It's one of the most common questions from app builders and indie founders: do I actually need a cookie policy?
The short answer is: if your app uses cookies — and most apps do — then yes, you are legally required to tell your users about it.
Here's the longer answer.
What Are Cookies, Really?
Cookies are small files stored on a user's device when they visit your site or use your app. They're used for all kinds of things:
- Keeping users logged in between sessions
- Remembering preferences
- Processing payments (Stripe uses cookies)
- Tracking user behaviour (Google Analytics, Mixpanel, Hotjar)
- Fraud prevention
Even if you haven't deliberately "added cookies" to your app, if you use any third-party tool — a payment processor, an analytics platform, a customer support widget — that tool is almost certainly setting cookies.
When Is a Cookie Policy Required?
Under UK law (the Privacy and Electronic Communications Regulations — PECR) and EU law (the ePrivacy Directive), a cookie policy is required when your app or website:
- Sets non-essential cookies on user devices
- Uses analytics tools (Google Analytics, Plausible, Fathom)
- Uses advertising or retargeting tools
- Embeds third-party widgets (Intercom, Crisp, Stripe)
- Uses session management cookies
The only apps that might genuinely not need a cookie policy are those with no third-party tools, no analytics, and no session management. In practice, that's almost nothing.
What's the Difference Between a Cookie Policy and a Privacy Policy?
A privacy policy covers all personal data — how you collect it, use it, store it, and share it.
A cookie policy focuses specifically on cookies — what types you use, why, and how users can control them.
You need both. Some businesses combine them into one document. Others keep them separate. Either approach works, but keeping them separate makes it easier for users to find the specific information they're looking for.
What Your Cookie Policy Needs to Cover
A complete cookie policy for an app or website should include:
1. What cookies you use
List each cookie or category of cookie. Essential cookies, analytics cookies, payment cookies, preference cookies.
2. Why you use them
Explain the purpose of each type. "We use analytics cookies to understand how visitors use our site" is clear and acceptable.
3. Which third parties set cookies
If Stripe sets a cookie, your policy needs to say so. If Google Analytics sets cookies, name it. Users have the right to know.
4. How long cookies last
Session cookies expire when the browser closes. Persistent cookies last longer — your policy should state how long.
5. How users can control cookies
Explain how to accept, decline, or delete cookies through browser settings. Provide links to instructions for major browsers.
Does My App Store App Need a Cookie Policy?
If your mobile app uses a web view, third-party SDKs, or analytics tools — yes. Apple and Google both require apps in their stores to publish a privacy policy, and a cookie policy should be part of your broader privacy documentation if your app uses tracking tools.
Apple in particular has become increasingly strict about data transparency. Not having a clear data practices policy can result in your app being rejected from the App Store or removed after review.
Getting Your Cookie Policy Right
A cookie policy needs to accurately reflect the cookies your specific app uses. A generic template that lists placeholder cookie names is not compliant and will not satisfy a regulator or a suspicious enterprise customer doing due diligence.
InkTerms generates a personalised cookie policy based on your answers to a short questionnaire. You tell us what your app does, what tools you use, and where your users are based. We generate a complete, accurate cookie policy you can publish immediately.
From £9. Ready in minutes.
InkTerms provides AI-assisted document generation and is not a substitute for professional legal advice. We recommend reviewing any generated document with a qualified legal professional before relying on it for your business.
Originally published on InkTerms Blog
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