Provision record
MyFitnessPal · MyFitnessPal Privacy Policy · View original document ↗

Cookie-Based Sharing as Potential CCPA 'Sale'

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Document Record

What it is

The policy discloses that while MyFitnessPal does not characterize its practices as an express sale of data, the operation of Functional Cookies and Targeted Advertising Cookies may qualify as a 'sale' or 'sharing' of personal information under CCPA and similar state privacy statutes, triggering applicable opt-out rights.

This analysis describes what MyFitnessPal'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 provision creates a direct interaction with CCPA opt-out obligations and similar state law requirements; users in applicable states hold the right to opt out of cookie-based data flows that meet the statutory definition of 'sale' or 'sharing,' and the policy's simultaneous denial of express selling alongside acknowledgment of potential statutory sale treatment may require evaluation under CPPA regulatory guidance.

Interpretive note: The operational classification of cookie-based sharing as a 'sale' under CCPA depends on the specific data flows and partner relationships, which are not fully enumerated in the policy; applicable law and CPPA regulatory guidance may govern the ultimate determination.

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, device identifiers, browsing activity, and usage information transmitted through Targeted Advertising Cookies may constitute a 'sale' of personal information under California law, entitling California residents to opt out through the Cookie Preferences link or the Privacy Center in the app.

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 the MyFitnessPal website, click 'Cookie Preferences' in the footer, and adjust settings to opt out of Targeted Advertising Cookies. Repeat on each browser and device used.

Cross-platform context

See how other platforms handle Cookie-Based Sharing as Potential CCPA 'Sale' and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
While MyFitnessPal does not expressly 'sell' information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose information may constitute 'sales' or 'sharing' of personal information or the use of personal information for 'targeted advertising' purposes under applicable privacy laws.

Excerpt from MyFitnessPal's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision directly engages CCPA as amended by CPRA (California Civil Code Section 1798.100 et seq.), enforced by the California Privacy Protection Agency and California AG.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
MyFitnessPal Privacy Policy
Entity
MyFitnessPal
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
July 9, 2026
Record ID
CA-P-015192
Document ID
CA-D-00150
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e8a00675fe5ad84cfe5a6a7c0d9d88889aaed93bcf547ddec00141f378e8a3ae
Analysis generated
May 8, 2026 05:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: MyFitnessPal
Document: MyFitnessPal Privacy Policy
Record ID: CA-P-015192
Captured: 2026-05-08 05:22:54 UTC
SHA-256: e8a00675fe5ad84c…
URL: https://conductatlas.com/platform/myfitnesspal/myfitnesspal-privacy-policy/provision/CA-P-015192/cookie-based-sharing-as-potential-ccpa-sale/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does MyFitnessPal's Cookie-Based Sharing as Potential CCPA 'Sale' clause do?

This provision creates a direct interaction with CCPA opt-out obligations and similar state law requirements; users in applicable states hold the right to opt out of cookie-based data flows that meet the statutory definition of 'sale' or 'sharing,' and the policy's simultaneous denial of express selling alongside acknowledgment of potential statutory sale treatment may require evaluation under CPPA regulatory guidance.

How does this clause affect you?

Under this clause, device identifiers, browsing activity, and usage information transmitted through Targeted Advertising Cookies may constitute a 'sale' of personal information under California law, entitling California residents to opt out through the Cookie Preferences link or the Privacy Center in the app.

Is ConductAtlas affiliated with MyFitnessPal?

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