Provision record
Calm · Calm Privacy Policy · View original document ↗

Behavioral Advertising as Data Sale or Sharing

High severity Common · 287 of 352 platforms
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Document Record

What it is

Calm uses cookies and allows advertising partners to track you across the web to show you targeted ads, and this may legally count as 'selling' or 'sharing' your personal data under privacy laws like CCPA.

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)

This provision establishes the operational framework for Calm's behavioral advertising practices and cross-site tracking infrastructure. It acknowledges regulatory classification of these activities under state privacy laws while specifying the process through which users may decline participation.

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 3, 2026
First Seen
Apr 17, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Consumer impact (what this means for users)

Your browsing behavior and usage data may be shared with advertising partners for cross-platform ad targeting, qualifying as a data 'sale' under CCPA. You can opt out of this practice at calm.com/optout.

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 targeted advertising, data sales, and sharing. You can also use the Cookie Preferences Manager on the Calm website to disable ad trackers.

How other platforms handle this

Oura Medium

We do not sell or share your personal data for cross-context behavioral advertising. You can always opt out of Oura direct marketing communications, though you may still see marketing messaging within the Oura App.

Skillshare Medium

Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud

Squarespace Medium

we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We use cookies and similar tracking technologies, and we allow our advertising partners to use such technologies, so we can, among other things, show you ads promoting Calm on other websites and services. These activities may be considered "sales," "sharing," or "targeted advertising" under certain privacy laws. You can opt out of these practices by visiting calm.com/optout.

Excerpt from Calm's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

Calm's acknowledgment that behavioral advertising activities may constitute 'sales' or 'sharing' under CCPA/CPRA creates opt-out obligations and triggers notice requirements.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001154
Document ID
CA-D-00218
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b57131f2e2dafc52f352427e7378a39e4b2c2e0959965b84e960a4bdab4f8318
Analysis generated
March 20, 2026 07:02 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Calm
Document: Calm Privacy Policy
Record ID: CA-P-001154
Captured: 2026-03-20 07:02:10 UTC
SHA-256: b57131f2e2dafc52…
URL: https://conductatlas.com/platform/calm/calm-privacy-policy/provision/CA-P-001154/behavioral-advertising-as-data-sale-or-sharing/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Calm's Behavioral Advertising as Data Sale or Sharing clause do?

This provision establishes the operational framework for Calm's behavioral advertising practices and cross-site tracking infrastructure. It acknowledges regulatory classification of these activities under state privacy laws while specifying the process through which users may decline participation.

How does this clause affect you?

Your browsing behavior and usage data may be shared with advertising partners for cross-platform ad targeting, qualifying as a data 'sale' under CCPA. You can opt out of this practice at calm.com/optout.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.

Is ConductAtlas affiliated with Calm?

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