Calm · Calm Privacy Policy · View original document ↗

Merger and Acquisition Data Transfer

Medium severity Unique · 0 of 325 platforms
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Document Record

What it is

If Calm is sold, merged, or its assets are acquired, your personal data may be transferred to the acquiring company as part of that transaction.

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)

The provision establishes the procedural framework for data continuity during corporate transactions, clarifying that user data constitutes a transferable asset subject to assignment alongside business operations. This defines institutional obligations and permissions during material corporate events.

Consumer impact (what this means for users)

A future sale or merger of Calm could result in your personal wellness data being transferred to a third party without your direct consent. Consumers have limited recourse to prevent such transfers under current policy terms.

How other platforms handle this

Windsurf Medium

If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries ...

OpenAI Medium

We may share or transfer personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

X Medium

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal information as transferred to the new entity, although the new ...

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▸ View Original Clause Language DOCUMENT RECORD
"
In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

— Excerpt from Calm's Calm Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

The M&A data transfer clause is standard but carries elevated risk given the sensitivity of Calm's data set (mental wellness, sleep, mood). Due diligence in any acquisition of Calm should carefully assess data asset classification, consent validity for secondary use, and obligations under GDPR Article 13/14 regarding changes in data controller.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC reviews certain mergers and acquisitions and has authority over consumer data practices that may be affected by corporate transactions.
    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
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001160
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-001160
Captured: 2026-03-20 07:02:10 UTC
SHA-256: b57131f2e2dafc52…
URL: https://conductatlas.com/platform/calm/calm-privacy-policy/merger-and-acquisition-data-transfer/
Accessed: May 20, 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 Merger and Acquisition Data Transfer clause do?

The provision establishes the procedural framework for data continuity during corporate transactions, clarifying that user data constitutes a transferable asset subject to assignment alongside business operations. This defines institutional obligations and permissions during material corporate events.

How does this clause affect you?

A future sale or merger of Calm could result in your personal wellness data being transferred to a third party without your direct consent. Consumers have limited recourse to prevent such transfers under current policy terms.

Is ConductAtlas affiliated with Calm?

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