I have made an open-source desktop app. I don't collect any personal data in it. The app only has logging that logs how the app performs and e.g. what events and actions are triggered, but the logs stay on the user's device unless they share it themselves. In this case, is a privacy policy required? If yes, where would I put it? A popup before the user downloads the app, or a popup when the user opens the app?
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You should probably have a privacy document that states that you don't collect any information.– BarmarCommented Jul 8 at 14:59
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1 Answer
Under rules like GDPR, if your app never, ever transmits any data, then the app does not need a privacy policy.
Same if it manages to transmit data without transmitting personal data, but doing that is very difficult. Things like IPs may become personal data ... so the safe way is to think of an app which never transmits any data as safe and to treat any data an app may transmit as personal until proven otherwise.
But if you are going to distribute the app yourself, your means of distribution will need a policy. Say you have a download server which sets cookies, or even writes IPs in an access log, and you need a plan how long you save the logs and how you delete it.
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@Trish, that's true in the default case. The IP of a public wifi access might not be personal data, but telling that apart is rather difficult. Hence my suggestion to treat all data as personal unless one did the analysis.– o.m.Commented Jul 8 at 4:11