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HIPAA Non-Applicability Disclaimer

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What it is

Noom is telling you that HIPAA, the federal health privacy law, does not apply to your data, so you do not have HIPAA-based rights to access, correct, or restrict how Noom uses your health information.

This analysis describes what Noom'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This disclaimer establishes the regulatory status of the service by clarifying that HIPAA's privacy and security protections, which typically apply to covered entities handling health information, do not extend to Noom's data handling practices. This distinction defines which federal regulatory standards govern the company's obligations regarding user health information.

Consumer impact (what this means for users)

Because Noom is not a HIPAA-covered entity, the detailed health data you enter does not receive the legal protections HIPAA would provide to medical records; your rights over this data depend on Noom's policy and applicable state privacy laws rather than federal health privacy law. Users in states with stronger health data laws, such as Washington, may have additional protections.

How other platforms handle this

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▸ View Original Clause Language DOCUMENT RECORD
"
Noom is not a HIPAA-covered entity and the information you provide to us is not protected health information under HIPAA.

— Excerpt from Noom's Noom Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: HIPAA's Privacy and Security Rules apply to covered entities (healthcare providers, health plans, and their business associates); Noom's disclaimer is consistent with the general understanding that consumer wellness apps are not HIPAA-covered entities, though HHS OCR has noted that HIPAA applicability depends on the specific facts of data flows; the FTC Health Breach Notification Rule, however, does apply to certain non-HIPAA health apps and requires notification in the event of a breach of unsecured identifiable health information; Washington State's My Health MY Data Act and similar state laws may impose HIPAA-adjacent obligations on consumer health apps regardless of HIPAA status. GOVERNANCE EXPOSURE: Medium. The disclaimer is legally accurate for most consumer app contexts, but the absence of HIPAA coverage means users may have significantly reduced expectations about the security and sharing standards applicable to their health data; the FTC Health Breach Notification Rule creates a parallel federal obligation that compliance teams should confirm is addressed in Noom's incident response procedures. JURISDICTION FLAGS: Washington State (My Health MY Data Act imposes obligations on consumer health data regardless of HIPAA status); Illinois, Nevada, and other states with health or biometric data laws; EU/EEA (GDPR treats health data as a special category regardless of HIPAA status). CONTRACT AND VENDOR IMPLICATIONS: Employers offering Noom as a corporate wellness benefit should not assume HIPAA Business Associate Agreement protections apply; if employer-sponsored health plan data flows into Noom, separate HIPAA analysis may be required; vendor contracts should specify the applicable data security standards in the absence of HIPAA. COMPLIANCE CONSIDERATIONS: Noom's incident response and breach notification procedures should be reviewed to confirm compliance with the FTC Health Breach Notification Rule; compliance teams should assess applicability of state health data laws on a jurisdiction-by-jurisdiction basis; the disclaimer should be prominently disclosed in user-facing materials to manage user expectations about the level of legal protection afforded to their health data.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces the Health Breach Notification Rule and Section 5 of the FTC Act for non-HIPAA health app operators, making it the primary federal oversight body for Noom's health data practices.
    File a complaint →

Provision details

Document information
Document
Noom Privacy Policy
Entity
Noom
Document last updated
May 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 10, 2026
Record ID
CA-P-009787
Document ID
CA-D-00397
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
05252f553ca6864667d2e582f332534d7ecc993e8e01284deda5add6a0607bb0
Analysis generated
April 28, 2026 06:52 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Noom
Document: Noom Privacy Policy
Record ID: CA-P-009787
Captured: 2026-04-28 06:52:27 UTC
SHA-256: 05252f553ca68646…
URL: https://conductatlas.com/platform/noom/noom-privacy-policy/hipaa-non-applicability-disclaimer/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Noom's HIPAA Non-Applicability Disclaimer clause do?

This disclaimer establishes the regulatory status of the service by clarifying that HIPAA's privacy and security protections, which typically apply to covered entities handling health information, do not extend to Noom's data handling practices. This distinction defines which federal regulatory standards govern the company's obligations regarding user health information.

How does this clause affect you?

Because Noom is not a HIPAA-covered entity, the detailed health data you enter does not receive the legal protections HIPAA would provide to medical records; your rights over this data depend on Noom's policy and applicable state privacy laws rather than federal health privacy law. Users in states with stronger health data laws, such as Washington, may have additional protections.

Is ConductAtlas affiliated with Noom?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Noom.