App legal requirements in Spain
Which privacy law applies to an app run from Spain, who enforces it, the pages you must publish, and what each store adds on top.
The short answer
An app operated from Spain answers to the General Data Protection Regulation (GDPR), enforced by the Agencia Española de Protección de Datos (AEPD). 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 Spain publishes 7 pages: Privacy Policy, Terms of Service, Account and data deletion page, Cookie Policy, Refund Policy, End User License Agreement, Legal notice.
What is specific to Spain
- Law that applies: the General Data Protection Regulation (GDPR).
- Who enforces it: the Agencia Española de Protección de Datos (AEPD).
- Language your users read: Spanish. Terms and a privacy policy in a language your buyer does not speak are worth little, whatever they say.
- Published legal notice: expected in Spain. It names the operator and how to reach them, and it is a common omission.
- Pages this produces: Privacy Policy, Terms of Service, Account and data deletion page, Cookie Policy, Refund Policy, End User License Agreement, Legal notice.
- Cookies and SDK identifiers: consent before they run, not after.
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 GDPR the drift is yours rather than your vendor's, and the Agencia Española de Protección de Datos (AEPD) 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 GDPR apply if my company is elsewhere but I live in Spain?
Two things bring you under a regime: being established there, and reaching people who are there. An establishment in Spain is enough on its own. So is offering a service to people in the region, or monitoring their behaviour there, with no company and no server in it, which is what Article 3(2) says in as many words. 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.