What can I do about this clause?

{'method': 'EMAIL', 'recipient': 'privacy@noom.com', 'difficulty': 'EASY', 'action_type': 'OPT_OUT_ARBITRATION', 'instructions': "California residents can submit a 'Do Not Sell or Share My Personal Information' request by emailing privacy@noom.com. Include your account email and state that you are a California resident exercising your CPRA opt-out right.", 'deadline_days': None, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The FTC has direct enforcement authority over unfair and deceptive practices involving sharing of health data with advertising partners under FTC Act Section 5, with recent precedent from the BetterHelp action.', 'complaint_url': 'https://reportfraud.ftc.gov/'}, {'agency': 'State_AG', 'reason': 'State Attorneys General in California, Colorado, Connecticut, and other states with comprehensive privacy laws have enforcement authority over advertising data sharing practices and opt-out right violations.', 'complaint_url': 'https://www.naag.org/find-my-ag/'}

What is the severity of this clause?

ConductAtlas classifies this Third-Party Advertising and Analytics Data Sharing clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Do other platforms have similar clauses?

Yes. ConductAtlas has identified similar Third-Party Advertising and Analytics Data Sharing clauses across approximately 7 other tracked platforms. You can compare how platforms differ on this clause type in the cross-platform comparison view.

Third-Party Advertising and Analytics Data Sharing — Noom

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What it is

Noom shares your personal data, potentially including health information, with advertising companies to show you targeted ads both inside and outside the Noom app.

Consumer impact (what this means for users)

Your interactions with the Noom platform — including health goals, food logs, and behavioral patterns — may be shared with advertising partners who can use this data to target you with ads across other websites and apps.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.

Opt Out of Arbitration

California residents can submit a 'Do Not Sell or Share My Personal Information' request by emailing privacy@noom.com. Include your account email and state that you are a California resident exercising your CPRA opt-out right.

Cross-platform context

See how other platforms handle Third-Party Advertising and Analytics Data Sharing and similar clauses.

Compare across platforms →

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Why it matters (compliance & risk perspective)

Sharing health-related behavioral data with advertising networks means your wellness struggles, dietary habits, and health conditions could be used to profile and target you across the internet, far beyond the Noom platform.

View original clause language

We may share your information with third-party service providers who perform services on our behalf, including analytics, advertising, and marketing services. We may share or disclose your personal information with advertising partners to show you ads that may be of interest to you, both on and off our Services. We use cookies, pixels, and similar tracking technologies to collect information about your interactions with our Services and share this information with our advertising partners.

Institutional analysis (Compliance & legal intelligence)

1. REGULATORY FRAMEWORK: Third-party advertising data sharing implicates CCPA/CPRA §§1798.120-1798.121 (right to opt out of sale/sharing of personal information and sensitive personal information); GDPR Arts. 6(1)(a) and 7 (consent as legal basis for advertising processing must be freely given and withdrawable); ePrivacy Directive (cookie consent requirements for tracking technologies); FTC Act Section 5 (deceptive practices if advertising data use is not clearly disclosed). Enforcement authorities: CPPA, EU DPAs, FTC. 2.

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Applicable agencies

FTC

The FTC has direct enforcement authority over unfair and deceptive practices involving sharing of health data with advertising partners under FTC Act Section 5, with recent precedent from the BetterHelp action.
File a complaint →
State AG

State Attorneys General in California, Colorado, Connecticut, and other states with comprehensive privacy laws have enforcement authority over advertising data sharing practices and opt-out right violations.
File a complaint →

Provision details

Document information

Document

Noom Privacy Policy

Entity

Noom

Document last updated

April 29, 2026

Tracking information

First tracked

April 28, 2026

Last verified

April 28, 2026

Record ID

CA-P-003845

Document ID

CA-D-00397

Evidence Provenance

Source URL

https://www.noom.com/noom-privacy-policy/

Wayback Machine

View archived versions →

SHA-256

05252f553ca6864667d2e582f332534d7ecc993e8e01284deda5add6a0607bb0

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Noom | Document: Noom Privacy Policy | Record: CA-P-003845
Captured: 2026-04-28 06:52:27 UTC | SHA-256: 05252f553ca68646…
URL: https://conductatlas.com/platform/noom/noom-privacy-policy/third-party-advertising-and-analytics-data-sharing/
Accessed: May 2, 2026

Classification

Severity

High

Third-Party Advertising and Analytics Data Sharing