- 07OperatorWho serves the app?
TikTok Technology Limited · Ireland
Dublin, CRO 635755. It is the other party to the user contract in the EEA, and joint controller of users' data with TikTok Information Technologies UK Limited. Designated a very large online platform on 25 April 2023; 189 million people a month in the EU, per TikTok's seventh DSA transparency report.
- TikTok terms of service, EEA version (July 2026)
your contract is with TikTok Technology Limited
read 25 Sep 2026 - TikTok privacy policy, EEA version (30 Nov 2025)read 25 Sep 2026
- European Commission, designated VLOPs and VLOSEsread 25 Sep 2026
- TikTok, seventh DSA transparency reportread 25 Sep 2026
- TikTok terms of service, EEA version (July 2026)
- 07OwnerWho owns the operator, where someone else does?
ByteDance Ltd. · Cayman Islands
also ByteDance group companies in China · China: where many of the group's companies and staff are, per the Irish High Court
Held through TikTok Information Technologies UK Limited and TikTok Ltd. in the Cayman Islands, each wholly owned. ByteDance is registered in the Cayman Islands, so the layer is coded there, with China beside it. For the GDPR fine the DPC treated ByteDance and TikTok as one undertaking, under ByteDance's decisive influence. A US executive order calls ByteDance TikTok's China-based parent. The joint venture set up in January 2026 runs TikTok in the United States only; the EEA terms still name the Irish company.
- High Court of Ireland, TikTok v DPC, [2026] IEHC 347, para. 55
many of the ByteDance group of companies and its employees are based in China
read 25 Sep 2026 - High Court of Ireland, TikTok v DPC, [2026] IEHC 419, paras. 29 and 126read 25 Sep 2026
- White House, executive order 14352, Saving TikTok while protecting national security (Sep 2025)
China-based parent company, ByteDance Ltd
read 25 Sep 2026 - TikTok, announcement from the new TikTok USDS Joint Venture LLCread 25 Sep 2026
- High Court of Ireland, TikTok v DPC, [2026] IEHC 347, para. 55
- 07ProtocolWho writes the rules of the network?
ByteDance Ltd. · Cayman Islands
protocol: proprietary
No open or federated protocol. The EEA terms bar collecting content with any automated tool TikTok has not approved in writing.
- TikTok terms of service, EEA version (July 2026)read 25 Sep 2026
- 07CodeWho builds the software?
TikTok Pte. Ltd. · Singapore
also ByteDance group staff in China · China: software engineering, maintenance and development, with access to EEA users' data, per the Irish High Court
licence: proprietary
The Singapore company is the trader for the app in the EU app stores. No source says the app or its algorithm is built in the EU. The web app's servers name ByteDance's own platforms in their response headers.
- App Store, TikTok (trader TikTok Pte. Ltd., Singapore)read 25 Sep 2026
- High Court of Ireland, TikTok v DPC, [2026] IEHC 347, para. 57
functions related to software engineering, maintenance and development
read 25 Sep 2026
- 07VerificationWho checks users' identity, age or account?
Yoti · United Kingdom
checks: age
ID needed to post: no
A neutral date-of-birth gate at sign-up. Since January 2026 TikTok's own model flags accounts in Europe that may belong to under-13s, for a moderator to review. On appeal, age can be confirmed through Yoti's facial age estimation, a credit card or a government ID; TikTok does not name the ID vendor.
- TikTok, updates to how we enforce age-appropriate experiences in Europe (16 Jan 2026)
Facial age estimation provided by Yoti.
read 25 Sep 2026
- TikTok, updates to how we enforce age-appropriate experiences in Europe (16 Jan 2026)
- 06ModelsWhose models moderate, rank or check?
ByteDance group teams in China · China
The For You feed is TikTok's own recommender, and automated systems removed 94.1% of violating content without human review. No outside model vendor is named. TikTok told the Irish High Court that EEA users' data is used in China for algorithm updates, among other work, which is why this layer is coded China; TikTok does not say where its models are built.
- High Court of Ireland, TikTok v DPC, [2026] IEHC 347, para. 24
product and feature updates, algorithm updates, bug identification and issues resolution
read 25 Sep 2026 - TikTok, seventh DSA transparency reportread 25 Sep 2026
- European Commission, preliminary findings on TikTok's addictive design (6 Feb 2026)read 25 Sep 2026
- High Court of Ireland, TikTok v DPC, [2026] IEHC 347, para. 24
- 05DataWhere does the data sit?
