Mexico’s privacy law creates major hurdles for mobile app developers working in the region. Stricter rules mean making sure your apps follow the law is now a top priority. The Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) sets detailed guidelines affecting how apps handle, store, and protect user data.
Following these rules can feel tricky when working with frameworks like OWASP MASVS or matching other major standards like PCI DSS and ISO 27001. The risks of ignoring compliance can be harsh, with fines going up to $1.5 million for bigger breaches. The LFPDPPP lays out clear steps to implement consent tools, clear privacy policies, and strong security protocols.
This guide gives mobile app creators a clear path to meet Mexico’s data privacy laws. It breaks down the law’s coverage, details on consent, privacy notice rules, handling user rights, and the security steps your app needs to take. Doing all this can help you avoid fines and build trust with users in Mexico.
Grasping What LFPDPPP Covers in Mobile Apps
The LFPDPPP now lays out strict rules for apps in Mexico that gather user data. A big update in March 2025 expanded this law increasing the obligations mobile app developers must meet. Learning the basic meaning of the law and knowing which apps it applies to is key when checking if your app is affected.
What Article 3 Says About Personal Data
Article 3 of the LFPDPPP explains what qualifies as personal data under Mexico’s legal framework in clear detail. The law defines personal data as “any information concerning an identified or identifiable individual”. It includes common details like profiles, while also covering things such as device IDs, location details, and patterns tracked by apps on mobile devices.
The law separates sensitive personal data from other types of information. It defines such data as details that involve “the most private areas of the data owner’s life, or whose misuse could result in discrimination or pose a serious threat”. Mobile app creators need to address sensitive information like:
- Ethnic or racial background
- Current and future health details
- Genetic data
- Religious, moral, or philosophical beliefs
- Union membership
- Political opinions
- Sexual orientation
These categories are relevant to apps focused on health, fitness, or social networking that may collect things like biometric data, health stats, or details about a user’s personal beliefs. The LFPDPPP enforces stricter rules to protect these types of sensitive information.
How It Affects App Developers and Data Processors
Mexico’s privacy law applies to three key situations that app developers need to think about:
- When a data controller is based within Mexico’s borders.
- When a data processor operates in Mexico, no matter where the controller is located.
- Processing that happens outside of Mexico but uses Mexican citizens’ data
The law draws a line between data controllers and data processors. It describes a data controller as “an individual or private legal entity that decides on the processing of personal data.” On the other hand, it defines a processor as an entity that “processes personal data on behalf of the data controller.”
Within mobile app ecosystems, both app developers, who often act as controllers, and external service providers working with user data known as processors, must meet legal obligations. If your app gathers information from people living in Mexico, you will need to follow LFPDPPP rules, no matter where your servers operate.
Apps That Don’t Need to Follow LFPDPPP Rules
The law doesn’t cover every app out there. Article 2 states two groups do not have to comply:
- Companies handling credit reports that are governed by other laws.
People gathering and keeping personal data for their own use, without any plans to make money from it or share it with others, are covered.
As a result, personal organization apps keeping contact info on a user’s device and not sharing it with external servers might get an exemption. In the same way simple work contact details saved within a company don’t face strict rules like others.
New app creators must understand one key rule: exemptions disappear as soon as user data is shared, sold, or used in any way beyond personal purposes. If collecting data moves into commercial use, following all rules in the LFPDPPP becomes necessary.
Legal Basis and Consent Guidelines to Collect Data
Obtaining proper consent stands as the key to following Mexico’s data privacy rules for mobile apps. The LFPDPPP lays out clear steps that developers must follow to get user approval before collecting or handling personal data. Knowing these rules allows developers to set up data collection systems that respect the law.
Article 6: Rules for Lawfulness and Consent
Article 6 requires all organizations managing personal data to follow eight essential rules. These rules are:
- Lawfulness: Data handling must align with Mexico’s laws and international standards
- Consent: Organizations need users’ clear and informed approval to process their data
- Notice: Organizations need to give clear privacy policies to inform people before collecting data.
- Quality: Information should stay accurate and up-to-date for proper use.
- Purpose: Data should be processed to meet clear and lawful goals.
- Fidelity: Those handling data must stick to promises made to users.
- Proportionality: Data collection should focus on what is needed.
- Accountability: Entities managing data need to prove that they follow the rules.
Mobile app creators need to build their data collection tools in a way that respects these core principles. Take the consent principle as an example. It means users must give permission , know what it’s for, and have all the necessary details. This means apps must describe the type of data they gather and the purpose behind it before users share any information.
