On November 1, 2021, the "Personal Information Protection Law of the People's Republic of China" officially came into effect. Since then, various government departments and agencies have successively issued regulations and requirements related to the necessary scope of personal information for common types of mobile internet applications, the special rectification campaign against infringements of user rights in mobile apps, and the enhancement of mobile internet application service capabilities, among others. These regulatory requirements aim to protect personal information rights and have achieved significant results. In order to assist developers and operators (referred to as "you") using the SolarEngine SDK in better protecting personal information on mobile terminals, and to avoid violations of relevant laws, regulations, policies, and standards due to involvement in third-party business practices, this compliance guide has been compiled for your reference.
Please note that the "compliance requirements," "precautions," "methods," and other contents in this compliance guide are drafted based on our understanding of relevant national laws, regulations, policies, and standards. They are provided as reference content and should not be construed as authoritative interpretations, legal opinions, or legal advice on any laws, regulations, policies, or standards. They also do not constitute any commitments or guarantees from the SolarEngine to external parties.
a. Collected Data:
• Unique device identification code (IMEI/Android ID/GAID/OAID)
• Event occurrence time/login account/IMEI2/UA/device language/device time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device model identification/network status/application version/application build number/package name/application name/channel name/browser/browser version/title of the current page/address of the current page/title of the previous page/address of the previous page/unique device ID/current time of the device/ Device boot time/Identification of whether ad tracking is turned on/ADServiceToken/Device screen density/Installed software package referrer URL/Referrer URL click client time/Client time when the application is installed/Referrer URL click server time/ The server time when the application is installed/the application version when it is installed for the first time/whether the application installation-free experience was released in the past 7 days, etc.
b. Purpose of Data Collection:
• To gather device information for generating a de-identified unique identifier for the end-user device, ensuring the provision of SDK services.
c. Timing of Data Collection:
• Collected when you call the SolarEngine SDK initialization method.
Permissions | Trigger Timing | Purpose |
---|---|---|
INTERNET | When event triggered | To allow the application to access the internet and send statistical data for providing analytics services. |
ACCESS_NETWORK_STATE | When event triggered | To detect the current network connection status. |
ACCESS_WIFI_STATE | When event triggered | To retrieve the Wi-Fi state. |
READ_PHONE_STATE (optional) | When IMEI collected | To retrieve the IMEI of the user's device. The IMEI is used for unique identification of users. |
The following methods are for reference only. Please consult your legal advisor or regulatory authorities for specific compliance solutions:
(1) Privacy Popup
a. When the app is first launched, it should prompt end users to read the privacy policy through a popup or other obvious means.
b. The privacy popup should include links to the user agreement and privacy policy.
c. The privacy popup should have a button for declining consent. End users should have the option to agree to or reject the privacy policy. It should not be pre-selected by default or obtained through deceptive or misleading means.
(2) Privacy Policy
a. The app should have a separate privacy policy that is documented independently, rather than being part of the user agreement or any other document.
b. The accessibility of the privacy policy should be ensured. Once end users enter the main functional interface of the app, they should be able to access the privacy policy with no more than four clicks or swipes.
c. The privacy policy should include a list of SDKs, including the SolarEngine SDK, providing information such as the name and contact details of each SDK provider, the purpose and method of processing personal information, the types of personal information processed, and the retention period. The privacy policy should also display the privacy policy link of the SDK provider.
d. A method should be provided for users to withdraw their consent, and the SolarEngine should be promptly notified when a user withdraws their consent.
Example: disclosing SolarEngine SDK information to users
Category | Description |
---|---|
SDK name | SolarEngine Android SDK v1.2.5.0 |
Developer name | Mobvista Cloud (Beijing) Technology Co., Ltd. |
Personal information collected (Please adjust the content according to your actual situation. The specific fields actually transmitted should prevail.) | IMEI/Android ID/GAID/OAID/Event occurrence time/login account/IMEI2/UA/device language/device time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device model identification/network status/application version/application build number/package name/application name/channel name/browser/browser version/title of the current page/address of the current page/title of the previous page/address of the previous page/unique device ID/current time of the device/ Device boot time/Identification of whether ad tracking is turned on/ADServiceToken/Device screen density/Installed software package referrer URL/Referrer URL click client time/Client time when the application is installed/Referrer URL click server time/ The server time when the application is installed/the application version when it is installed for the first time/whether the application installation-free experience was released in the past 7 days, etc. |
Collection purpose | To understand the performance of mobile applications on different terminal devices, usage platforms or application distribution channels; To optimize advertising strategies and detect anti-fraud activities; To provide "user tag" services & A/B testing services; To conduct device-level user group analysis, serving Internet advertising targeted delivery and user ROI analysis services. |
Privacy Policy Link | https://www.solar-engine.com/privacyPolicyEN.html |
You should ensure that the user has agreed to the Privacy Policy before calling the SolarEngine SDK for initialization. The initialization steps during the first cold start after installation are as follows:
(1) The pre-initialization method does not collect device information or report data to the SolarEngine background;
(2) Ensure that the formal initialization method is called only after the user has agreed to the Privacy Policy during the app's first cold start. At this point, the SDK will start collecting device information and reporting data. Conversely, if the user does not agree to the Privacy Policy, the formal initialization method should not be called.
For detailed initialization configuration instructions, please refer to Initialize the SDK on this page.