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
The updated policy now permits Calm to infer health-related characteristics from information users voluntarily provide about their feelings, though such inferred data will only be processed for the stated purpose. For minors, the policy explicitly prohibits targeted advertising and data sales, and applies age-appropriate data minimization practices. For residents of 20+ U.S. states with privacy laws, the policy adds detailed disclosures of privacy rights, including the ability to opt out of targeted advertising and data sales (scope varies by state), designate agents to exercise rights on their behalf (Colorado, Connecticut, Minnesota), and request lists of third parties receiving personal data (Minnesota). You can exercise these rights by contacting Calm through the methods specified in the policy or following state-specific instructions provided.
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We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.
We may disclose Contact Data as we reasonably believe is necessary to comply with any judicial or governmental subpoenas, warrants or orders.
These third parties have limited access to your information, may use your information only to perform agreed tasks, and are prohibited from disclosing or using your information for other purposes.
"If your Calm subscription was obtained through a third-party promotion...we may inform them that you redeemed the offerExcerpt from Calm's Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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The clause states: “If your Calm subscription was obtained through a third-party promotion...we may inform them that you redeemed the offer”
ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.
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