Privacy Notice for Our TikTok Profile

1.What this notice covers

This page explains what happens to your data specifically when you visit or interact with Crossroutes' own profile on TikTok. It does not describe how TikTok itself runs the platform as a whole — that's between you and TikTok, governed entirely by TikTok's own Privacy Policy(external link, opens in a new tab). We link to this page from our profile's bio because German law (Impressumspflicht) requires it to be reachable in a couple of clicks from any commercial social presence — see Section 8.

2.Who's responsible for what

Crossroutes is run by Lennard Zirks (business name: Software-Entwicklung Lennard Zirks), Hirtenweg 63A, 26180 Rastede, Germany — [email protected]. Full details: Legal Notice. Crossroutes is small enough that none of the Art. 37 GDPR thresholds requiring a Data Protection Officer apply, so requests go directly to the address above.

Unlike Meta's Facebook Pages, TikTok has not published a comparable joint-controller framework for creator/business account analytics, and we're not aware of case law establishing one the way there is for Facebook Page Insights. We treat ourselves as an ordinary account holder here, not a joint controller with TikTok for anything — TikTok is the sole controller for the platform itself, including whatever aggregate analytics it shows account holders about their own content and whatever cookies it sets.

3.What we actually see and do

• Analytics: whatever aggregate, anonymized numbers TikTok's own account tools show us (views, follower counts, basic audience breakdowns) — we don't export or separately store these.
• Comments and public replies: visible to us the same way they're visible to anyone viewing the video, exactly as the platform itself shows them.
• Direct messages sent to our profile: read by us personally — the only recipient — and treated like any other inbound contact, used only to answer whatever you asked. We never add it to a marketing list, combine it with anything else we hold, or share it onward, except where legally required or with your consent. TikTok does not publish a guarantee that direct messages are end-to-end encrypted. Do not send sensitive personal data via direct message; use email instead: [email protected].

We don't run ads on this profile and don't use any TikTok pixel or tracking SDK anywhere.

4.Legal basis and retention

Maintaining a public brand presence on TikTok and responding to messages sent to it both rest on legitimate interest (Art. 6(1)(f) GDPR) — reaching and supporting the people who use or might use Crossroutes. A direct message or comment is kept only as long as it's relevant to answering it, then deleted along with the rest of our message history on the platform.

5.Cookies

TikTok sets its own cookies on its platform — that's entirely TikTok's responsibility as sole controller, not ours, and not something this notice can change. See TikTok's own Privacy Policy, linked in Section 1, for the details.

6.International data transfers

TikTok's corporate structure and international data flows (including its relationship to its China-based parent company, ByteDance) are the subject of ongoing regulatory scrutiny in the EU and elsewhere — this is TikTok's own responsibility to disclose and manage as the platform's controller, described in its Privacy Policy, not something we can meaningfully add detail to here. We ourselves only ever see the aggregate analytics or message content described in Section 3 — nothing we hold separately leaves the EU on our end.

7.Your rights

For anything TikTok processes as sole controller (the platform itself, its analytics, its ad system) — exercise your rights directly with TikTok via the contact details in its own Privacy Policy. For anything we hold ourselves (a message you sent us) or questions about this notice, write to [email protected]; we respond within 30 days. You can also complain to our supervisory authority, the Landesbeauftragte für den Datenschutz Niedersachsen(external link, opens in a new tab).

8.Legal Notice (Impressum)

German law requires an easily reachable Impressum for any commercially operated social media presence. Ours is the same one that covers crossroutes.de: Legal Notice.

9.Looking for the app or website policy instead?

This page is only about the TikTok profile itself. If you're looking for how the Crossroutes app handles your data, see the App Privacy Policy. If you're looking for how crossroutes.de itself handles visitor data, see Website Privacy.

10.Changes to this notice

If a meaningful change to how this profile is run affects this notice, we'll update it here — the "Stand" date above always reflects the current version.

11.Contact

Questions about this notice: [email protected].