Article 8: Explicit Consent to Handle Sensitive Data
The LFPDPPP sets out different rules for getting consent depending on the type of data being gathered. Article 8 outlines three specific types of consent:
- Tacit consent means individuals agree by not objecting after they get a privacy notice. This applies to basic personal information.
- Express consent is needed for financial or property-related data. People give this , in writing, or .
- Express written consent is necessary when dealing with sensitive personal information. It requires a signed document, an electronic signature, or other forms of verification.
You can find more details in Article 8.
When mobile apps deal with sensitive details like genetic data, religious views racial origins, or health records, just putting up a privacy notice isn’t enough. Developers need to use clear methods to get and keep a record of express written consent. Article 8 also bans making databases with sensitive personal data unless there’s a valid reason tied to the app’s specific purpose.
Article 10: Cases Where Consent Is Not Needed
While consent is required, Article 10 outlines cases where mobile apps can handle personal data without needing user approval. Some of these exceptions are:
- The law demands the data to be processed.
- The data is taken from sources anyone can access.
- Personal information has been anonymized removing its link to individuals.
- Processing is necessary to meet duties in a current legal relationship.
- There is an urgent situation that may risk someone’s safety.
- The data is needed for medical reasons when the person cannot give consent.
- A qualified authority has authorized the data to be processed.
Developers need to know that recent changes have widened these consent exemptions. The law now includes exemptions allowed by any legal source, like decrees or regulations. It also expands authority-based exemptions to cover rulings, resolutions, and court orders.
To implement mobile apps, developers need to document which exemption allows them to process data without direct user consent. Even if no consent is necessary in such situations, developers still have to provide users with a clear privacy notice.
Privacy Notice Rules for Mobile Apps
Privacy notices act as a key part of ensuring transparency in Mexico’s data protection laws. Under the LFPDPPP mobile app developers must explain their data collection practices to users through detailed privacy notices. following these rules not prevents fines but also builds user trust.
Article 15: What Privacy Notices Must Include
Article 15 requires data controllers to tell users what personal data they collect and why they collect it. This duty serves as the basis for creating transparency in mobile apps. Recent changes to the LFPDPPP have simplified and organized privacy notice rules under Article 15. These updates make it easier for developers to apply and understand the requirements.
Article 16 states that a valid privacy notice must include key details such as:
- The identity and address of the data controller gathering the information
- Goals of data processing separating those that are required from those that are optional
- Ways and choices provided to users to control how their information is used or shared
- Steps to take to access, modify, delete, or object to personal data (ARCO rights)
- Information on any planned sharing of data with others
Steps to notify users about updates to the privacy notice
To begin with, applications handling sensitive personal data need to mention this type of classification in their privacy notice. The latest rules also require privacy notices to separate data transfers that need consent from those allowed without explicit approval.
Article 16: Mobile Interface Notice Formatting and Presentation
The LFPDPPP accounts for the specific limitations of mobile device screens by allowing three types of notices:
Full Notice explains everything in detail and works as a standalone document that users can rely on.
Simplified Notice includes a shorter breakdown and provides a way to access the Full Notice .
Short Notice shares the essential basics like the controller’s name, their location, why data is being processed, and how to find the Full Notice.
These formats help deal with the small amount of space on mobile screens. Every type of notice must be written in plain words. It cannot use complicated terms or technical jargon that might be hard to understand.
Article 17: When to Show Privacy Notices
Article 17 sets clear rules on when privacy notices need to be shown, depending on how the information is gathered. For mobile apps, there are two main situations to address:
When users give personal data through the app, the privacy notice must appear right then and there.
When data gets captured using methods like electronic, optical, audio, or visual tools, the company collecting it has to share basic details (like who they are and why they need it) and explain how to see the full privacy notice right away.
Mobile app makers should plan a layered system. They need to show the most important info first and make it simple to find all the details later on. Collecting data should never start before users get the chance to see at least the basic privacy facts.
The law demands that privacy notices be accessible through a variety of formats. These include print digital, visual, or audio methods as well as other technologies suitable for how the data is collected [\3]. In mobile apps, this often means adding in-app screens to display privacy details before any data gets collected.
How to Include ARCO Rights in App Interfaces
ARCO rights act as the key framework that helps Mexican users manage their personal data in mobile apps. To include these rights, app developers need to design user-friendly interfaces. These interfaces should give users control over their data and meet the technical rules required by the LFPDPPP.
Article 22: Access, Rectification, Cancelation, and Objection
Article 22 states that individuals have the ability to use four key rights related to their personal data. These rights are called ARCO rights:
Access: People can ask about the personal data being handled, including what has been saved and why it was collected.
Rectification: They can fix incorrect or incomplete details in their personal data.
Cancellation: They can ask to have their data deleted when it is no longer needed for its original purpose.
