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Privacy Evaluation for TikTok - Real Short Videos

Last updated March 20, 2019

Overview

TikTok is an app for sharing short-form mobile videos that allows users to capture and present the world's creativity, knowledge, and precious life moments, directly from their mobile phone. The terms of TikTok state that users may interact with trusted and other untrusted users on the service. TikTok's terms state they collect personal information, technical information, and behavioral information about a user's use of the service. TikTok's terms state they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. Lastly, TikTok provides a separate privacy policy for younger users that covers the experience they provide for users under the age of 13.

TikTok can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and the Amazon App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on TikTok’s website, iOS App Store, the Google Play Store, and the Amazon App Store. Additionally, other policies used for this evaluation include: Copyright Policy, and Privacy Policy for Younger Users. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of TikTok state that users may interact with trusted and other untrusted users on the service. The terms recommend that if users choose to engage in public activities on the service, they should be aware that any information they share may be read, collected, or used by other users. However, younger users under the age of 13 have a more limited interactive experience. For example, they can’t exchange messages with other users. Younger Users also cannot publicly share personal information, including videos or profile information. While younger users may save videos directly to their device, the videos will not be saved by TikTok or viewable by other users. Lastly, the terms state that users control whether their user content is made publicly available on the services to all other users of the services, or only available to people a user approves.

Privacy

TikTok's terms state they collect personal information, technical information, and behavioral information about a user's use of the service. The terms also state TikTok collects information contained in the messages users send through the service and information from a user's phone book, if they grant TikTok access to the phone book on a user's mobile device. If a user chooses to find other users through their phone contacts, TikTok will access and collect the names and phone numbers and match that information against existing users of the service. In addition, if users choose to find other users through their social network contacts, TikTok will collect their public profile information as well as names and profiles of their social contacts.

TikTok's terms do not disclose whether they may sell a user's personal information to third parties, but do disclose that they may send users promotional marketing materials from TikTok or on behalf of other third-party affiliates and trusted third parties. The terms state that TikTok and their third-party partners may use cookies and tracking technologies for the purpose of displaying advertisements on other websites or online services on their behalf. The terms state TikTok works with third-party online advertising networks which use technology to recognize a user's browser or device and to collect information about their visit to TikTok in order to provide customized content, advertising, and commercial messages.

Additionally, the terms state TikTok allows their business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about a user's online activities. TikTok's terms state they link a user's contact or subscriber information with a user's activity on their service across all a user's devices, using their email or other log-in or device information. Third parties may use a user's information to display advertisements on TikTok and elsewhere online tailored to a user's interests, preferences, and characteristics. However, users should be aware their mobile device may include a feature that allows them to opt-out of some types of targeted advertising such as "Limit Ad Tracking" on iOS, and "Opt out of Interest-Based Ads" on Android.

Security

TikTok's terms state they will maintain a comprehensive data security program and have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information they collect and to protect against unauthorized access, disclosure, and use. However, the terms do not disclose whether personal information is protected with encryption while in transit or while at rest. Lastly, the terms do not state whether notification is provided to users if personal information under TikTok's control is compromised as a result of a data breach of security.

Compliance

TikTok's terms state they are committed to protecting and respecting their users' privacy. In addition, TikTok provides a separate privacy policy for younger users that covers the experience they provide for users under the age of 13. When a younger user under the age of 13 registers for TikTok, they collect only limited information, including username, password, and birthday. However, the terms do not disclose whether they require parental consent to be obtained prior to the collection or disclosure of personal information from users under the age of 13, or what methods a parent or guardian may use to provide consent.

The terms state that the service is not directed at children under the age of 13. If TikTok becomes aware that personal information has been collected on the service from a user under the age of 13, the terms state they will delete that information and terminate the user's account. Lastly, the terms ask that if a user believes TikTok has collected information from a child under the age of 13 on the service, to please contact them so they may delete it immediately.

Data Collection
SCORE: 45%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 65%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether use of information is limited to the purpose for which it was collected.
  • Data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • The roles of third-party service providers are indicated.
  • Social or federated login is supported.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 35%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 55%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Users can control their information through privacy settings.
  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether the school, parents, or students can delete data.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 15%

Is the data sold?

  • Unclear whether data are sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • User information can be transferred to a third party.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 70%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 40%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether this product requires parental consent.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.