If your application collects personal information or we think it might collect personal information then you need a privacy policy.
The detail can be found at 4.1.1 Your app must have a privacy statement if it collects personal information and thankfully it is now much more explicit.
The two areas that caught companies out were:
“I’m not collecting personal information, I’m just using the internet. But i failed???”
However, an IP address is personal information and declaring Internet capabilities such as internetClient and internetClientServer in the app manifest makes us think you’re collecting the IP number of the user. You will need a privacy policy
“I have a privacy policy in my listing, yet I failed???”
That is because you need it in the description page for your application and in the applications settings as displayed from the Windows Settings charm.
Resources: