HK OPC Instant Messaging App Terms


On Jan. 11, HK OPC advised users re instant messaging app changes.


  • HK OPC terms of service and privacy policy privacy changes on instant messaging app.
  • Privacy Commissioner appealed to users, to carefully consider the new terms, policy.
  • Sharing Information with App Parent
  • Per announced changes users would need to agree to share their information with the messaging app parent company and its subsidiaries, if they wish to continue using it.
  • Users have to agree to the terms of service and privacy policy on or before Feb. 8, 2021, as otherwise they cannot continue to use their accounts on the messaging app.
  • Privacy Concerns
  • HK OPC concerned the data to be shared includes substantial amount of personal data.
  • Thus appealed to users, to be aware of the changes, carefully consider the new terms.
  • Also to take note of data types to be shared, how they will be used under new terms.
  • Users should consider, in particular, if they are willing to transfer their personal data to companies associated with the messaging app for storage and use.
  • If users choose not to consent, they should make preparations to back up their data.
  • Parents are also reminded to, as far as possible, provide appropriate guidance to their children who use the messaging app as many children have phones and use it.
  • Request to Messaging App
  • To clearly explain to users the arrangements for sharing of personal data under new terms, the personal data involved and how the data will be used.
  • To extend period for consideration by users to allow ample time to assess new terms.
  • To consider excluding users of the messaging app who do not have accounts on the online social platform concerned (associated company) from the new terms.
  • To consider providing practical alternatives to users who do not agree to the new terms and privacy policy so that they can continue using the messaging app.
  • Other Aspects
  • According to the to-be-updated terms of service and privacy policy announced user information will be shared with messaging app’s parent company and its subsidiaries.
  • To help operate, provide, improve, understand, customize, support and market its services and related products; release provides a list of the data to be shared.
  • Effectiveness
  • At present the deadline for users to agree to new terms is Feb. 8, 2021.

Regulators HK OPC
Entity Types CNSM; Corp
Reference PR 1/11/2021
Functions Compliance; Legal; Operations; Privacy; Risk; Technology
Countries Hong Kong
Products Corporate
Regions AP
Rule Type Guidance
Rule Date 1/11/2021
Effective Date 1/11/2021
Rule Id 95200
Linked to
Reg. Last Update 1/11/2021
Report Section International

Last substantive update on 01/12/2021