App legal requirements in Ukraine
Which privacy law applies to an app run from Ukraine, who enforces it, the pages you must publish, and what each store adds on top.
The short answer
An app operated from Ukraine answers to the Law of Ukraine on Personal Data Protection, enforced by the Ukrainian Parliament Commissioner for Human Rights. On top of that, each store you ship on has its own requirements, which are contract terms rather than law and are stricter in places.
Put together, a paid app on both stores from Ukraine publishes 6 pages: Privacy Policy, Terms of Service, Account and data deletion page, Cookie Policy, Refund Policy, End User License Agreement.
What is specific to Ukraine
- Law that applies: the Law of Ukraine on Personal Data Protection.
- Who enforces it: the Ukrainian Parliament Commissioner for Human Rights.
- Language your users read: Ukrainian. Terms and a privacy policy in a language your buyer does not speak are worth little, whatever they say.
- Published legal notice: not generally required in Ukraine; the operator details live in the privacy policy and the terms.
- Pages this produces: Privacy Policy, Terms of Service, Account and data deletion page, Cookie Policy, Refund Policy, End User License Agreement.
- Cookies and SDK identifiers: disclosure is the main duty; prior consent is required in fewer situations than under the GDPR.
What each store asks for on top
- A privacy policy URL in App Store Connect and in the Play Console, reachable without signing in.
- A deletion page on the open web, which Google Play asks for and which most rejected submissions were missing.
- An end user licence agreement, either Apple's standard one or your own carrying Apple's required clauses.
- Data safety answers in the Play Console that agree with the policy, word for word where it matters.
The order to do it in
- Write down what the app actually does with data. Everything else is derived from this.
- Generate or write the pages, and put them somewhere permanent.
- Paste the URLs into App Store Connect and the Play Console.
- Fill in the data safety form so it agrees with the policy.
- Read the pages once, properly, before you submit.
Where people go wrong
- Using a US template, which names the wrong law and offers rights that do not exist here.
- Publishing a deletion route that lives only inside the app, which Google Play rejects.
- Store metadata that says less than the policy does.
- A hosting link that expires a few months after launch.
Keeping it true after launch
A legal page stops being true the moment the product moves past it, usually by adding a payment provider, an analytics SDK or a sign-in. Under the Ukrainian data protection law the drift is yours rather than your vendor's, and the Ukrainian Parliament Commissioner for Human Rights is who hears about it.
- Re-read it whenever you add a dependency that sees user data.
- Re-check what loads on the page after any change: the cookie notice and the policy have to agree.
- Keep the URL stable. Changing where a policy lives breaks every listing that points at it.
Common questions
Does the Ukrainian data protection law apply if my company is elsewhere but I live in Ukraine?
Two things bring you under a regime: being established there, and reaching people who are there. An establishment in Ukraine is enough on its own. Most modern privacy laws also reach a company outside the country when it targets people inside it, and the Ukrainian data protection law is written that way, so being elsewhere is not on its own an answer. If both could apply, write to the stricter one.
Do I need a lawyer?
Not to publish a first version. You do once there is revenue, staff, or a complaint, and the generated documents are a much better starting point for that conversation than a blank page.