Ctrl+Z Therapy
CasesQuick answersGuides10-minute checklistHow we testCartoonSend it in

Does your iPhone app send user data to an AI API? Apple wants permission first

Ship ItChecked against the official sourceNot legal advice.

Source checked 10 Oct 2026 · Published 23 Oct 2026 · Last reviewed 23 Oct 2026 · By Ctrl+Z Therapy (how we test)

The short answer

Apple's App Review Guideline 5.1.2(i) says you must clearly disclose where personal data will be shared with third parties, including with third-party AI, and obtain explicit permission before doing so. Apple announced this clarification, naming third-party AI, on November 13, 2025. Apps that share user data without user consent or otherwise complying with data privacy laws may be removed from sale.

What to do

  1. Find every place your app sends what users type, their photos, messages or other personal data to an AI model like OpenAI, Claude or Gemini.
  2. Before the first AI call, tell users which provider gets what, and ask for their permission.
  3. Give users an easily accessible and understandable way to withdraw consent later, as Guideline 5.1.1(ii) asks.
  4. Ask your AI tool: "Find every place this app sends user data to an AI API. Add a consent screen before the first call that names the AI provider and what is sent, and a setting to turn it off."

Good to know

  • Apple doesn't prescribe what the consent screen should look like.

Source

Checked on 10 Oct 2026. Prices, limits and settings change, so check the source before you rely on them. Not legal advice.

Related