The policy states that Noom may update the privacy policy at any time, that continued use of the service after changes take effect constitutes agreement to the updated policy, and that more prominent notice or consent may be obtained for significant changes.
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 establishes that material changes to data processing practices may take effect through a notice-and-continued-use mechanism, without affirmative consent, except where Noom determines the changes are significant. Under GDPR, changes to processing purposes for special category data may require explicit consent regardless of this mechanism.
Interpretive note: Whether continued-use acceptance constitutes valid consent for changes to sensitive data processing purposes under GDPR depends on jurisdiction-specific analysis and may not be enforceable as drafted in EEA or UK contexts.
Under this provision, continued use of Noom's services after a policy update constitutes acceptance of the updated terms, including any new data collection or sharing practices described in the revised policy. The agreement reserves to Noom the discretion to determine when changes are 'significant' enough to warrant prominent notice or affirmative consent.
Cross-platform context
See how other platforms handle Policy Acceptance Through Continued Use and similar clauses.
Compare across platforms →"We may change this policy from time to time and if we do, we'll post any changes on this page. If you continue to use Noom after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide more prominent notice or obtain your consent to the changes.Excerpt from Noom's Privacy Policy
(1) REGULATORY LANDSCAPE: Unilateral policy modification with continued-use acceptance engages GDPR's requirements for lawful processing bases and consent validity, particularly where policy changes alter the purposes for which sensitive data is processed.
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This provision establishes that material changes to data processing practices may take effect through a notice-and-continued-use mechanism, without affirmative consent, except where Noom determines the changes are significant. Under GDPR, changes to processing purposes for special category data may require explicit consent regardless of this mechanism.
Under this provision, continued use of Noom's services after a policy update constitutes acceptance of the updated terms, including any new data collection or sharing practices described in the revised policy. The agreement reserves to Noom the discretion to determine when changes are 'significant' enough to warrant prominent notice or affirmative consent.
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