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
Many users assume that a health and wellness app is subject to HIPAA protections; this disclaimer clarifies that Noom's data practices are governed by its own privacy policy and applicable consumer privacy laws, not HIPAA's stricter health data standards.
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.
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If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"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
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.
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Many users assume that a health and wellness app is subject to HIPAA protections; this disclaimer clarifies that Noom's data practices are governed by its own privacy policy and applicable consumer privacy laws, not HIPAA's stricter health data standards.
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.
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