App Sales Location Risk Checklist - Startups Edition
• 07 Aug 25
"If your app is your shopfront, then every tap, swipe, and click is a legal risk.” - Matt Glynn
Introduction
Selling through an app gives startups instant global reach. But app stores are rule-heavy environments, and the risks - from compliance breaches to IP lawsuits - are real.
Use this checklist to test whether your app sales location is legally safe and commercially sound.
40-Point App Risk Checklist
App Store Rules: Have you reviewed Apple/Google developer agreements?
Approval Process: Do you know the criteria your app must meet to be accepted?
Review Updates: Do you track rule changes and update your app accordingly?
Privacy Policy: Does your app publish a compliant privacy policy?
Cookie/Tracking: Are users properly informed about tracking technologies?
User Consent: Is consent gathered explicitly where required (e.g., GDPR)?
Data Security: Is personal data encrypted at rest and in transit?
Data Storage: Do you know where user data is stored (jurisdiction)?
Data Breach: Do you have a notification plan if there’s a breach?
Payment Gateway: Does your payment provider meet PCI-DSS standards?
In-App Purchases: Are you complying with Apple/Google rules on IAPs?
Refund Policy: Do you have clear refund terms aligned with consumer law?
Consumer Law: Are B2C consumer protection obligations covered?
Disclosures: Do you provide upfront information on pricing and terms?
Delivery Obligations: If goods are sold, are delivery timelines clear?
Terms of Use: Are your app’s terms enforceable (with acceptance captured)?
Jurisdiction: Do your terms specify governing law and dispute resolution?
Dispute Handling: Is there a clear process for user complaints?
IP Ownership: Do you own all app code, content, and branding?
Third-Party Rights: Do you have licences for external libraries or content?
Trademark Check: Have you checked your app name/brand is free to use?
Accessibility: Does your app meet accessibility standards (WCAG)?
Age Restrictions: Are there measures for underage users if relevant?
Advertising Rules: Do ads in your app meet legal and platform standards?
Employment Law: Are contractors building the app properly engaged?
Open Source Use: Are open source licences tracked and compliant?
AI/Content Use: If AI is used, do you own the outputs/data legally?
Cyber Protection: Is your app penetration-tested for vulnerabilities?
Incident Response: Do you have a security response plan in place?
Insurance Cover: Do you carry cyber or liability insurance for your app?
Third-Party Links: Do you check liability for linked external content?
Marketplace Risk: Can your app survive if banned by Apple/Google?
Competition Law: Are your practices compliant with antitrust rules?
User Generated Content: Do you moderate or filter what users post?
Take-Down Rights: Do you have rights to remove abusive users/content?
Cross-Border Reach: Do you understand which country laws apply to your users?
Continuous Monitoring: Do you review app compliance annually?
Legal Team Access: Do you have access to quick, pragmatic legal advice?
How GLS Can Help You
By building your own legal team on the GLS platform you will be able to:
◼️Draft enforceable app terms of use and in-app purchase policies.
◼️Put in place privacy and consent mechanisms that comply globally.
◼️Review payment gateway and in-app purchase terms.
◼️Ensure compliance with consumer law where B2C obligations apply.
◼️Defend your intellectual property and check freedom to operate.
◼️Support with app store compliance and developer agreement reviews.
◼️Advise on data protection, breach planning, and cyber resilience.
◼️Deliver rapid red flag reviews for urgent app launches.
By establishing your legal team with GLS, you’ll turn legal from a cost centre into a growth enabler.
Observations and Tips
- App stores are highly regulated environments: Startups must comply with platform rules in addition to general legal requirements.
- Privacy compliance is essential: Clear policies, consent mechanisms, and transparent data practices are required for user data handling.
- Data security and storage location matter: User data must be securely stored and properly protected, especially in cross-border contexts.
- Payments and in-app purchases require strict compliance: Financial transactions must follow platform rules and applicable payment regulations.
- IP ownership must be clearly defined: All app code, content, branding, and third-party assets should be properly owned or licensed.
- Third-party tools increase legal exposure: APIs, libraries, and integrations introduce additional licensing and compliance obligations.
- App store dependency is a major business risk: Policy changes, rejection, or removal can directly impact revenue and operations.
- Continuous compliance is necessary: Legal and platform requirements evolve, requiring ongoing monitoring and updates.
- Overall insight: App businesses must manage legal, technical, and platform risks together to ensure stable growth and uninterrupted distribution.
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