By Scott Thiel, Carolyn BiggLauren Hurcombe and Venus Cheung.

While apps are incredibly popular in China, in recent months some have been disappearing from app stores in the country because they do not comply with recent apps regulations. Indeed many companies are not even aware of the comprehensive new privacy compliance obligations for apps in China.

Under the new framework, app operators in China must:

  • obtain express, voluntary, unbundled consent from app users to processing of their personal information in accordance with clear, concise privacy notices available on the app itself;
  • provide unsubscribe (opt-out) mechanisms for personalized advertisements delivered via the app, and to enable users to de-register their accounts; and
  • undertake a self-evaluation of their apps against 32 stringent and detailed compliance requirements (which are largely focused on the form, format and content of privacy notices/consents rather than the content of the app itself).

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