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The policy authorizes the use of personal information, including health-adjacent diary data, in machine learning systems and artificial intelligence tools to personalize content, generate meal plans and recommendations, produce analytics, and test new features.
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 authorizes the application of machine learning and artificial intelligence to health-adjacent personal data, including Food and Activity Diary Data that may include medications and physiological conditions, for automated personalization and recommendation purposes, which may engage automated decision-making provisions under GDPR and emerging AI governance frameworks.
Interpretive note: The policy does not specify the degree of automation or whether AI-generated recommendations constitute automated decision-making with legal or significant effects under GDPR Article 22; applicability of EU AI Act obligations depends on system risk classification not disclosed in the document.
Under this clause, personal information including dietary habits, body measurements, and health goals may be processed by machine learning and AI systems to generate personalized meal plans, suggestions, and recommendations within the service.
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"We use your personal information to improve and enhance our Services, including through the use of various technologies (e.g., business intelligence tools, machine learning systems, and artificial intelligence), personalize content and features to your interests and goals (e.g., providing suggestions, reporting and analytics, meal plans, and recommendations), and test out new features and updates to our Services.Excerpt from MyFitnessPal's Privacy Policy
1) REGULATORY LANDSCAPE: The use of AI and machine learning on personal data engages GDPR Article 22 (automated individual decision-making, including profiling) for EEA users, which may require disclosure, a lawful basis, and in some cases a right to human review. The EU AI Act may apply depending on the risk classification of AI systems used for health-related recommendations. The FTC has issued guidance on AI and algorithmic accountability relevant to consumer health applications. 2) GOVERNANCE EXPOSURE: Medium. The policy authorizes AI processing of health-adjacent data for recommendation and personalization purposes but does not specify the degree of automation, the types of decisions made, or whether human review is available. For EEA users, the absence of GDPR Article 22 disclosure specificity may require evaluation. 3) JURISDICTION FLAGS: EEA users are protected by GDPR Article 22 automated decision-making provisions. EU AI Act obligations may apply depending on whether health recommendation AI systems are classified as high-risk under the regulation's Annex III. California's CPRA profiling opt-out rights apply to automated profiling of California residents. 4) CONTRACT AND VENDOR IMPLICATIONS: If third-party AI or machine learning vendors process personal information on MyFitnessPal's behalf, applicable data processing agreements should address the specific use cases, data inputs, and output restrictions for AI systems handling health-adjacent data. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate: (a) whether AI-based recommendation systems constitute 'profiling' under GDPR and whether CCPA's profiling opt-out right is operationally implemented; (b) whether the EU AI Act's risk classification process has been applied to health recommendation AI systems; (c) whether GDPR Article 22 disclosure and, where applicable, human review mechanisms are in place for EEA users; and (d) whether AI system outputs, such as meal plans and health recommendations, are subject to accuracy and bias review procedures given the health-sensitive nature of the underlying data.
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This provision authorizes the application of machine learning and artificial intelligence to health-adjacent personal data, including Food and Activity Diary Data that may include medications and physiological conditions, for automated personalization and recommendation purposes, which may engage automated decision-making provisions under GDPR and emerging AI governance frameworks.
Under this clause, personal information including dietary habits, body measurements, and health goals may be processed by machine learning and AI systems to generate personalized meal plans, suggestions, and recommendations within the service.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by MyFitnessPal.