10.5.1 Personal Information: privacy policy required

What it means

Policy 10.5.1 says that if your product accesses, collects or transmits personal information, you must have a privacy policy and enter its URL in Partner Center. Product types that inherently have access to personal information always need one, and Microsoft names Desktop Bridge and Win32 products. So a packaged desktop app needs a privacy policy even if you think it collects nothing.

Partner Center can also mark the privacy question as Yes for you if your package declares capabilities that could reach personal information.

How to fix it

1. Write a policy that says what personal information the app accesses, collects or transmits, how it's used, stored and secured, who it's shared with, what controls users have and how they can access their information. Those are the points 10.5.1 lists.
2. Publish it at a URL that opens the policy itself. Microsoft has flagged apps whose link went to a page that didn't show one. Partner Center also lets you paste the policy text instead of a link.
3. In Partner Center, open the Properties page of the submission, answer whether the app accesses personal information and enter the privacy policy. You can also link to it inside the app.
4. Keep it current as you add features, then submit again.