Objective: Trust and accessibility are vital to adoption of health and wellness apps. This research scoped three elements of cognitive accessibility of health app privacy policies: availability, ease of navigation, and readability.

Methods: For this cross-sectional study, quantitative data collected in the Netherlands, Sweden, and the United Kingdom included: whether privacy information was in a country's official language (availability); number of distracting visual elements (ease of navigation); word count and Common European Framework of Reference (CEFR) reading level (readability). Health app privacy policies were compared to policies from a purposively selected sample of websites, and to benchmarks, including CEFR reading level B1.

Results: Health app privacy policies were less often available in countries’ official languages compared to sampled websites (Chi-Square [1, 180] = 57.470, p < 0.001) but contained fewer distracting visual elements. More UK privacy policies were in the country's official language, whereas Swedish privacy policies contained fewest words and fewest potentially distracting design elements. Only one privacy policy met the CEFR reading level benchmark.

Conclusions: Lack of privacy information in non-Anglophone app-users’ native languages and high reading levels may be major barriers to cognitive accessibility. Web and app developers should consider recommendations arising from this study, to stimulate trust in and adoption of health and wellness apps.