Noom · Noom Privacy Policy · View original document ↗

International Data Transfers

Low severity Medium confidence Explicitdocumentlanguage Common · 55 of 343 platforms
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Document Record

What it is

Noom may transfer your data to countries outside your own, including the US, which may have less protective privacy laws than your home country.

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)

For EU and UK users, transferring health data to the US requires specific legal safeguards, and the adequacy of those safeguards is a live area of regulatory scrutiny.

Interpretive note: The policy does not specify which transfer mechanism is used for EU/UK to US data transfers, creating uncertainty about whether GDPR Chapter V requirements are fully satisfied.

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

If you are an EU or UK user, your health and personal data may be transferred to the United States, where it is subject to US law rather than GDPR; Noom states it takes appropriate safeguards but does not specify the transfer mechanism used, such as Standard Contractual Clauses.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Medium Medium

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

Grindr Medium

Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy.

— Excerpt from Noom's Noom Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: GDPR Chapter V restricts transfers of personal data to third countries unless an adequate level of protection is ensured; Standard Contractual Clauses, the EU-US Data Privacy Framework, and adequacy decisions are the primary lawful transfer mechanisms; the UK has its own International Data Transfer Agreement for post-Brexit transfers; the absence of specificity about the transfer mechanism used by Noom means the adequacy of protection is difficult for users or regulators to assess from the policy text alone. GOVERNANCE EXPOSURE: Medium. The vague reference to appropriate safeguards without specifying the legal mechanism creates compliance uncertainty; European supervisory authorities and the UK ICO have taken enforcement action against companies that cannot demonstrate valid transfer mechanisms, particularly for sensitive data categories. JURISDICTION FLAGS: EU/EEA (GDPR Chapter V, enforced by lead supervisory authority and local DPAs); UK (UK GDPR and ICO International Data Transfer requirements); transfers of health data attract heightened scrutiny given special category status. CONTRACT AND VENDOR IMPLICATIONS: Noom's agreements with US-based advertising, analytics, and service provider partners should include SCCs or rely on the EU-US Data Privacy Framework where applicable; legal teams should confirm transfer mechanisms are current following post-Schrems II requirements. COMPLIANCE CONSIDERATIONS: The privacy policy should be updated to specify the legal mechanism used for international transfers; a transfer impact assessment may be warranted for transfers of health data to the US; EU and UK users should be informed of the specific safeguards in place so they can make informed decisions about providing sensitive health data.

Full compliance analysis

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

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Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

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-009790
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-009790
Captured: 2026-04-28 06:52:27 UTC
SHA-256: 05252f553ca68646…
URL: https://conductatlas.com/platform/noom/noom-privacy-policy/international-data-transfers/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Noom's International Data Transfers clause do?

For EU and UK users, transferring health data to the US requires specific legal safeguards, and the adequacy of those safeguards is a live area of regulatory scrutiny.

How does this clause affect you?

If you are an EU or UK user, your health and personal data may be transferred to the United States, where it is subject to US law rather than GDPR; Noom states it takes appropriate safeguards but does not specify the transfer mechanism used, such as Standard Contractual Clauses.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 55 platforms. See the full comparison.

Is ConductAtlas affiliated with Noom?

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