Privacy Policy for Firefox OS Apps

If you're developing apps for Firefox OS, you'll need to update the "Marketplace Privacy Policy" field when submitting your app to appear in the Firefox Marketplace.

Firefox OS also allows developers to have their Privacy Policy agreements hosted on the Firefox Marketplace rather than placing a link to a URL hosted on the developer's server, e.g. official website of an app.

This method - allowing the agreement to be added to the Marketplace - is also used by Apple's App Store to embed licensing agreements, like Vimeo.com app.

Google Play Store, Apple App Store and Windows Phone Store don't allow this. Developers creating apps for iOS, Android or Windows must host the agreement and only add the URL when submitting the app for review.

Firefox OS Requirements for Privacy Policy

Mozilla is making it clear in their "Privacy policy guidelines" document that a Privacy Policy is recommended, but it's also required as specified in their Developer Agreement page:

Privacy-Related Obligations

You agree to provide end users with a legally adequate privacy policy that accurately describes any collection, use or disclosure of information provided to you by end users. All Apps are required to have a privacy policy. You represent and warrant that any information you are provided from Mozilla about users will be used solely in accordance with your privacy policy and applicable privacy and data protection laws.

You agree to ensure that any advertising presented to end users of your Marketplace Content complies with all requirements of these Terms and your privacy policy in accordance with applicable privacy and data protection laws. For example, (i) embedded advertising and your use of data derived from such advertising must comply with applicable law; (ii) embedded advertising must not contain any “spyware,” “malware” or harmful code and must not cause injury to any person or damage to any property; and (iii) you must provide meaningful notice and choice for any tracking that leads to you or third parties tailoring advertisements or promotions to users.

This applies even if you don't collect any kind of personal information from users or all the data is stored locally:

If your app doesn't collect, use, store, and share or disclose any information about people, simply enter "This application doesn't collect, use, store, and share or disclose any information about the user or any other person." in the Marketplace Privacy Policy field.

That's a best practice: having a Privacy Policy even if your app doesn't collect any kind of personal data from users.

Firefox OS Marketplaces allows the developer to either place the URL to their app's Privacy Policy or place the agreement text inside the field itself.

Here's how to add the URL or update the field:

1. Click Submit An App
2. Read and agree to the "Developer Agreement". Don't forget that it requires you to have this agreement for your app.
3. Choose Free or Paid
4. Select compatible devices for your app
5. Upload or provide the location to your app
6. Add the necessary details of your app and click Continue. At this step, make sure to update the Privacy Policy field (this is a required field.)

Whenever you update the "Marketplace Privacy Policy" field, the "Privacy Policy" button is displayed on your app's page:

Here's how the Facebook app has its Privacy Policy field updated:

It links directly to Facebook's Data Policy page.

Other apps developed for Firefox Marketplace, like ConnectA2, have the full Privacy Policy embedded and made available on their app's Marketplace page:

Privacy guidelines to follow

Here are the guidelines shared by Mozilla for Firefox OS developers in regards to privacy practices of the apps being submitted to the Marketplace:

• Give users control over what kind of personal information to share with you, e.g. if they can opt-out of not providing you with a certain type of personal information, allow them to do so easily
• Limit what kind of personal data you collect. Design your app in such way that you collect the minimum amount of personal data without affecting your business/app to function properly.
• Obtain consent from users on special features, such as geolocation data sharing.

  Here's how iOS geolocation sharing permission shows on iOS:

  

• Place a link to the agreement on the Marketplace, but also make this agreement and other agreements (such as Terms and Conditions) available in the app.

  Here's how Dropbox embeds its Privacy Policy on its iOS app:

  

• Be transparent. Your Privacy Policy must properly inform users about your policy on: accessing, collecting, transmitting, sharing and disclosing personal data.

Examples of Firefox OS apps

The Highway

The Highway, a game developed for Firefox OS, updated its Privacy Policy field to inform users that the game doesn't collect any kind of personal information:

This application doesn't collect, use, store, and share or disclose any information about the user or any other person.

LINE

LINE, the messaging app, is also available for Firefox OS Marketplace and places its Privacy Policy directly on the app page, it doesn't provide a link to its official page on its website:

However, that Privacy Policy for its Firefox OS platform is different from its Privacy Policy hosted on the website:

It's better to have only one single agreement that's shared across all platforms where your app is available: iOS, Android, Windows Phone, Firefox OS, desktop app and so on.

Doing so allows you to easily update the agreement at any time (but don't forget to properly inform users about the changes) without the risk of having separate, old and no longer valid Privacy Policies.

Avoid being in this kind of situation: your app has an old agreement where you specify that you collect certain types of information, but the app was later updated to collect more types of personal data and your Privacy Policy was not updated to reflect this.