GDPR Compliance for Mobile Apps — EU Representative Required

Mobile app developers outside the EU who have EU users face significant GDPR obligations. From App Store/Play Store privacy labels to SDK data collection, every mobile app that processes EU user data must comply — and Article 27 requires an EU Representative.

Does GDPR Apply to Mobile Apps?

Yes. Mobile apps collect extensive personal data: device IDs, IP addresses, location data, in-app behaviour, contacts, photos, payment data. If any of your app’s users are located in the EU, GDPR Article 3(2) applies. App Store and Google Play do not handle GDPR compliance for you.

App-Specific GDPR Issues

SDK Data Collection

Analytics SDKs (Firebase, Amplitude, Mixpanel), ad SDKs (AdMob, AppLovin), and crash reporting tools (Sentry, Crashlytics) all collect personal data. You are responsible for what the SDKs in your app do with EU user data.

App Tracking Transparency (ATT)

Apple’s ATT framework interacts with GDPR. ATT’s “ask permission” model aligns with GDPR consent requirements, but GDPR also requires documented consent records, not just a one-time prompt.

Children’s Apps

Apps directed at children under 16 face GDPR Article 8 parental consent requirements, COPPA obligations (if US-based), and heightened compliance standards. See Education guide →

Push Notifications

Push notification tokens are personal data. EU user consent is required before sending push notifications.

Privacy Labels and Data Safety

Apple’s App Store Privacy Labels and Google Play’s Data Safety section require you to declare your data collection practices honestly. These declarations are legally relevant — discrepancies between your label and actual data processing can constitute a GDPR violation.

3-Step Compliance for App Developers

1. Appoint EU Shield as your EU Representative
2. Audit SDKs — understand what data each SDK collects from EU users
3. Update Privacy Policy — include data processing details for all SDKs and features

Get started →