Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The policy authorizes disclosure and transfer of personal information, including health-adjacent diary data, to acquiring companies, investors, lenders, auditors, and advisors in connection with mergers, acquisitions, restructurings, financing transactions, or bankruptcy proceedings.
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 permits health-adjacent personal information to be transferred to entities not party to the current privacy relationship during corporate transactions, including prior to transaction completion, which may result in sensitive data being accessible to acquirers or lenders before a new privacy policy is in effect.
Under this clause, personal information collected by MyFitnessPal, including Food and Activity Diary Data that may include medications and physiological conditions, may be disclosed to acquiring companies, lenders, and advisors during or in anticipation of a corporate transaction.
Cross-platform context
See how other platforms handle Data Disclosure in Business Transactions and similar clauses.
Compare across platforms →Monitoring
MyFitnessPal has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.
"If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer your personal information to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction, such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.Excerpt from MyFitnessPal's Privacy Policy
1) REGULATORY LANDSCAPE: Business transaction data transfers engage CCPA's requirement that successor entities honor the privacy policy under which data was collected, GDPR's lawful basis requirements for processing personal data in a transaction context, and FTC guidance on data transfers in acquisitions. HHS OCR has issued guidance on health data transfers in healthcare-adjacent M&A contexts, though HIPAA applicability to MyFitnessPal as a consumer app is not asserted in the document. 2) GOVERNANCE EXPOSURE: Medium. The broad category of personal information potentially disclosed in a transaction context, combined with the health-adjacent nature of MyFitnessPal's core data, creates material exposure if an acquirer's data practices differ materially from current policy commitments. Pre-completion disclosure to lenders and advisors is noted explicitly. 3) JURISDICTION FLAGS: California residents retain rights under CCPA regarding data transferred in business transactions, and the successor entity would be required to honor existing opt-out requests. EEA users require a documented lawful basis for transaction-related data transfers under GDPR. 4) CONTRACT AND VENDOR IMPLICATIONS: Due diligence teams reviewing potential acquisitions of MyFitnessPal should assess the sensitivity of health-adjacent data assets and applicable regulatory obligations that would transfer with the data. Non-disclosure agreements with transaction advisors should address the sensitivity of health-related personal data. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate: (a) whether successor entity obligations under CCPA and equivalent state laws are addressed in transaction documentation; (b) whether pre-completion data disclosures to advisors and lenders are governed by adequate confidentiality and data handling obligations; and (c) whether EEA data transfer documentation would need to be updated in an acquisition scenario.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision permits health-adjacent personal information to be transferred to entities not party to the current privacy relationship during corporate transactions, including prior to transaction completion, which may result in sensitive data being accessible to acquirers or lenders before a new privacy policy is in effect.
Under this clause, personal information collected by MyFitnessPal, including Food and Activity Diary Data that may include medications and physiological conditions, may be disclosed to acquiring companies, lenders, and advisors during or in anticipation of a corporate transaction.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by MyFitnessPal.