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Founder of Euverify | EU & UKCA Compliance Expert
Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.
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GDPR Representatives for Mobile Apps: What Developers Need to Know
There are more than 3 billion smartphone users worldwide, and millions of applications available on the App Store and Google Play. Mobile apps have become part of everyday life, but they also collect and process a lot of personal data, which can create compliance challenges.
If you’re a developer outside the EU or UK, you still need to follow their data protection rules. One requirement that often catches app makers by surprise is GDPR Article 27, which mandates that certain companies appoint a local representative in the EU or UK.
In this post, we’ll break down what that means, why it matters for your app, and how you can stay compliant without slowing down your global growth.
What Is GDPR Article 27 and Why Does It Apply to Mobile Apps?
Under Article 27 of the GDPR, non‑EU entities processing data from EU individuals must appoint a local representative. As the IAPP clarifies, “Most companies outside the EU must designate a representative in the EU if they process personal data of EU residents and have no EU establishment.”
Similarly, the UK GDPR also sets this requirement for non-UK organisations. The ICO states: “As you will not have a base inside the UK after the transition period ends, the UK GDPR will require you to appoint a representative in the UK.”
In simple terms Article 27 likely applies to you, if your mobile app:
- Is available to users in the EU or UK,
- Collects personal data (such as names, emails, IP addresses, geolocation, or device data),
- Tracks user behavior (via cookies, analytics, or in-app tracking), or
- Offers subscriptions or services to residents in these regions,
The representative acts as your local contact, both for regulators (like the ICO in the UK or CNIL in France) and for users who want to exercise their GDPR rights.
Key Triggers That Require a GDPR Representative for Mobile Apps
A lot of app developers think that if they don’t have an office or team in the EU or UK, GDPR doesn’t apply to them. But that’s not true. For mobile apps, the main triggers that make Article 27 compliance necessary include:
- App availability in the EU/UK: If your app is available in EU or UK app stores, this may indicate targeting those markets — especially when combined with other factors (language, currency, local ads).
- In-app purchases in euros or pounds: Letting users pay in local currency shows that you’re targeting those regions commercially.
- Use of analytics and SDKs: Many apps rely on third-party SDKs (like Firebase, Mixpanel, or Facebook SDK) that automatically collect user data. Under the GDPR, this is considered behavioural monitoring — especially when those SDKs track the behaviour, location, or preferences of EU/UK users.
- Push notifications based on actions or location: Sending tailored notifications like this is seen as profiling and behavioral analysis.
- Advertising with geotargeting or local language: Running ads in local languages or aimed at EU/UK users signals clear targeting of those markets.
Unless your data processing is truly occasional, very limited, and carries no real risk to people’s rights, you probably won’t qualify for an exemption.
Third-Party SDKs and GDPR Risk in Mobile Apps
Mobile apps rarely work completely on their own. Most developers use third-party SDKs (Software Development Kits) to handle things like crash reporting, analytics, push notifications, payments, or ads. But these SDKs often collect, share, and process personal data and this brings your app under the scope of GDPR.
Common SDKs that may trigger GDPR applicability:
- Firebase (by Google) – Collects analytics, crash data, and user behavior metrics
- Facebook SDK – Gathers device data, ad attribution metrics, and user interactions
- Appsflyer or Adjust – Tracks installs and in-app activity for attribution
- OneSignal – Manages and targets push notifications (including behavior-based triggers)
- Stripe or PayPal SDKs – Involve personal and payment data collection
If these SDKs are active while someone in the EU or UK uses your app, regulators may view it as monitoring user behavior. That alone can trigger GDPR Article 3(2)(b) — and with it, Article 27.
Even if data is labelled “anonymous,” it may still count as personal data if it can be tied back to a user or device (for example, through device IDs or location data).
Best practice: Review all SDKs in your app, explain their behaviour clearly in your privacy notice, and make sure they’re listed in your Record of Processing Activities (RoPA) managed by your GDPR representative.
What Does a GDPR Representative Actually Do for Your Mobile App?
A GDPR representative is a natural or legal person established in the EU or UK who:
- Acts as the official point of contact for local regulators and users
- Facilitates Data Subject Rights (DSARs) requests by ensuring they are passed to your business for action.
- Maintains a copy of your Records of Processing Activities (RoPA)
- Supports investigations or enforcement actions if they arise
- Ensures communication lines remain open and compliant during a breach or complaint
Your representative isn’t personally liable for your app’s data protection issues, but they do need to be reachable and cooperative with regulators. They must be formally appointed in writing and clearly named in your app’s privacy notice. That is, named in your privacy notice, which should be easily accessible to users — for example, within the app itself and (where relevant) in your app store listing.
Dual Representation: EU and UK GDPR Reps Are Separate
Since Brexit, the EU GDPR and UK GDPR are separate legal regimes. Here’s what that means for app developers:
- If your app targets users in both regions, you’ll need two GDPR representatives. One in the EU and one in the UK.
