75 Total
16 High severity
47 Medium severity
12 Low severity

Key Facts

What does Noom require regarding continued use after policy changes?
Noom requires that continued use of Noom after policy changes take effect constitutes agreement to the new policy.
Does continued use of Noom after policy changes take effect constitute agreement to the new policy?
Noom requires that continued use of Noom after policy changes take effect constitutes agreement to the new policy.
What legal reasons may there be to retain user data?
Noom states there may be legal reasons to retain user data, such as in response to a law enforcement request to preserve data, that could override a user's deletion request.
Could legal reasons to retain user data override a user's deletion request?
Noom states there may be legal reasons to retain user data, such as in response to a law enforcement request to preserve data, that could override a user's deletion request.
What does Noom collect in combination with passwords, security codes, access codes, or other credentials?
Noom collects usernames or account numbers in combination with passwords, security codes, access codes, or other credentials that allow access to an account.
What does Noom collect from chats and message boards within Noom's apps?
Noom collects the contents of messages users send in chats and message boards within Noom's apps.
What information about racial or ethnic origin, religion, or philosophical beliefs does Noom collect?
Noom collects information about racial or ethnic origin, religion, or philosophical beliefs that users provide or that Noom infers throughout the program.
Does Noom collect information that users provide or that Noom infers?
Noom collects information about racial or ethnic origin, religion, or philosophical beliefs that users provide or that Noom infers throughout the program.
What health-related information does Noom collect and analyze?
Noom collects and analyzes health-related information including weight, mental state, sleep and exercise habits, and food intake.
When will Noom access, disclose, and preserve user information?
Noom will access, disclose, and preserve user information when it believes doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
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Summary

Noom collects a wide range of sensitive personal data — including your health metrics, message content, account credentials, and information about your beliefs or background — and uses it to run and improve its services, including building AI systems. Some of your data may be shared with or collected by third-party advertising companies, and Noom acknowledges this may qualify as a sale of personal information under certain state laws, meaning you have the right to opt out. If you continue using Noom after a policy change, Noom treats that as your agreement to the updated terms.

Analysis

Noom's privacy policy establishes the scope of personal data Noom collects, the purposes for which that data is used, and the conditions under which it is shared or retained. Collected data includes account credentials, in-app message content, inferred or volunteered sensitive attributes such as racial or ethnic origin and philosophical beliefs, and health data including weight, mental state, sleep, exercise, and food intake, which Noom actively analyzes. Noom uses this data to improve existing products and services and to develop new ones including AI and machine learning systems. Data may be shared with law enforcement and government agencies based on Noom's own assessment of legal necessity, and third-party analytics and advertising companies collect personal data through Noom's platforms and may combine it across other sites. Noom acknowledges that certain third-party disclosures may constitute a sale or sharing of personal information under California and other U.S. state laws, and users retain an opt-out right; legal obligations, including law enforcement data preservation requests, may override user deletion requests.

What this means for you

Noom collects and analyzes highly sensitive personal data — including your health information, in-app messages, account credentials, and inferred attributes about your beliefs or background — and uses it to develop new products and AI systems. Third-party companies collect personal data through Noom's platforms and may combine it across other sites. Noom may sell or share your sensitive personal data, and you have the right to opt out of that sale or sharing. To exercise that right, you can use the opt-out option Noom makes available for the sale or sharing of personal information.

Institutional Analysis
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Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

2 important changes detected

3 versions captured · Last updated: April 2026

What changed Noom updated its privacy policy on April 19, 2026 to add clearer introductory language and summaries explaining what data it collects, how it uses that data, and how it shares information. The policy now includes plain-language summaries at the start of each major section, such as a statement that Noom collects personal, technical, and health information, uses it to run services and personalize experiences, and shares it with service providers and partners. The substantive policy sections remain substantively similar, but the new formatting makes the policy more accessible to non-lawyers reading it for the first time.
Why this matters Noom's policy now leads with a clearer summary explaining that it collects personal, technical, and health information; uses it to personalize services and run the platform; and shares it with service providers and partners for business operations and payments. The updated policy makes these practices more transparent and easier for users to understand before reading the full terms. The core data practices described appear unchanged, but are now presented more accessibly.
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What changed Noom updated its privacy policy on April 3, 2026 to add a summary section at the beginning explaining what data it collects, how it uses that data, and what choices users have. The policy now explicitly states it collects personal, technical, and health information from multiple sources and uses it to personalize services, run the business, and show marketing or ads. The changes make the policy structure more transparent by adding summary sections before detailed explanations, but do not appear to introduce new data collection or usage practices.
Why this matters Noom's updated privacy policy adds transparency by explicitly stating upfront that it collects personal, technical, and health information and uses it for personalization, marketing, and advertising. The policy does not appear to introduce new data collection or usage rights beyond what may have been disclosed in more detailed sections previously. The main practical change is improved clarity about what data categories Noom processes and for what purposes, though the underlying data practices themselves do not appear to have fundamentally changed based on the provided diff.
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Featured, High severity
Featured, Medium severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

75 provisions
12 featured
11 clause types
16 high severity
AI / Automated Decision-Making 1 1 high
Restricted or Prohibited Content/Industries 1 1 high
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Mapped Governance Frameworks

CCPA/CPRA
California, USA
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Connecticut Data Privacy Act Amendments
US-CT
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CAN-SPAM
United States Federal
View official text ↗
ePrivacy Directive
European Union
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FTC Act Section 5
United States Federal
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GDPR
European Union
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HIPAA
United States Federal
View official text ↗
Indiana Consumer Data Protection Act
US-IN
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Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗
Archival ProvenanceSource & Archival Record
Last Captured April 19, 2026 06:18 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000397
Version ID CA-V-000753
SHA-256 fda3dc10dae1f5bff4e6c09096e6999baa24395c2dd36eadf4b77fef91c03e0f
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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