Provision record
Noom · Noom Privacy Policy · View original document ↗

Cross-Border Data Transfer to United States

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The policy discloses that user data, including data from EEA, UK, and Swiss residents, may be transferred to and processed in the United States and other countries, some of which do not have European Commission adequacy determinations, with Noom relying on contractual mechanisms such as standard contractual clauses to support such transfers.

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 provision establishes that sensitive health data, demographic data, and communications content collected from EEA, UK, and Swiss residents may be transferred to the United States under contractual transfer mechanisms, creating compliance obligations under GDPR Chapter V and requiring verification that transfer impact assessments and standard contractual clauses are current and adequate.

Interpretive note: The specific transfer mechanism relied upon (such as standard contractual clauses or EU-US Data Privacy Framework certification) is not named in the policy, creating ambiguity about the applicable safeguard and its adequacy under current GDPR guidance.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, personal and sensitive data collected from users globally, including EEA, UK, and Swiss residents, may be stored and processed in the United States, which does not have a blanket European Commission adequacy determination for all data transfers. Noom states it uses contractual mechanisms to support these transfers, but the specific mechanism (such as standard contractual clauses) is not named in the policy text provided.

Cross-platform context

See how other platforms handle Cross-Border Data Transfer to United States and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
The information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in the United States. These locations were chosen to operate efficiently and improve our performance. We take steps to protect your information as described in this policy wherever the data are located, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections.

Excerpt from Noom's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: Cross-border data transfers from the EEA engage GDPR Chapter V, which requires either an adequacy decision, appropriate safeguards such as standard contractual clauses, or derogations.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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
July 9, 2026
Record ID
CA-P-014864
Document ID
CA-D-00397
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fda3dc10dae1f5bff4e6c09096e6999baa24395c2dd36eadf4b77fef91c03e0f
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-014864
Captured: 2026-04-28 06:52:27 UTC
SHA-256: fda3dc10dae1f5bf…
URL: https://conductatlas.com/platform/noom/noom-privacy-policy/provision/CA-P-014864/cross-border-data-transfer-to-united-states/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Noom's Cross-Border Data Transfer to United States clause do?

This provision establishes that sensitive health data, demographic data, and communications content collected from EEA, UK, and Swiss residents may be transferred to the United States under contractual transfer mechanisms, creating compliance obligations under GDPR Chapter V and requiring verification that transfer impact assessments and standard contractual clauses are current and adequate.

How does this clause affect you?

Under this provision, personal and sensitive data collected from users globally, including EEA, UK, and Swiss residents, may be stored and processed in the United States, which does not have a blanket European Commission adequacy determination for all data transfers. Noom states it uses contractual mechanisms to support these transfers, but the specific mechanism (such as standard contractual clauses) is …

Is ConductAtlas affiliated with Noom?

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