TikTok Consumer Health Data Policy

Sharing & Disclosure · Context

Information shared in public activities can be read and used by others, and laws may not protect it

If you take part in public activities on the Services, TikTok says the information you share may be read, collected or used by other users and the public. It warns that laws may not protect consumer health data you choose to make public and tells you to use caution in disclosing personal information.

Supporting quotations

If you choose to engage in public activities on the Services, you should be aware that any information you share may be read, collected, or used by other users and the public.

Laws may not protect consumer health data you choose to make public, and you should use caution in disclosing personal information while using the Services.

Qualifications & exceptions

• Applies to information you share through public activities you choose to engage in.

Not stated here

• The policy does not list which activities on the Services are public.

Sharing & Disclosure · Permission or license

May share personal information, including consumer health data, as reasonably necessary to provide the Services

TikTok says that, subject to applicable laws, it may share personal information, which may include each of the categories of consumer health data described earlier in the policy, as reasonably necessary to provide you the Services, in the ways listed. The wording of the lead-in is tied to providing the Services, but several listed items (a sale, merger or other business transfer; legal reasons; as otherwise permitted by law) are not phrased in terms of providing the Services. The policy does not reconcile the two, so how far the lead-in limits those items is not stated.

Supporting quotations

Subject to applicable laws, we may share personal information, which may include each of the categories of consumer health data as described above, as reasonably necessary to provide you the Services in the following manner:

Information about your physical and mental health conditions that you or others choose to provide in the content that you create or upload through the Services.

We may collect biometric identifiers and biometric information as defined under US laws, such as faceprints and voiceprints from your user content.

Qualifications & exceptions

• Subject to applicable laws.
• Lead-in limit: "as reasonably necessary to provide you the Services".

Not stated here

• "Reasonably necessary" is not defined.
• The six listed ways do not name advertising or analytics partners or say whether any sharing is a sale; the Privacy Policy section the list points to is not supplied here.
• Whether the lead-in's "reasonably necessary to provide you the Services" limit applies to the business-transfer, legal-reasons and as-otherwise-permitted-by-law items is not stated.

Cross-references

• contrast (model-proposed): Shares as otherwise permitted by law — The lead-in limits sharing to what is reasonably necessary to provide the Services, while the last listed item allows sharing as otherwise permitted by law without that purpose. The policy does not say which governs; both are quoted and the tension is left open.

Sharing & Disclosure · Company practice

Shares with service providers and business partners for business operations

TikTok may share this information with service providers and business partners to help it perform business operations and for business purposes. As an example, they may receive certain information to help TikTok provide services, like content moderation.

Supporting quotations

With service providers and business partners to help us perform business operations and for business purposes.

For instance, service providers and business partners may receive certain information to help us provide services, like content moderation.

Qualifications & exceptions

• Within the lead-in's limit: subject to applicable laws and as reasonably necessary to provide the Services.

Not stated here

• "Business partners" and "business purposes" are not defined here; the example (content moderation) is not stated to be the only use.

Sharing & Disclosure · Company practice

Shares with TikTok's affiliates as necessary for this policy's purposes

TikTok may share with affiliates it controls or that are under common control with it, as necessary for the purposes set out in this Consumer Health Data Privacy Policy.

Supporting quotations

With our affiliates controlled by, or under common control with, us as necessary for the purposes set forth within this Consumer Health Data Privacy Policy.

Qualifications & exceptions

• Limited to affiliates controlled by, or under common control with, "us", and to what is "necessary for the purposes set forth" in this policy.

Not stated here

• The policy does not name the affiliates or say where they are located.

Sharing & Disclosure · Company practice

Shares in connection with a sale, merger or other business transfer

TikTok may share information in connection with a sale, merger or other business transfer. The item says nothing further about what is shared, who receives it or what limits apply to the recipient.

Supporting quotations

In connection with a sale, merger, or other business transfer.

Not stated here

• The policy does not say who receives the information, whether it must be used consistently with this policy, or whether users are told.

Sharing & Disclosure · Company practice

Shares for legal reasons

TikTok may share information "for legal reasons". The item is a single phrase: it does not say which legal reasons, which authorities or parties, or what TikTok requires before sharing.

Supporting quotations

For legal reasons.

Not stated here

• The policy does not define "legal reasons" or say whether a legal process is required.

Sharing & Disclosure · Company practice

Shares with your consent or at your direction, such as when you allow a third-party service to access your account

TikTok may share information with your consent or at your direction. The example given is that if you choose to allow a third-party service to access your account, TikTok may share certain information about you with that third party depending on your permissions.

Supporting quotations

With your consent or at your direction.

For example, if you choose to allow a third-party service to access your account, we may share certain information about you with the third party depending on your permissions.

Qualifications & exceptions

• The third-party example applies when you choose to allow the service access and depends on the permissions you give.

Not stated here

• The policy does not say how consent is requested or whether it can be withdrawn; the account-access example is not stated to be the only form.

Sharing & Disclosure · Company practice

Shares purchase information with the seller and its payment and fulfillment providers

When you make a purchase from a third party on the Services, including from a merchant selling through TikTok's shopping features, TikTok may share the information related to the transaction with that third party and its payment processors and transaction fulfillment providers. This is introduced as an addition to the consent item ("In addition").

Supporting quotations

In addition, when you make a purchase from a third party on the Services, including from a merchant selling products through our shopping features, we may share the information related to the transaction with that third party and their payment processors and transaction fulfillment providers.

Qualifications & exceptions

• Applies to purchases from a third party on the Services, including from merchants selling through shopping features.

Not stated here

• The policy does not say which transaction details are shared or whether those details can include health-related information.

Sharing & Disclosure · Permission or license

Shares as otherwise permitted by law

The last item lets TikTok share "as otherwise permitted by law". It is a catch-all that is not tied to any purpose named in the policy, so any sharing the law allows falls within the list's wording, subject to the lead-in's "subject to applicable laws" and "reasonably necessary to provide you the Services" wording.

Supporting quotations

As otherwise permitted by law.

Qualifications & exceptions

• Tied only to what law permits.

Not stated here

• The policy does not say what recipients or purposes this covers, or how it interacts with the lead-in's "reasonably necessary to provide you the Services" limit.

Cross-references

• contrast (model-proposed): May share personal information, including consumer health data, as reasonably necessary to provide the Services — The lead-in limits sharing to what is reasonably necessary to provide the Services, while the last listed item allows sharing as otherwise permitted by law without that purpose. The policy does not say which governs; both are quoted and the tension is left open.

Sharing & Disclosure · Context

Points to the Privacy Policy for more on sharing

For more detail on sharing, the policy refers readers to the "How We Share Your Information" section of the TikTok Privacy Policy. That section is not part of this document.

Supporting quotations

For additional details about how we share information, please review “How We Share Your Information” in the

Not stated here

• The content of "How We Share Your Information" was not supplied, so this analysis does not state what it says.