TikTok rewrites all US terms following the transfer of its USA operations

TikTok ▪ Commercial Terms, Data Processor Agreement, Developer Terms, In-App Purchases Policy, Law Enforcement Guidelines, Privacy Policy, Terms of Service ▪ January 23, 2026

By Tam Kien Duong and Saumyaa Naidu, Open Terms Archive team members

On January 23, 2026, TikTok revised multiple policy documents in several jurisdictions. The updates established a new legal entity, “TikTok USDS Joint Venture LLC”, as the new “operator of the Platform in the United States”. Most importantly, the terms that applied globally with a few paragraphs defining local specificities, now have a dedicated US version that applies only to that country.

The updated privacy policy for this US entity (also applicable to TikTok Ad Network) replaced all references to the “Platform” with “Service”. It now includes data collection from AI interactions. The tracking of precise location information has been part of the policy in Europe, the United Kingdom and Switzerland since October 2025.

The data collection has been expanded to include as sources:

  • the duration and frequency of use;
  • engagement with other users;
  • interactions with websites while using the in-app browser;
  • information from sellers and payment providers;
  • information on the delivery of products purchased through TikTok’s shopping features.

TikTok has added shopping features and age verification as purposes for data collection, and widened information sharing with several new service providers, business partners and their affiliates to “facilitate a global and interoperable experience”. The policy states that the US entity will share certain data with international TikTok operations for interoperability “in compliance with applicable laws”.

Documents from other jurisdictions (Ireland, the United Kingdom, Australia and Canada) have been less affected. They mainly reflect changes in the service’s contact points in the US and update links to point to new “global” versions of the terms that now differ from the US version. The Developer Terms, however, contain a new section named “TikTok Developer US Data Sharing Agreement”.

This establishment of a US-based entity for TikTok has come into place to address national security concerns and avoid a potential ban. TikTok is the object of scrutiny regarding digital rights, election integrity, misleading political information and direct influence over young audiences. But beyond these points, the United States of America have treated TikTok’s case as a matter of national security, in a long-standing conflict with China that culminated with Oracle buying TikTok’s US operations, leading to these changes.