WeChat

WeChat is a popular multipurpose messaging application owned by Chinese conglomerate Tencent.

3.7/10

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Handling

Does the policy allow personally-targeted or behavioral marketing? Yes

0/10

Does the service allow you to permanently delete your personal data? Yes, using an automated mechanism

5/5

Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.

Score

Yes, by contacting someone

60%

Yes, using an automated mechanism

100%

N/A

The service doesn't collect any personal information.

100%

Citation

You can delete your account, or remove certain personal information, by logging into your WeChat account and following the account deletion instructions here. If there is any other personal information you believe we process that you would like us to erase, please complete the request form here.

[...]

We destroy personal information upon the extinguishment of need for such personal information, such as the expiration of its retention period and achievement of its purpose for processing, except where there is a law or regulation that requires us to retain that personal information. Inactive accounts are automatically deleted after 180 days (except if you have a positive balance in your WeChat Pay account or are an authorized account holder for the purposes of a WeChat feature such as a Mini Program).

Does the service allow third-party access to private personal data? Yes

0/10

This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).

Note that whether the policy allows sharing aggregated user data does not affect this question.

If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).

If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).

Score

Yes

The policy allows sharing personal data with third parties (not just critical service providers), and does not explicitly list the third parties.

Yes, all parties specified (including non-critical service providers such as advertisers)

30%

Yes, not all parties specified (but only to critical service providers)

70%

Yes, all parties specified (only to critical service providers)

80%

100%

Citation

We do not share your information with any third parties, except where we need to in order to provide the service [...] or if we are instructed to by a court, authority or compelled by law. We use these third party services solely to process or store your information for the purposes described in this policy.

government, public, regulatory, judicial and law enforcement bodies or authorities [...]
related group companies: we share your Personal Information within our group of companies (and all related group companies may only use your personal information in accordance with this policy), including [...] for the purpose of: [...] assisting us in carrying out the purposes set out under the "How do we use Your Information" section above.
service providers: service providers supplying services to support, improve, or promote other products or features through our services, including the service providers listed here. [...]
in the event of an internal restructuring of our or our affiliates businesses, or the sale of WeChat or any of its assets to a third party, the entity that consequently operates WeChat may be a different entity to us and we will transfer your information accordingly so that your service can continue;
WeChat Official Accounts and Mini Program operators, [...]
a third party that acquires all or substantially all of us or our business. [...]

We collect personal information for the following purposes: [...]
To personalise WeChat, including by providing personalised advertisements;

Notes

The use of shared information is unclear:
For the purpose of sharing information with "related group companies", it only mentions the purpose is "carrying out the purposes set out under the "How do we use Your Information"", which is too general.

did not list all the third parties

In the "related group companies" section, they only listed some company "included" in this category, did not mention whether it was all the companies.

The sharing include non-essential sharing:

Even they mentioned "We do not share your information with any third parties, except where we need to in order to provide the service", there is no where mentioned whether advertisement is part of "the service":
In the "How do we use Your Information" section, there is no clear mention of advertisement, but in "Addendum for California Residents", it clearly mentions it collect personal information for advertisement purpose.

When does the policy allow law enforcement access to personal data? When reasonably requested

3/5

Score

Always

This includes cases in which law enforcement either runs the service or has a known backdoor into (or relationship with) the service.

Not specified

When reasonably requested

60%

Only when required by a court order or subpoena

80%

N/A (no personal data to share)

The service would have no personal data to share with law enforcement.

100%

Never (special legal jurisdiction)

The service operates in a jurisdiction in which sharing data with law enforcement is never required.

100%

Citation

Only where necessary will we share your information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:

government, public, regulatory, judicial and law enforcement bodies or authorities: there are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, such as a court order, subpoena or other legal process, to enforce our terms, address issues relating to security or fraud, or protect our users and provided the requesting entity has valid jurisdiction to obtain your personal information;

Notes

They will share data with law enforcement "only when necessary"

Transparency

Does the policy outline the service's general security practices? Somewhat

1/3

Score

Somewhat

The policy provides only a very vague overview of its security practices.

30%

Yes

60%

Yes, including audits

"Reviews," "monitoring," etc. also count as audits.

80%

Yes, including independent audits

Independent "reviews," "monitoring," etc. also count as independent audits.

100%

N/A

The service doesn't collect any personal information.

100%

Citation

SECURITY OF YOUR PERSONAL INFORMATION

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Is the policy's history made available? Only the date it was last modified

3/5

Does the policy require users to be notified in case of a data breach? Not necessarily

0/7

Will affected users be notified when the policy is meaningfully changed? Yes

5/5

Collection

Does the service collect personal data from third parties? Yes, but for critical data only

7/10

Is it clear why the service collects the personal data that it does? Somewhat

3/10

Does the service allow the user to control whether personal data is collected or used for non-critical purposes? No

0/10

Does the policy list the personal data it collects? Yes, generally

7/10

Score

The policy does not claim to not collect personal data, but it also doesn't provide any meaningful insight into the types of personal data it collects.

Only summarily

The policy uses overly vague language to provide a summary of the types of collected personal data.

30%

Yes, generally

All general categories of collected personal data are listed, though not all types of personal data are explicitly mentioned (for example, the list might use a phrase like 'such as' when listing types of personal data).

70%

Yes, exhaustively

All types of collected personal data are listed specifically

100%

N/A (no personal data is collected)

100%

Notes

In "WHAT INFORMATION DO YOU NEED TO PROVIDE WECHAT?" section, only mentions several categories, including:

"Location Data",
"Log Data",
"Non-Personal Information",
"Personal Information",
"Shared Information",

and examples of such data.

In the "HOW DO WE USE YOUR INFORMATION?" section, you will see a chart of most of the information collected, and the purpose of collection.

Last Updated

May 26, 2021

Sources

Source #1 ↗

Contributors

Anonymous