TikTok states it receives information about your activity on other websites and apps from advertisers and measurement partners, and uses this combined data to deliver targeted ads both on TikTok and on other websites through its ad network.
This analysis describes what TikTok Ads's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision authorizes TikTok to receive off-platform behavioral data from third-party advertisers and partners, including browsing activity, purchase history, and app downloads, and to combine this with on-platform data for ad targeting through the TikTok Ad Network.
Interpretive note: The policy's qualified statement that TikTok does not share for cross-context behavioral advertising 'where restricted by applicable law' does not clearly specify which states or user populations are covered by this restriction, creating ambiguity about the actual opt-out scope.
The updated policy states that TikTok Pte. Ltd., a Singapore-registered entity, now provides and controls the Platform, replacing the previous U.S.-based operator. The policy removes its prior explic…
Your activity on websites and apps outside TikTok may be tracked and shared with TikTok by advertisers and measurement partners, and used to target you with ads on TikTok and across the broader TikTok Ad Network; your ads settings may affect the scope of this use according to the policy.
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"Advertisers, publishers, and measurement and other partners provide us with information about you and the actions you have taken outside of our websites and apps, including the pages you visit, products or services you purchase, and apps you download. These partners also provide information such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help measure the effectiveness of ads we serve and to better deliver ads to you on our websites and apps, or through TikTok Ad Network elsewhere online, depending on your ads settings.— Excerpt from TikTok Ads's TikTok Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages CCPA/CPRA's restrictions on sharing personal information for cross-context behavioral advertising, which requires an opt-out mechanism. The policy states TikTok does not share for cross-context behavioral advertising 'where restricted by applicable law,' a conditional formulation that may require evaluation under CPRA's opt-out requirements. The FTC Act applies to data broker-style practices involving off-platform behavioral data. State comprehensive privacy laws in Virginia, Colorado, Connecticut, Texas, and others include targeted advertising opt-out rights. 2. GOVERNANCE EXPOSURE: High. The combination of on-platform data with off-platform behavioral data received from advertisers and measurement partners, used for ad targeting across TikTok and the TikTok Ad Network, constitutes the core of TikTok's advertising business model as described in the policy. The policy's qualified statement about cross-context behavioral advertising restrictions creates compliance ambiguity: organizations reviewing this policy should assess whether TikTok's ads settings constitute a compliant opt-out mechanism under applicable state laws. 3. JURISDICTION FLAGS: California residents have a CPRA right to opt out of sharing for cross-context behavioral advertising. Virginia, Colorado, Connecticut, Texas, and Oregon residents have similar rights under their respective comprehensive privacy statutes. The involvement of the TikTok Ad Network for off-platform ad delivery may extend data processing beyond the primary platform relationship, which may require additional disclosure and opt-out mechanisms in some jurisdictions. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertisers using TikTok Pixel or TikTok Advertiser Tools integrate TikTok's tracking directly into their own properties, creating a data flow that involves both the advertiser and TikTok as data processors or controllers. B2B contracts between advertisers and TikTok should address compliance with applicable state advertising opt-out requirements and data processing obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that TikTok's ads settings provide a functional and accessible opt-out from cross-context behavioral advertising that meets CPRA and comparable state law requirements. Data flows involving the TikTok Ad Network and third-party measurement partners should be mapped and documented. Advertisers and publishers using TikTok Advertiser Tools should review whether their own privacy policies and consent mechanisms address the data flows described in this provision.
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This provision authorizes TikTok to receive off-platform behavioral data from third-party advertisers and partners, including browsing activity, purchase history, and app downloads, and to combine this with on-platform data for ad targeting through the TikTok Ad Network.
Your activity on websites and apps outside TikTok may be tracked and shared with TikTok by advertisers and measurement partners, and used to target you with ads on TikTok and across the broader TikTok Ad Network; your ads settings may affect the scope of this use according to the policy.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by TikTok Ads.