A Comparative Study on the Legal Framework for User Data Protection on Digital Platforms: The Case of China and Uzbekistan

Аннотация

With the deep integration of the digital economy and digital platforms, user data protection has become a focal point of legislative attention worldwide. As a global leader in the digital economy, China enacted the Personal Information Protection Law in 2021[1], establishing a comprehensive legal system for personal information protection. Uzbekistan, a pioneer in digital transformation in Central Asia, adopted the Law on Personal Data in 2019[5], and has undergone intensive amendments in 2025-2026[8][9], with its legal framework evolving rapidly. This paper adopts a functional comparative method to analyse the legal frameworks of China and Uzbekistan from four dimensions: the definition of sensitive personal information, data localization and cross-border transfer rules, data subject rights, and enforcement mechanisms. The study shows that both countries have established relatively complete personal data protection systems drawing on the GDPR, but due to differences in economic development stages, industrial policy objectives and the level of digital economy development, their institutional designs manifest a divergence between a “strict regulatory model” and a “balanced development model”. Uzbekistan‟s recent shift from absolute localization to flexible regulation[9] provides a useful reference for latecomer countries seeking to strike a balance between data protection and digital economic development.