TikTok states it collects approximate location from your device and network data automatically, and can collect precise GPS-level location if you enable location services for the app in your device settings.
This analysis describes what TikTok'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
Approximate location is collected by default from IP address and device settings, while precise location collection requires enabling location services; the policy states location services can be disabled in device settings at any time, giving users a direct control mechanism.
The policy states approximate location data is collected automatically as part of device and network information, and precise location data is collected if location services are enabled for TikTok in device settings; users can disable location services for TikTok through their device settings to prevent precise location collection.
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"Location information about your approximate location based on your device and network information, such as SIM card region, IP address, and device system settings. We also collect information, such as tourist attractions, shops, or other points of interest, if you choose to add the location to your user content. Also, if you choose to enable location services for the TikTok app within your device settings, we collect approximate or precise location information from your device. You can turn off location services from your device settings at any time.— Excerpt from TikTok's TikTok Privacy Policy
1) REGULATORY LANDSCAPE: Precise location data is treated as sensitive personal information under CCPA and CPRA, as well as under other state comprehensive privacy laws. Washington's My Health My Data Act may engage where location data could reveal health-related visits. The FTC has taken enforcement action regarding deceptive location data practices and has issued guidance on precise location data use. COPPA's restrictions on collection of geolocation information from minors apply where the user population includes users under 13. 2) GOVERNANCE EXPOSURE: Medium. The policy discloses both approximate and precise location collection with a clear user control mechanism (device settings), which reduces disclosure-related exposure. However, the automatic approximate location collection from IP address and device data occurs without a separate opt-in, which may require evaluation under state privacy laws that treat location data as sensitive. 3) JURISDICTION FLAGS: California CPRA categorizes precise geolocation as sensitive personal information subject to heightened rights. Other state comprehensive privacy laws provide similar treatment. Illinois and other states may have specific provisions regarding location data in certain contexts. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertising partners receiving location-derived audience data from TikTok should assess whether that data constitutes precise geolocation under applicable state definitions and whether their use of it triggers additional compliance obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the automatic approximate location collection from IP address and device settings constitutes collection of sensitive information requiring a right-to-limit mechanism under CPRA, and whether the disclosure adequately distinguishes automatic approximate collection from opt-in precise collection.
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Approximate location is collected by default from IP address and device settings, while precise location collection requires enabling location services; the policy states location services can be disabled in device settings at any time, giving users a direct control mechanism.
The policy states approximate location data is collected automatically as part of device and network information, and precise location data is collected if location services are enabled for TikTok in device settings; users can disable location services for TikTok through their device settings to prevent precise location collection.
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