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The policy authorizes MyFitnessPal and its third-party partners to combine online behavior and device location data across multiple browsers and devices attributed to the same user, and to use inferred device associations to deliver targeted advertisements and measure campaign effectiveness.
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 device identifiers, location data, and behavioral data may be combined across browsers and devices by third-party partners, creating a cross-device profile used for advertising delivery and measurement, which engages both CCPA targeted advertising opt-out rights and GDPR consent requirements for EEA users.
The agreement authorizes third-party partners to infer device associations and deliver advertisements across multiple devices attributed to a user; opting out through Cookie Preferences or the in-app Privacy Center is required separately on each browser and device, as the policy states preferences are applied at the browser or device level.
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"Cross-Device Tracking . We and our third-party partners may use the information we collect to help us identify other devices that you use (e.g., a mobile phone, tablet, computer, etc.). This means that your online behavior on your current browser or device and your device's location may be combined with information collected from your other browsers or devices. Upon making an inference that a device is in use by you, our partners may use this information to deliver an advertisement on the device, to limit the number of times you see an advertisement across your devices, and to help measure the effectiveness of our campaigns across devices.Excerpt from MyFitnessPal's Privacy Policy
1) REGULATORY LANDSCAPE: Cross-device tracking engages CCPA's definition of 'sharing' for cross-context behavioral advertising, GDPR consent requirements for tracking technologies under the ePrivacy Directive, and FTC guidelines on cross-device tracking disclosed in the FTC's 2017 cross-device tracking report. State AG offices in California, Colorado, Connecticut, and Virginia have authority over targeted advertising opt-out obligations under their respective state privacy statutes. 2) GOVERNANCE EXPOSURE: Medium. The policy discloses cross-device tracking by third-party partners and the use of inferred device associations for advertising. The practical scope of the cross-device data graph depends on partner integrations not fully enumerated in the policy, creating compliance exposure if partner data use exceeds what is disclosed. 3) JURISDICTION FLAGS: EEA and UK users require prior consent under GDPR and the ePrivacy Directive for cross-device tracking cookies. California CPRA opt-out rights for cross-context behavioral advertising apply to California residents. The policy's statement that preferences must be set on each browser and device separately may not satisfy GPC signal recognition requirements under CPRA. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party partners conducting cross-device tracking on MyFitnessPal's behalf should be subject to data processing agreements specifying permissible use cases, data retention limits, and restrictions on onward transfer. Procurement teams should audit partner agreements to confirm that inferred device data is not used for purposes beyond those disclosed. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate: (a) whether the per-browser and per-device opt-out requirement is consistent with GPC recognition obligations; (b) whether cross-device data flows are documented in data processing records; (c) whether EEA consent banners capture valid consent for cross-device tracking; and (d) whether third-party partner contracts restrict cross-device data use to the purposes stated in this policy.
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This provision establishes that device identifiers, location data, and behavioral data may be combined across browsers and devices by third-party partners, creating a cross-device profile used for advertising delivery and measurement, which engages both CCPA targeted advertising opt-out rights and GDPR consent requirements for EEA users.
The agreement authorizes third-party partners to infer device associations and deliver advertisements across multiple devices attributed to a user; opting out through Cookie Preferences or the in-app Privacy Center is required separately on each browser and device, as the policy states preferences are applied at the browser or device level.
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