Opposition: They can refuse certain kinds of data processing if there are valid reasons.
Mobile app developers must keep personal data in a way that makes it easy for people to use these rights whenever they need to. Using one of these rights does not stop a person from using the other rights, either at the same time or later on.
Article 30: Assigning a Data Rights Officer
Every data controller needs to pick a person or department to manage ARCO rights requests. Article 30 requires this role no matter how large the company is or how much data it handles. The appointed individual or group must:
Handle all ARCO rights-related queries from data owners
Support personal data protection across the organization
In simple terms, your app should make it obvious who users can contact about data requests via the privacy notice. Businesses can meet this requirement by either assigning someone or hiring an outside data protection expert.
Article 33: Refusing Requests and Notifying Users
As per Article 34, there are valid reasons when apps can reject ARCO requests such as specific exceptional cases.
The person making the request is not the data subject or someone authorized to act on their behalf.
Your database does not contain the personal data being requested.
Granting the request would interfere with the rights of a third party.
A legal issue or restriction from an authority prevents the action.
The requested action has already been completed.
If you deny a request, you need to inform the data subject in the same way they submitted it. You must explain why the request was denied. You should also send this notification and in a clear manner to follow Mexico’s data privacy law.
Security, Sharing Data, and Enforcing Penalties
Strong security measures play a key role in Mexico’s data privacy rules for mobile app makers. The LFPDPPP lays out strict rules to ensure user data stays safe at every stage, from when it’s collected to how it’s shared and stored.
Article 19: Keeping Mobile Data Safe
Article 19 requires data controllers to take solid steps to protect personal information against problems like destruction, loss, damage, changes, or illegal access and use. Mobile apps must follow three main types of protections:
- Administrative protections include staff training, company policies, and systems for managing data.
- Physical protections focus on securing devices, installations, and anything that holds personal information.
- Technical protections make sure only the right people can access data using technology.
App developers need to ensure security measures “are not inferior to those they keep to manage their own information” [\7]. While designing security systems, they should evaluate risks, think about possible user harm, consider how sensitive the data is, and look at what technology is available. Since mobile data holds sensitive information, telling users about a breach right away becomes a rule when it might harm their rights.
Article 36: Data Transfers to Third Parties in SDKs
Apps often move data to third parties through analytics SDKs or cloud services, but these transfers demand strict oversight. Article 36 states controllers must “provide them with the privacy notice and the purposes to which the data owner has limited data processing” [\7] during such exchanges.
Transfers to data processors meaning organizations that handle data for controllers, are subject to different guidelines. These transfers don’t need clear user consent if processors meet specific contract rules, keep information private, and apply proper security steps.
Article 64: Penalties for Breaking Rules in Mobile Data Use
Breaking the rules can lead to hefty financial penalties. Article 64 outlines fines starting at 24,893 pesos and going up to 79,657,600 pesos in Mexico, based on a daily minimum wage of 248.93 pesos in 2024. If the violations deal with sensitive data, the fines might even double.
To start, penalties take into account a few factors. These include the type of personal data involved, if the violations were done on purpose, the financial ability of the controller to pay, and their history of following the rules. If sensitive data gets exposed in such cases, fines can go over 2.7 million USD equivalent [\15].
To align with technical standards, you can use frameworks like OWASP MASVS or ISO 27001 to strengthen your app’s security protocols. This also helps you stay in line with larger compliance requirements.
In summary
Mobile app developers working in Mexico must follow the rules set by the country’s LFPDPPP laws. These regulations play a key role in protecting personal data. This guide explored how the law creates a solid system to handle personal information in different ways. Article 3 explains that personal data includes not just basic details like names and emails but also device IDs and user behavior data that apps often gather.
Developers need to collect data by meeting strict consent rules with sensitive data such as health or religion-related information. Written consent is required for such sensitive cases. However, Article 10 allows exceptions under specific conditions like emergencies or when the data is made anonymous.
Privacy notices act as the foundation of transparency within this legal structure. Developers need to use notice formats like full, short, or simplified versions based on how the interface is set up. They should still make sure that users can access all required details before any data gets collected.
Users can use ARCO rights to access, update, delete, or object to their data being processed. These rights need companies to set up special interfaces and assign staff to handle requests .
Security remains a critical part requiring protections in administration, physical setup, and technology to match how sensitive the data is. Ignoring these rules can lead to massive fines running into millions if sensitive personal data is involved.
To comply with Mexican data privacy rules, developers need to understand and apply them during every part of building mobile apps. Setting up solid compliance systems helps developers avoid big fines and earn the trust of Mexican users, which is a useful advantage in a world that values privacy.
