Grindr · Grindr Terms of Service · View original document ↗

Sensitive Personal Data Collection including HIV Status

High severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Grindr collects highly sensitive personal information including your HIV status, sexual preferences, and precise location as part of creating and maintaining your profile and using the service.

This analysis describes what Grindr'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)

HIV status and sexual orientation are among the most sensitive categories of personal data, and their collection and potential disclosure can create significant real-world risks for users including discrimination, outing, and safety threats.

Consumer impact (what this means for users)

By using Grindr and completing your profile, you consent to the collection of health data (HIV status) and sexual orientation data, which are special category data under GDPR and carry heightened sensitivity; mishandling or unauthorized disclosure of this information could have serious personal consequences.

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.
  • Delete Your Data
    Submit a data deletion request through Grindr's help center or privacy request form. California residents and EU/EEA users have enforceable rights to request deletion of their personal data including sensitive health information.

How other platforms handle this

Egnyte Medium

We collect information you provide directly to us, such as when you create an account, contact us for support, sign up for marketing emails, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, company name, job tit...

ClickUp Medium

We collect information you provide directly to us, such as when you create an account, use our Services, make a purchase, or contact us for support. The types of information we may collect include your name, email address, password, phone number, credit card and other payment information, and any ot...

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.

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▸ View Original Clause Language DOCUMENT RECORD
"
We collect information you give us when you use our Services. This includes: profile information such as your name, username, email, phone number, date of birth, HIV status, sexual preferences, relationship status, ethnicity, and photos. We use your precise geolocation information to show your distance to other users and to provide location-based features of our Services.

— Excerpt from Grindr's Grindr Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: GDPR Article 9 designates health data and data concerning sexual orientation as special category data requiring explicit consent under Article 9(2)(a) or another enumerated legal basis. The Norwegian Data Protection Authority fined Grindr approximately 65 million NOK in 2021 for sharing user data including HIV status with advertising partners without valid GDPR consent. The FTC Act Section 5 prohibits unfair or deceptive practices, and the FTC has signaled that mishandling of sensitive health data by consumer apps constitutes an unfair practice. CCPA/CPRA classifies sensitive personal information including health data and sexual orientation as a distinct category requiring additional disclosure and opt-out rights. GOVERNANCE EXPOSURE: High. The collection of HIV status is a documented regulatory risk area for Grindr specifically, with prior enforcement action. The adequacy of the consent mechanism for special category data under GDPR must meet the standard of being freely given, specific, informed, and unambiguous, and conditioning core service access on providing this data may not satisfy the freely given requirement under GDPR Recital 43. JURISDICTION FLAGS: EU/EEA users have the strongest protections under GDPR Article 9, and any onward transfer of this data to third countries must comply with Chapter V transfer mechanisms. California users have CPRA rights to limit use of sensitive personal information. Illinois users should be aware that location data practices may intersect with state privacy discussions. Users in jurisdictions where homosexuality is criminalized face acute safety risks from any data exposure. CONTRACT AND VENDOR IMPLICATIONS: Any vendor or partner receiving HIV status or sexual orientation data must be assessed under GDPR Article 28 data processor agreements or Article 26 joint controller arrangements. Advertising technology partners in particular require scrutiny given the prior enforcement history. Data sharing agreements should explicitly restrict onward transfer and re-identification. COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether the consent mechanism for HIV status and sexual orientation data meets GDPR Article 9 explicit consent standards, including granularity and the ability to withdraw consent without detriment. A data mapping exercise should confirm which third parties receive special category data. CPRA compliance requires publishing a clear notice of the right to limit use of sensitive personal information. Security assessments should address the specific risk profile of storing health and orientation data given the sensitivity of the user population.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has enforcement authority over unfair data practices involving sensitive health information collected by consumer apps under FTC Act Section 5
    File a complaint →
  • State AG
    State attorneys general have authority under CCPA/CPRA and state consumer protection laws to enforce rights regarding sensitive personal information including health data and sexual orientation
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Grindr Terms of Service
Entity
Grindr
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-007572
Document ID
CA-D-00269
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
33e47cc19955427d2ed8dd4c81bb724c515b59cfcbfb1e0fcf39702fc487d424
Analysis generated
May 7, 2026 08:35 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Grindr
Document: Grindr Terms of Service
Record ID: CA-P-007572
Captured: 2026-05-07 08:35:25 UTC
SHA-256: 33e47cc19955427d…
URL: https://conductatlas.com/platform/grindr/grindr-terms-of-service/sensitive-personal-data-collection-including-hiv-status/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Grindr's Sensitive Personal Data Collection including HIV Status clause do?

HIV status and sexual orientation are among the most sensitive categories of personal data, and their collection and potential disclosure can create significant real-world risks for users including discrimination, outing, and safety threats.

How does this clause affect you?

By using Grindr and completing your profile, you consent to the collection of health data (HIV status) and sexual orientation data, which are special category data under GDPR and carry heightened sensitivity; mishandling or unauthorized disclosure of this information could have serious personal consequences.

Is ConductAtlas affiliated with Grindr?

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