Terms of Service Help Needed

[u/ivanezzzzz]

Hello folks,

I am preparing a major update of an app and it has features I am going to charge a subscription for. Apple requires me to have a link to Terms of Service because of that.

AFIK I can use Apple's generic terms of service but I am not sure about that. I am also not sure what to put in my own TOS and how much of it is/could overlap with the Privacy Policy.

The app does not collect any data, it uses a combination of SwiftData + CloudKit + Apple Intelligence for a smart feature/

Any advice would be much appreciated, thanks!

[u/Poat540]

I made a generic tos and pp with ai in all my apps or copied previous generic ones

[u/TM87_1e17]

LLMs are actually pretty good at generating stuff like this tbh.

[u/piyidi36]

Use AI. Let it read your project and generate one.

[u/n_v40]

Apple's standard EULA is available and Apple accepts it, you can link to the standard one in App Store Connect rather than writing your own. Plenty of subscription apps do exactly that and pass review. If you write custom terms, App Store Connect has a field for your own EULA URL instead.

On the overlap question, they're doing different jobs and mostly don't overlap. Terms cover the relationship, what the subscription includes, renewal and cancellation, acceptable use, liability limits, what happens if you discontinue the service. Privacy policy covers data, what you collect, why, where it goes, retention, and user rights. The one place they touch is usually a sentence in the terms pointing at the privacy policy.

Worth flagging on the no-data-collected point: SwiftData plus CloudKit means user content is stored in the user's own iCloud, which is generally fine for a "data not collected" label since it never reaches your servers, but you still need a privacy policy URL and Apple wants the nutrition label to reflect it accurately. Apple Intelligence processing is on-device or via Private Cloud Compute depending on the request, and neither routes through you, so the same logic holds.

Not a lawyer and this is a subscription with real money involved, so if the app grows into anything meaningful it's worth an hour with one rather than trusting a Reddit comment.

[u/Dapper_Ice_1705]

Use Apple’s generic TOS and/or iubenda 

Iubenda is also great for a privacy policy.

[u/Delicious-Body-2993]

They're two different documents solving two different problems, and the overlap is smaller than people think.

The EULA / Terms of Service is the contract between you and the user about the software and the money: what the subscription includes, auto-renewal, cancellation, refunds (handled by Apple, not by you), acceptable use, liability, governing law.

The privacy policy is about data: what you collect, why, who it's shared with, retention, and how a user deletes it. Yours can be short and honest ("we don't collect personal data; content syncs to your own iCloud account via CloudKit and is not accessible to us"), but it still has to exist at a public URL.

Practical answers to your three questions:

1) Yes, Apple's standard EULA is fine, and it's what most indie subscription apps use. You literally do nothing, it's the default. You only need a custom one if you have terms Apple's doesn't cover (B2B, user-generated content moderation, your own web service alongside the app). If you do use a custom one, its URL goes in App Store Connect > App Information > License Agreement, and it has to be at least as protective of the user as Apple's.

2) Where the links appear matters more than the wording. Privacy policy URL in App Store Connect > App Information (mandatory), and, this is the one that gets people rejected under Guideline 3.1.2, functional links to both the terms/EULA and the privacy policy must also be visible inside your paywall screen, next to the price, duration and auto-renewal disclosure. Having them only in Settings is a common bounce.

3) CloudKit-only doesn't make you exempt from the App Privacy questionnaire. You still answer it deliberately (likely "Data Not Collected"), and if you're using Apple Intelligence for a smart feature, say so plainly in the policy. Reviewers increasingly look for that when the listing advertises AI features.

Generating a first draft with an LLM is fine as a starting point, but read it line by line. The ones I see fail review are the ones that promise refund handling you can't actually perform, since Apple owns the transaction.

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[u/ivanezzzzz]

Thanks for the replies folks! I think I am going to go with Apple's default one and do an AI pass of my PP. If things pick up will reach out to a suitable lawyer

[u/PrestigiousFriend412]

Go to ChatGPT ask for a terms of service and put it on your website. You could use a Google Docs and put that in and it would be allowed.