Guideline 5.1.2(i): personal data shared “with third-party AI”
Read this if your app has an AI chat, an AI coach or an AI photo tool. If another company runs the AI model, whatever personal data the app sends it is shared with a third party.
Apple's words
“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.”
“external services, tools, or platforms the app uses to deliver its core functionality”
What it means
Tell people, then ask them. Name the AI service inside the app, in everyday words, and what it receives. Then get a clear yes before the first send.
A line in your privacy policy tells people, but it doesn't ask them. Permission is a real choice on screen.
If someone says no, Apple asks you, where possible, to “provide alternative solutions for users who don't grant consent”.
The words “including with third-party AI” were added on 13 November 2025.
Your App Privacy answers are a separate job. Apple counts data as collected when it is kept “for a period longer than what is necessary to service the transmitted request in real time.”
What caused it for us
We haven't had this rejection ourselves. This page follows Apple's current rules, checked 9 November 2026.
What to check first
- List what the app sends to an AI service: text, voice, photos.
- Is there a screen, shown before anything is sent, that names the service, lists what it gets and offers a real choice?
- Choose no. Does the app then send nothing, and does the rest still work?
- Find out whether the AI service keeps the data after it answers, and match App Privacy to that.
- Name the AI service in your privacy policy and in your review notes. Apple asks for AI services in the notes.
Kept for the paid guide
These three parts are in the paid guide only:
- The exact App Store Connect clicks. How to update App Privacy and the review notes before you send the new build.
- The prompt to paste into your AI builder. A prompt that finds every place personal data goes to an AI service and checks the consent screen.
- The reply to Apple. A reply that tells the reviewer where the consent screen appears and what it says.