Overview
TikTok describes its app's purpose as 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 say they do not sell a user's personal information to third parties, but they 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 that 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. The terms do not discuss encryption of data or data breach notification.
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.
Overall Score
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
| Basic Score | Full Score | |
|---|---|---|
| Comprehensive Assessment | 60 | 50 |
Concerns
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
| Concern | Basic Score | Full Score |
|---|---|---|
| Data Collection: Protecting personal information | 83 | 55 |
| Data Sharing: Protecting data from third parties | 50 | 75 |
| Data Security: Protecting against unauthorized access | 0 | 35 |
| Data Rights: Controlling rights to data | 88 | 45 |
| Data Sold: Preventing sale of data | 75 | 25 |
| Data Safety: Promoting responsible use | 67 | 70 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 50 | 60 |
| Parental Consent: Protecting children’s personal information | 50 | 45 |
| School Purpose: Following student data privacy laws | 0 | 0 |
| Individual Control: Controlling data use | NA | 50 |
Statutes
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
| Statute | Basic Score | Full Score |
|---|---|---|
| California Online Privacy Protection Act (CalOPPA) | 81 | 62 |
| Children's Online Privacy Protection Act (COPPA) | 64 | 54 |
| Family Educational Rights and Privacy Act (FERPA) | 43 | 34 |
| Student Online Personal Information Protection Act (SOPIPA) | 55 | 45 |
| General Data Protection Regulation (GDPR) | 60 | 49 |
| The California Consumer Privacy Act (CCPA) | 58 | 51 |
Privacy Policy Details
1: Transparency
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a change log or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Unclear whether users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Privacy Contact
- Users can contact the company about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
- Privacy policies do indicate privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Intended for teens.
- Intended for adults over 18.
- Unclear whether intended for parents or guardians.
- Unclear whether intended for students.
- Unclear whether intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Geolocation data are collected.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically collected.
2.2: Data Source
- Unclear whether personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is collected.
2.3: Data Excluded
- Unclear whether specific types of personal information excluded from collection.
- Specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
- Collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Personal information is shared for third-party marketing.
3.3: Data Not Shared With Third Parties
- Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
- Personal information is not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information about users is obtained from third parties.
3.6: Third-Party Links
- Links to third-party external websites are not age-appropriate.
3.7: Third-Party Data Access
- Third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
- Unclear whether personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party.
3.10: Third-Party Service Providers
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive data are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
- Company may combine data with additional data from third-party sources.
- Unclear whether data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
- Third-party login is supported.
- Personal information from third-party login providers is collected.
- Personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- Unclear whether user information that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
3.16: Third-Party Contractual Obligations
- Unclear whether contractual limits are placed on third-party data use.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
4: Respect for Context
4.1: Data Use
- Unclear whether use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
4.2: Data Combination
- Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Unclear whether notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Unclear whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users can create or upload content.
5.2: User Consent
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- A grievance or remedy mechanism is not available for users to file a complaint.
5.4: Data Settings
- Users can control the use of their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- Users can request to know what personal information has been shared with third parties.
- Notice is provided in the event the company receives a government or legal request for a user's information.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Any copyright license to a user's data is not limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- Unclear whether methods are available to restrict who has access to data.
- Unclear whether the school, parents, or students can review student data.
6.2: Data Integrity
- Unclear whether the company attempts to maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify data are available for authorized users.
- Unclear whether the school, parents, or students can modify inaccurate student information.
- Unclear whether the time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
- Unclear whether the product provides a data-retention policy.
- Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for authorized users to delete data are available.
- The time period for the company to delete data is indicated.
6.6: Data Portability
- Unclear whether this product provides users the ability to download their data.
- A user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
8: Security
8.1: User Identity
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Unclear whether managed accounts are available.
- Unclear whether multi-factor account protection is available.
8.3: Third-Party Security
- Third-parties with access to information are required to provide the same security protections as the company.
8.4: Data Confidentiality
- Reasonable security practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
8.5: Data Transmission
- Unclear whether this product encrypts all data in transit.
8.6: Data Storage
- Unclear whether all data are stored in an encrypted format.
- The company is clear what jurisdiction a user's personal information is subject to.
8.7: Data Breach
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Unclear whether this product performs data-privacy and/or security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
9.2: Data Visibility
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
9.3: Monitor and Review
- User-created content is reviewed, screened, or monitored by the company.
- 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.
9.4: Report Content
- Unclear whether users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- The company provides links to resources that support safe and appropriate social interactions.
10: Advertising
10.1: Company Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Personalised advertising is displayed.
10.4: Ad Tracking
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
10.5: Filtered Advertising
- Unclear whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Company does not respond to "Do Not Track" or other opt-out mechanisms.
- The company does provide a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Account creation is restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
11.3: Parental Consent
- Unclear whether parental consent is required before personal information is collected or disclosed.
- 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.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- A user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- A user is required to waive the right to join a class action lawsuit.
- A company will disclose personal information to law enforcement.
11.5: Certification
- Unclear whether the company has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- Unclear whether a user's data are subject to International data transfer or jurisdiction laws.
- Unclear whether the company has indicated it is a Data Controller or Data Processor.