Calm · Calm Privacy Policy · View original document ↗

Cross-Platform Ad Targeting Using Email or Phone Identifiers

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

Calm may share a hashed or converted version of your email address or phone number with advertising partners so they can target you with Calm ads on other websites and apps.

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 practice means your contact information, which you provided to Calm for account purposes, may be used to track and target you with ads outside of Calm's own services.

Clause Stability Stable

0
Changes
3
Months Monitored
May 11, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 1153 other provisions on other platforms.

Consumer impact (what this means for users)

Your email address or phone number may be converted into an advertising identifier and shared with third-party platforms, enabling cross-platform ad targeting based on your Calm account identity.

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 and follow the instructions to opt out of targeted advertising and data sharing with advertising partners, including the use of your contact information for cross-platform ad targeting.

How other platforms handle this

Hinge Medium

We are part of the Match Group family of businesses. Match Group considers the safety and security of members a top priority. If you were banned from another Match Group service, your data can be shared with us to allow us to take necessary actions, including closing your account or preventing you f...

MetaMask Medium

We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
Some of our advertising partners enable us to convert your email address or phone number into an identifier to show ads that are more relevant to you on other platforms.

— Excerpt from Calm's Calm Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This practice implicates GDPR Article 6 (lawful basis) and Article 5 (purpose limitation), as using contact data provided for account creation to enable cross-platform ad targeting may not align with user expectations or the original collection purpose. Under CPRA, this activity may constitute 'sharing' personal information for cross-context behavioral advertising, triggering opt-out obligations. The FTC's enforcement posture on unfair or deceptive data practices is also relevant. Relevant enforcement authorities include data protection supervisory authorities in EU/EEA member states, the UK ICO, the California Privacy Protection Agency, and the FTC. (2) GOVERNANCE EXPOSURE: Medium-High. The conversion of contact identifiers for cross-platform targeting is a disclosed practice but one that engages purpose limitation principles under GDPR. The policy relies on legitimate interests as a legal basis for advertising personalization, which may face challenge under GDPR's balancing test, particularly given the sensitive lifestyle context of Calm's services. Under CPRA, this is likely classified as 'sharing' for cross-context behavioral advertising, requiring an opt-out mechanism, which the policy does provide. (3) JURISDICTION FLAGS: EU/EEA and UK users face the highest exposure; legitimate interest as a basis for this processing may require a documented balancing test. California residents are entitled to opt out of this 'sharing' practice. The Global Privacy Control signal must be honored for California users under CPRA. (4) CONTRACT AND VENDOR IMPLICATIONS: Advertising partners receiving hashed identifiers should be assessed under data processing agreements or controller-to-controller agreements as appropriate. Procurement teams should verify that partner agreements reflect the disclosed purposes and include appropriate restrictions on onward data use. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism at calm.com/optout and the Cookie Preferences Manager effectively prevent email or phone identifier sharing with advertising partners when activated. Consent mechanisms for EU/UK users should be evaluated to confirm whether consent (rather than legitimate interest) is obtained for this specific processing activity.

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 data practices, including the use of consumer contact information for cross-platform advertising without adequate disclosure or opt-out mechanisms.
    File a complaint →
  • State AG
    California residents may file complaints regarding 'sharing' of personal information for cross-context behavioral advertising under the CPRA with the California Attorney General or the California Privacy Protection Agency.
    File a complaint →

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
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-009936
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-009936
Captured: 2026-05-08 12:04:34 UTC
SHA-256: 6b81368a982bdbc7…
URL: https://conductatlas.com/platform/calm/calm-privacy-policy/cross-platform-ad-targeting-using-email-or-phone-identifiers/
Accessed: June 27, 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 Cross-Platform Ad Targeting Using Email or Phone Identifiers clause do?

This practice means your contact information, which you provided to Calm for account purposes, may be used to track and target you with ads outside of Calm's own services.

How does this clause affect you?

Your email address or phone number may be converted into an advertising identifier and shared with third-party platforms, enabling cross-platform ad targeting based on your Calm account identity.

Is ConductAtlas affiliated with Calm?

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