Is it particularly different from https://en.wikipedia.org/wiki/CLOUD_Act ?

Yes

https://www.buzzfeednews.com/article/emilybakerwhite/tiktok-...

It's more like being perpetually subject to a National Security Letter (NSL) warrant issued by a US FISA court, a fairly rare occurrence and specifically targeted, but for blanket database replication and as the widespread legal default for every company in China.

The main difference is that HN is mainly visited by American users, not affected by CLOUD act.

The CLOUD Act affects all US companies.

For what it's worth, non-american citizens on non-american soil have no legal protection against the same. And big ad monopolies are not in the business of pissing off the security state.

I don't see how, for instance, with a Austrian customer of a Belgian data center operator, the Belgian data center operator does not have a legal obligation to form a secure database pipeline connection and replicate everything directly into the NSA.

Obviously whatever signals intelligence gathering method or data copying the NSA might be doing in Western Europe could very well exist, but it's not a defined requirement for that theoretical Belgian ISP.

Correct, a Belgian isp would have vastly fewer reasons to comply with polite requests from CIA/NSA than a US-based FAANG.

They are working on a deal with US, all data for US citizens will be kept in US[1].

And some info about it from them directly:

"As we recently shared with members of Congress, we are working toward a new system in which access to U.S. user data by anyone outside of USDS will be limited by, and subject to, robust data access protocols with monitoring and oversight mechanisms by Oracle."[2]

1. https://arstechnica.com/tech-policy/2022/09/tiktok-can-keep-...

2. https://newsroom.tiktok.com/en-us/our-approach-to-keeping-us...

EDIT: downvotes for sharing latest additional data from official sources about the topic without any private opinions? This trend is dangerous for healthy discussion.

doesn't mean their office and staff in china don't remotely have access to the data or the ability to replicate it.

I think it's addressed in sources I've linked, there is a whole section describing who have access to data of US citizens. Additionally I don't think US administration will just let them do it (share whatever they want with China), if a deal will be made then US citizens will control who is and how that data is accessed outside US through Oracle, otherwise they would just be banned as national security threat.

Actually the data was already stored in the US as required by US law. The deal with Oracle is to guarantee the access is limited.