TikTok Technology Limited · United States
also the European enclave's data centre in Dublin · Ireland: storage for European users, live since September 2023
also the European enclave's data centre in Hamar · Norway: storage for European users, fully live since April 2025
also ByteDance group companies in China · China: remote access to EEA users' data, for product, algorithm and outage work
where: By default a European enclave hosted in Norway, Ireland and the US, per TikTok's Project Clover pages. The EEA privacy policy names servers in the US, Malaysia and Singapore and does not mention the EEA. Two more data centres are being built in Finland.
transfers: Remote access from China continues. In 2025 the Irish DPC fined TikTok €530 million over those transfers and ordered them suspended; the order was stayed, and in June 2026 the High Court upheld the infringement and sent the orders back to the DPC. In February 2025 TikTok also found that limited EEA data had been stored on servers in China, which the DPC is investigating.
- TikTok, Project Clover update, Norwegian data centre fully online (3 Apr 2025)
hosted across data centres in Norway, Ireland, and the US
read 25 Sep 2026 - TikTok privacy policy, EEA version (30 Nov 2025)
servers located in the United States, Malaysia and Singapore
read 25 Sep 2026 - TikTok, update on the Irish GDPR decision
entities in our corporate group located in China remote access to some personal data
read 25 Sep 2026 - Irish DPC, €530 million fine for transfers of EEA users' data to China (2 May 2025)read 25 Sep 2026
- Irish DPC, inquiry into EEA users' data stored on servers in China (10 Jul 2025)read 25 Sep 2026
- TikTok, progress on Project Clover, first Dublin data centre operational (Sep 2023)read 25 Sep 2026
- TikTok, Project Clover update, Norwegian data centre fully online (3 Apr 2025)
- 04ServersWho runs the servers?
Green Mountain AS · Norway
also a co-location provider TikTok does not name · country not established: the Dublin data centre; press names one, and the reports conflict
also a host TikTok does not name · United States: the US leg of the European enclave
region: Hamar NO and Dublin IE, both live; Kouvola FI being built and Lahti FI announced; a US site not named
TikTok rents space in data centres others run; the Hamar site was developed by Green Mountain. The origin could not be measured, because every host tried answered from a CDN or from ByteDance's own network.
- TikTok, Project Clover update, Norwegian data centre fully online (3 Apr 2025)
The data centre in Hamar, Norway, developed by Green Mountain
read 25 Sep 2026 - TikTok, Project Clover, two more European data centres (Mar 2023)
co-location sites operated by third party service providers
read 25 Sep 2026 - TikTok, data centre in Finlandread 25 Sep 2026
- TikTok, Project Clover update, Norwegian data centre fully online (3 Apr 2025)
- 04EdgeWho stands in front of them?
Akamai · United States
also Fastly · United States: some images
also ByteDance's own network · United States: video, through a ByteDance node in Rome; the network is registered to Bytedance Inc. in the US
also Fastweb SpA · Italy: houses Akamai's cache servers inside its network; Akamai runs them and the content
Measured from Italy. The web app, its APIs, the EU login and most images come through Akamai, some of them from Akamai servers inside Fastweb's network. Video comes from ByteDance's own network.
- measured · www.tiktok.com · AS20940 Akamai · 25 Sep 2026
- measured · login-eu.www.tiktok.com · AS20940 Akamai · 25 Sep 2026 · the EU login
- measured · p16-common-sign.tiktokcdn-eu.com · AS30722 Fastweb (Vodafone Italia) · 25 Sep 2026 · images, from an Akamai server inside the ISP
- measured · p19-common-sign.tiktokcdn-eu.com · AS54113 Fastly · 25 Sep 2026 · images
- measured · v45.tiktokcdn-eu.com · AS396986 ByteDance (Bytedance Inc., US) · 25 Sep 2026 · video, via a ByteDance node in Rome
where a claim in circulation is wrong
Under Project Clover, European users' TikTok data stays in Europe.
TikTok's own Clover pages say the European enclave is hosted in Norway, Ireland and the US. The EEA privacy policy names servers in the US, Malaysia and Singapore, and staff in China keep remote access to some EEA users' data.
TikTok, Project Clover update (3 Apr 2025)TikTok privacy policy, EEA versionTikTok, update on the Irish GDPR decision
Checked 25 Sep 2026.