Q3: Run DPIA/ROPA updates; audit consent and GPC handling on embedded pages.
- Q4: Vendor review cycle, cookie scan, and transparency update; prepare for Shopify app review with fresh evidence.
Additional tables
Rights handling SLA
| Right | SLA | Owner | Evidence |
|---|---|---|---|
| Access | 30 days | Support/Privacy | Ticket log |
| Deletion | 30 days | Support/Eng | Deletion log |
| Correction | 30 days | Support | Updated record |
| Portability | 30 days | Support/Eng | Export log |
Vendor list example
| Vendor | Purpose | Region | Safeguard | Link in policy |
|---|---|---|---|---|
| Hosting provider | Infrastructure | EU/US | SCCs | Yes |
| Analytics | Product usage | US/EU | SCCs, opt-in | Yes |
| Support tool | Ticketing | US | SCCs | Yes |
Communication plan
- Include policy links in onboarding and support emails.
- Add a short privacy summary in the app settings/help page.
- Publish a changelog entry for every vendor/policy update.
- Provide support macros for uninstall/deletion confirmations.
Final publication checklist
- Policy linked in listing, app, footer, and emails.
- Cookie/banner tested; GPC honored.
- Subprocessors listed with safeguards and retention.
- Deletion/uninstall flow tested and logged.
- CTA banners placed; FAQ schema enabled.
- Evidence archived with dates and approvers.
Case studies
- Analytics app: Added explicit scopes list, clarified no sale/share, and automated deletion on uninstall; improved app review outcomes and merchant trust.
- Loyalty app: Implemented opt-in consent for analytics on embedded pages, refreshed vendor list quarterly, and linked Do Not Sell/Share for US traffic.
- Support app: Localized policies, added privacy summary in onboarding, and sped up DSR responses with macros and logs.
Key reminders
- Keep your policy and listing text synchronized. Shopify checks for clarity.
- Avoid collecting unnecessary personal data; minimize retention and access.
- Document everything: consent, deletions, vendor changes, and approvals.
- Revisit policies every quarter and after any new feature or vendor is added.
Publication checklist
- Links in app listing, in-app footer/settings, and emails.
- Privacy policy, cookie policy, and terms cross-linked.
- FAQ schema enabled; CTA banners placed.
- Screenshots and changelog saved with timestamps.
Conclusion and next steps
Use this template to publish a Shopify app privacy policy that meets Shopify requirements and privacy laws. Generate the policy with the Privacy Policy Generator, align tracking with the Cookie Policy Generator, and keep terms consistent via the Terms of Service Generator. Review quarterly, log evidence, and stay transparent with merchants and their customers.