Guideline 5.1.1(viii) prohibits apps from aggregating or compiling personal information from third-party sources, including publicly available databases, without explicit user consent. This prohibition applies to both App Store distribution and alternative distribution channels.
This analysis describes what Apple's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision prohibits a category of data aggregation and people-search functionality that is common in data broker and background check applications, and extends the prohibition to alternative distribution channels beyond the App Store. The explicit consent requirement for compiling data from public databases is a substantive restriction on data aggregation business models.
The updated guidelines do not directly affect end users of apps, but they establish new requirements for developers submitting apps to the App Store. Developers must now provide regulatory documentation for apps requiring approval, implement content moderation safeguards for user-generated content and AI content creation platforms, and ensure all app information and creative assets meet specific accuracy and appropriateness standards. Developers who fail to implement safeguards or remediate violations after notice may be considered in violation of the Developer Code of Conduct, potentially resulting in app removal or account termination.
View change record →⚠ Apps that compile personal information from sources other than the user without explicit consent are not permitted on the App Store or alternative distribution and may be removed.
⚠ Developer accounts may be terminated for violating this prohibition.
Cross-platform context
See how other platforms handle Prohibition on Compiling Personal Information Without Explicit Consent and similar clauses.
Compare across platforms →"Apps that compile personal information from any source that is not directly from the user or without the user's explicit consent, even public databases, are not permitted on the App Store or alternative distribution.Excerpt from Apple's App Store Review Guidelines
(1) REGULATORY LANDSCAPE: Data aggregation and people-search applications are subject to FTC enforcement under Section 5 of the FTC Act and, for consumer reporting purposes, the Fair Credit Reporting Act (FCRA).
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision prohibits a category of data aggregation and people-search functionality that is common in data broker and background check applications, and extends the prohibition to alternative distribution channels beyond the App Store. The explicit consent requirement for compiling data from public databases is a substantive restriction on data aggregation business models.
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