- Your privacy policy must list both representatives, with clear contact details.
- Each representative must be able to receive user requests and regulator communications under their respective law.
Missing one of these steps can draw regulatory scrutiny from either side, even if you’ve partially complied.
App Store Listing Requirements & GDPR Transparency
Apple and Google require developers to explain how personal data is collected, used, and shared. While many see this as just a UI/UX step, it’s also an important GDPR transparency requirement, especially when you’ve appointed a representative.
iOS App Store (Apple):
- Requires a Privacy Policy URL that users can access before downloading the app
- Developers must complete App Privacy Details in App Store Connect
- You should include your GDPR representative’s contact in your privacy policy
Google Play Store:
- Requires you to fill out a Data Safety Form
- Privacy policy must be linked and accessible from your app listing
- Google recommends explaining how users can exercise their data protection rights.
Best practice: Your privacy policy should clearly include your GDPR representative’s name, physical address, and contact email in the URL linked from both app stores. Make sure this information matches the details your representative has access to in your compliance records. The privacy policy should also be easy to find within the app itself, for example under Settings > Legal or About.
What Happens If You Don’t Appoint a GDPR Representative?
Failing to comply with Article 27 can lead to:
- Fines of up to €10 million or 2% of global annual turnover under Article 83(4)(a) GDPR
- Public reprimands or even app store takedowns, especially if your privacy notice is incomplete
- Delayed approvals or feature rollouts due to legal reviews from platform partners
- Loss of trust and credibility with EU/UK users who expect transparency and GDPR compliance
A well-known case is Locatefamily.com, which was fined €525,000 by the Dutch regulator for failing to appoint an EU representative while making the personal data of millions of individuals, including EU citizens, publicly accessible.
How Mobile App Developers Can Appoint a GDPR Representative
Here’s a step-by-step guide tailored for app developers:
- Confirm Applicability
- If you collect personal data from EU/UK users or offer services there, Article 27 applies.
- Select a Qualified Representative
- Must be based in the EU and/or UK.
- Should have GDPR knowledge and infrastructure to manage requests.
- Sign a Mandate Agreement
- This document officially authorises the rep to act on your behalf.
- Update Your Privacy Policy
- Add rep contact details both in the app and your app store listing.
- Maintain RoPA & Share with Rep
- Ensure the representative has access to documentation on what data is collected, how it’s processed, and shared.
- Train Your Team
- Make sure your devs, marketers, and support staff know when and how to refer issues to the GDPR rep.
Common Mistakes Mobile Developers Make With GDPR Article 27
Understanding GDPR is one thing and applying it correctly in practice is another. Here are some of the most common (and risky) mistakes mobile app developers make with Article 27 compliance:
- Assuming the App Stores “cover you”
Just because your app is listed on the App Store or Google Play doesn’t mean you’re automatically GDPR-compliant. These platforms don’t take responsibility for how your app handles user data. - Using a “mailbox” representative with no privacy expertise
Some low-cost services offer GDPR representation for just a few dollars a month, but they don’t actually respond to regulators or keep the required documentation (like your RoPA). This leaves you non-compliant — and exposed if you’re audited. - Omitting representative details from the privacy policy
GDPR requires your representative to be clearly listed, including their name, address, and contact information. Many apps either skip this entirely or bury it in legal jargon, which won’t meet compliance standards. - Failing to disclose SDK data flows
If your analytics or crash reporting SDKs send data to third parties, this has to be made clear in your privacy notice. Regulators have already penalized companies for leaving out this level of transparency.
Run a full privacy audit of your app, including the backend and any SDK integrations. Make sure your GDPR representative knows exactly what data you’re collecting and where it’s going — because if regulators come knocking, they’ll be the ones answering.
Best Practices for In-App Privacy Compliance
- Use clear, layered consent for things like location access, contact syncing, or push notifications.
- Provide users with an easy way to contact your GDPR representative or file a data request.
- Regularly audit your third-party SDKs to ensure they meet EU/UK standards.
- Be transparent about how you use analytics, crash reports, or behavioral data.
Final Thoughts: Don’t Let GDPR Article 27 Be an Afterthought
If you’re a mobile app developer or SaaS provider outside the EU or UK, GDPR almost certainly applies to you. Skipping Article 27 compliance can create serious legal and commercial risks.
The upside? Appointing a GDPR representative is a straightforward step with a big impact. It shows both regulators and users that you take data protection seriously.
At Euverify, we provide GDPR representative services built for mobile apps and tech platforms. We’ll help you meet EU and UK requirements, manage documentation, and handle regulator and user requests — making sure compliance never slows your growth.
Need a GDPR Representative for Your App? Contact Euverify today to stay compliant, build user trust, and protect your mobile business across Europe and the UK.
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