There is a new New Privacy Policy Requirements For Mobile Apps In China. One of rules is "They must be in a pop-up message, either on your landing or login page."

Can a full screen be alternative? I am looking for official confirmation that it is has to be pop up, and a full screen alternative is not law compliant.

I am designing for giant company which want/has to be fully law compliant.

Here is a link to the new requirements: https://www.appinchina.co/blog/new-privacy-policy-requirements-for-mobile-apps-in-china/

  • 2
    I’m voting to close this question because questions about the rationale behind laws is not a legal topic, it's a political one.
    – user6726
    Jul 8, 2020 at 23:23

1 Answer 1


The page you referenced contains a link to the relevant announcement, dated October 31, 2019 (released November 6, 2019) which does not really prescribe any such micro-managed "specific requirements" as they claim.

(For example, via Google translate description of the eight issues they are addressing)

(1) Illegal collection of user personal information

  1. "Privately collect personal information". That is, the APP does not clearly inform the purpose, method and scope of collecting and using personal information and collects the user's personal information before obtaining the user's consent.

  2. "Over-range collection of personal information". That is, the APP collects personal information, is not necessary for the service or there is no reasonable application scenario, and collects personal information over the range or frequency, such as address book, location, ID card, face, etc.

(2) Unauthorized use of user personal information

  1. "Privately shared to a third party". That is, the APP shares with other applications and uses the user's personal information without user consent, such as device identification information, product browsing records, search usage habits, and commonly used software application lists.

  2. "Force users to use directional push function". That is, the APP does not inform the user, or does not mark it in a prominent way, and uses the collected user search, browsing history, usage habits and other personal information for targeted push or precision marketing, and does not provide the option to turn off the function.

(3) Unreasonable request for user rights

  1. "Do not give permission without permission". That is, when the APP is installed and running, the user is asked for rights that are not related to the current service scenario. After the user refuses to authorize, the application exits or closes.

  2. "Frequently apply for permission". That is, after the user explicitly rejects the permission application, the APP frequently applies to open the address book, positioning, SMS, recording, camera and other permissions that are not related to the current service scenario, harassing the user.

  3. "Excessive permission". That is, when the user does not use related functions or services, the APP applies in advance to open the address book, positioning, SMS, recording, camera and other permissions, or exceeds its business functions or services, apply for address book, positioning, SMS, recording, camera and other permissions .

(4) Setting up obstacles for user account cancellation

  1. "It is difficult to cancel the account." That is, the APP does not provide users with an account cancellation service, or sets an unreasonable obstacle to the cancellation service.

That is the problem statement, the announcement says they want the companies collecting information to fix the problem themselves or it will be legislated on them.

It's now 2020 and the Ministry has engaged a third-party testing agency to verify applications, and has given a small number of them notice to fix problems or be removed by specific dates). The first batch has already passed the due date, the second by mid-July.

I did not find a link to the actual law, but the Ministry announcements of non-compliant applications referred to the requirement to "clearly inform" the user of what the app was doing.

Without a native Chinese-speaking lawyer who is app-savvy to find and interpret the actual regulations it's going to be hard to give a specific answer to the question of how to meet the requirements.

For MIIT announcements you can search this site using the English term APP and you will get a number of relevant results (all in Chinese, of course).

  • 1
    Hey Spehro! Thank you so much for your really informed and detailed answer. It helped me a lot. We decided to go with full modal, but taking care it's still clear and straightforward for user to know for what he is giving a consent.
    – Jerry
    Jul 13, 2020 at 6:21

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