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Instructions on Accessing Data as a Vetted Researcher under the DSA

Under the Digital Services Act (DSA), vetted researchers may request access to Temu data to identify, detect, and understand systemic risks in the European Union (EU), arising from the use of online services, and to assess the adequacy of risk-mitigation measures.

1. How to submit a data access request

Vetted researchers seeking access to data under Article 40(4) of the DSA must submit their application through the European Commission’s (EC) Data Access Portal.

Please note that vetted researchers should submit data requests to the competent Digital Services Coordinator (DSC) and processed via the EC’s official portal. Data access requests may be submitted to:

• the DSC of the EU Member State where the vetted researcher’s affiliated research organization is based; or

• the DSC of Ireland, the EU Member State where Temu is established, namely, Coimisiún na Meán.

2. Vetted Researcher Eligibility

To qualify as a vetted researcher under Article 40(4), applicants must meet the eligibility conditions set out in the DSA and the EC’s Delegated Regulation on Data Access. These include:

• affiliation with an independent research organisation;

• research objectives directly linked to the detection, identification, or understanding of systemic risks or the evaluation of mitigation measures applied by Temu;

• transparent disclosure of funding sources and absence of conflicts of interest;

• commitment to uphold strict data security and confidentiality standards; and

• agreement to make research findings publicly available free of charge.

The vetting and approval process is carried out by the vetted researcher’s national DSC, which assesses eligibility and issues a reasoned request to Temu where appropriate. Further information about the vetting and approval process is available here.

3. Data Catalogue

To help vetted researchers identify potentially relevant data for their studies, Temu maintains a data catalogue outlining a non-exhaustive and regularly-updated list of data categories pertaining exclusively to the EU, as may be available on Temu under Article 40(4).

The catalogue is designed to guide vetted researchers in preparing their applications. The catalogue includes:

Vetted researchers may also apply for access to other publicly accessible data, as set out on our Instruction page for qualified researchers under Article 40(12) of the DSA and in our Transparency Center .

4. Data Structure and Metadata

Information on data structure and metadata may differ across systems and datasets due to variations in data formats and update frequency. Therefore, this information will be evaluated and shared with vetted researchers on a case-by-case basis.

5. Data Access Modalities

Once a vetted researcher’s request has been validated by a DSC and formally transmitted to Temu, Temu will provide data access through secure modalities that will be determined on a case-by-case basis by the DSC, which may vary depending on the nature and sensitivity of data and regulatory requirements.

Temu’s Suggested Access Modalities

Access to vetted researchers may be granted through a virtual desktop infrastructure (VDI), which is a secure and isolated network environment where data is made available.

For real-time and publicly accessible data, vetted researchers are welcome to access our Application Programming Interface (API), which is open to qualified researchers under Article 40(12) DSA.

All access is logged, auditable, and time-limited. Vetted researchers must ensure strict security and confidentiality, including the protection of personal data, where applicable.

6. Contact

Questions regarding the DSA data access process may be directed to legal@eur.temu.com for Article 40(4) research access. Communication in English is preferred.

Please note that the designated point of contact cannot accept or review applications from vetted researchers directly. All formal data access requests must be submitted through the EC’s Data Access Portal and processed by the competent DSC in accordance with the rules of the DSA and its implementing regulations.

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