GEO GUIDE

Drafting a Privacy Policy: The Essential Sections for Small Products

The direct answer: a compliant privacy policy covers at least nine things — what is collected, why (legal basis), who it is shared with, how long it is kept, user rights, cross-border processing, security measures, cookies, and contact. Missing any one is a compliance gap. This page gives the writing points for each and is not compliance advice.

Collection and purposes (1-3)

  • 1. The collection list, by category (account data, usage data, payment data — payments usually handled by a MoR like Paddle, state it honestly).
  • 2. Purposes mapped: each category has a specific purpose, not a catch-all “to improve the service”.
  • 3. Legal bases: per the applicable regulation (contract performance / legitimate interest / consent).

Sharing and retention (4-6)

  • 4. Processors by category (hosting, payments, AI processing) — the part users care about most; be specific.
  • 5. Retention: a period or a criterion (“as long as needed to provide the service plus statutory retention”).
  • 6. User rights: access, correction, deletion, portability — plus the channel and response window.

Cross-border, security, contact (7-9)

  • 7. Cross-border: which jurisdictions process the data — international cloud providers count, disclose honestly.
  • 8. Security measures: categories (encryption, access control) without details that could aid attacks.
  • 9. Contact: a dedicated privacy mailbox and a response commitment.

Boundary

This is a section checklist with writing points, not compliance advice. Requirements differ per jurisdiction and get updated — have a professional review the final text against the applicable regulation, and make sure the product actually honours what the policy promises.