The policy discloses that Noom collects and analyzes health data including weight, mental state, sleep, exercise habits, and food intake, as well as sensitive demographic data including racial or ethnic origin, religion, and philosophical beliefs, including data inferred rather than directly provided by users.
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
This provision authorizes collection of data categories that qualify as 'special categories' under GDPR Article 9 and as 'sensitive personal information' under CCPA/CPRA, triggering heightened processing requirements and opt-out rights in multiple jurisdictions. The disclosure that sensitive demographic data may be inferred by Noom rather than directly provided by users adds an additional processing layer that may require distinct legal basis evaluation under applicable frameworks.
The agreement authorizes Noom to collect and analyze health and sensitive demographic information, including data inferred from user activity, and to use this data across all stated purposes including product improvement, AI and machine learning development, personalization, marketing, and advertising. Under applicable state and federal frameworks, users in covered jurisdictions may have rights to limit use or disclosure of sensitive personal information beyond what is necessary to provide the Noom service.
Cross-platform context
See how other platforms handle Collection and Use of Sensitive Health Data and similar clauses.
Compare across platforms →"Health data: We collect and analyze information concerning your health, such as weight, mental state, sleep and exercise habits, and food intake. Sensitive demographic data: We collect information about racial or ethnic origin, religion, or philosophical beliefs that you may provide or we infer throughout the program to better support you.Excerpt from Noom's Privacy Policy
(1) REGULATORY LANDSCAPE: Collection of health data and sensitive demographic data (racial or ethnic origin, religion) engages GDPR Article 9 (special categories of personal data), which generally requires explicit consent or another enumerated lawful basis …
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This provision authorizes collection of data categories that qualify as 'special categories' under GDPR Article 9 and as 'sensitive personal information' under CCPA/CPRA, triggering heightened processing requirements and opt-out rights in multiple jurisdictions. The disclosure that sensitive demographic data may be inferred by Noom rather than directly provided by users adds an additional processing layer that may require distinct legal …
The agreement authorizes Noom to collect and analyze health and sensitive demographic information, including data inferred from user activity, and to use this data across all stated purposes including product improvement, AI and machine learning development, personalization, marketing, and advertising. Under applicable state and federal frameworks, users in covered jurisdictions may have rights to limit use or disclosure of sensitive …
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