Calm · Calm Privacy Policy · View original document ↗

Behavioral Advertising and Cookie-Based Tracking

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Calm allows third-party advertising and analytics companies to place tracking technologies on your devices to collect information about your behavior across the web and use it to serve targeted ads.

This analysis describes what Calm's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Third-party tracking extends beyond Calm's own services and may result in your browsing behavior across other websites being collected and used to target you with ads.

Consumer impact (what this means for users)

Third-party ad and analytics partners may track your online activity across websites and apps using cookies and device identifiers, and this data is used to serve you targeted advertising on other platforms.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Visit calm.com/optout to opt out of cookie-based behavioral advertising. You can also use the Cookie Preferences Manager on Calm's website, or enable a Global Privacy Control signal in your browser to opt out automatically for California users.

How other platforms handle this

American Airlines Medium

American gets this information by using technologies, including cookies, web beacons, and mobile device geolocation to provide and improve our Interactive Services and advertising, including across browsers and devices (also known as cross-device linking). This technical information may be combined ...

Progressive Medium

We and our service providers may use cookies, web beacons, pixel tags, and other tracking technologies to collect information about your browsing behavior, device type, IP address, and interactions with our website and advertisements.

Zendesk Medium

We use cookies and similar tracking technologies to track the activity on our websites and services and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze our services. You can instruct your browser to ...

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▸ View Original Clause Language DOCUMENT RECORD
"
We allow others to provide analytics services and serve advertisements on our behalf across the web and other online services. These entities use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, device identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information.

— Excerpt from Calm's Calm Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Cookie-based tracking and behavioral advertising engage the EU ePrivacy Directive (Cookie Directive), GDPR consent requirements, the UK Privacy and Electronic Communications Regulations, and CPRA's 'sharing' opt-out provisions. The FTC also has authority over unfair or deceptive tracking practices. Under GDPR and ePrivacy, non-essential cookies generally require prior informed consent; the policy's provision of a Cookie Preferences Manager and opt-out page is consistent with this requirement but the adequacy of the implementation depends on the specific consent mechanism deployed. (2) GOVERNANCE EXPOSURE: Medium. The scope of third-party tracking described is standard for consumer technology platforms but is substantive; the combination of cross-site tracking with Calm's wellness data context may attract heightened regulatory attention. The policy's reference to Global Privacy Control as a recognized opt-out signal for California users is a positive compliance indicator. (3) JURISDICTION FLAGS: EU/EEA and UK users require prior consent for non-essential cookies under ePrivacy rules. California users under CPRA are entitled to opt out of 'sharing' for cross-context behavioral advertising. The opt-out mechanism at calm.com/optout and the Cookie Preferences Manager should be evaluated to confirm they function correctly for each jurisdiction. (4) CONTRACT AND VENDOR IMPLICATIONS: Each third-party analytics and advertising partner receiving tracking data should be assessed under appropriate data processing or controller agreements. The volume and diversity of third-party partners implied by the policy's disclosure warrants a vendor inventory and periodic assessment. (5) COMPLIANCE CONSIDERATIONS: A cookie audit should be conducted to confirm that all tracking technologies deployed on Calm's web and app properties are disclosed in the Cookie Preferences Manager and that consent is obtained prior to non-essential cookie placement for EU/UK users. The California-specific opt-out page and GPC signal response should be tested for accuracy and completeness.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices in online behavioral advertising and third-party tracking, and has issued guidance on cross-context behavioral advertising practices.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Calm Privacy Policy
Entity
Calm
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-009942
Document ID
CA-D-00218
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6b81368a982bdbc72c1c75ee7ed70374d68d979bedcaaa382c4440f59aef9243
Analysis generated
May 8, 2026 12:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Calm
Document: Calm Privacy Policy
Record ID: CA-P-009942
Captured: 2026-05-08 12:04:34 UTC
SHA-256: 6b81368a982bdbc7…
URL: https://conductatlas.com/platform/calm/calm-privacy-policy/behavioral-advertising-and-cookie-based-tracking/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Calm's Behavioral Advertising and Cookie-Based Tracking clause do?

Third-party tracking extends beyond Calm's own services and may result in your browsing behavior across other websites being collected and used to target you with ads.

How does this clause affect you?

Third-party ad and analytics partners may track your online activity across websites and apps using cookies and device identifiers, and this data is used to serve you targeted advertising on other platforms.

Is ConductAtlas affiliated with Calm?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Calm.