Why iTC app privacy policy is not optional anymore?
Sorry, I found answer by myself:

https://developer.apple.com/app-store/review/guidelines/#privacy


  Apps that collect user or usage data must have a privacy policy and secure user consent for the collection. This includes—but isn’t limited to—apps that implement HealthKit or other health/medical technologies, HomeKit, Keyboard extensions, Apple Pay, Stickers and iMessage extensions, include a login, or access user data from the device (e.g. location, contacts, calendar, etc.).


My app is using HealthKit for workouts on Apple Watch (but not collect any data).