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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If you use an authorized agent to submit a request, we will not act on that request unless we are able to authenticate, with commercially reasonable efforts, both your identity and the authorized agent's authority to act on your behalf.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond...
In certain states, you can designate an authorized agent to make a rights request on your behalf. You or the agent must provide written authorization acceptable to us.
"we may require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.Excerpt from Calm's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The clause states: “we may require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.”
ConductAtlas has identified this type of provision across 276 platforms. See the full comparison.
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