The policy discloses that personal information may be transferred to the United States and other countries with different data protection laws, and acknowledges that transferred data may be subject to foreign government, court, or law enforcement access under local law in the destination country.
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
This provision establishes that international data transfers may result in personal information becoming subject to foreign government access obligations, a disclosure that engages GDPR Chapter V transfer requirements and the adequacy determinations and supplementary measures framework established following the Schrems II ruling.
Interpretive note: The policy asserts 'appropriate steps' and 'applicable law' compliance for international transfers but does not specify the legal transfer mechanisms used, creating uncertainty as to whether GDPR Chapter V documentation requirements are fully satisfied.
The agreement informs users that their personal information, including health-adjacent diary data, may be transferred to countries with different privacy protections, and that local laws in those countries may permit government or law enforcement access to the transferred data.
Cross-platform context
See how other platforms handle International Data Transfers with Foreign Government Access Acknowledgment and similar clauses.
Compare across platforms →"When we transfer your personal information outside of your country of residence, we do so in accordance with applicable law and take appropriate steps to ensure your information is protected. However, please note that while outside of the jurisdiction in which you reside, your personal information will be subject to applicable local laws, which might permit foreign governments, courts, law enforcement, or regulatory agencies to access your information in certain circumstances. By using the Services and/or sharing your personal information with MyFitnessPal, you are informed that your personal information may be transferred to countries outside of your country of residence.Excerpt from MyFitnessPal's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V governing transfers of personal data to third countries, the EU-US Data Privacy Framework (and equivalent UK and Swiss arrangements), and the CJEU's Schrems II decision, which …
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This provision establishes that international data transfers may result in personal information becoming subject to foreign government access obligations, a disclosure that engages GDPR Chapter V transfer requirements and the adequacy determinations and supplementary measures framework established following the Schrems II ruling.
The agreement informs users that their personal information, including health-adjacent diary data, may be transferred to countries with different privacy protections, and that local laws in those countries may permit government or law enforcement access to the transferred data.
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