Noom · Noom Terms of Service · View original document ↗

User Content License

Medium severity High confidence Explicitdocumentlanguage Uncommon · 25 of 325 platforms
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Document Record

What it is

When you share content on Noom, such as posts, photos, or progress updates, you give Noom broad rights to use, adapt, and distribute that content across any media platform.

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 clause establishes Noom's operational rights to incorporate user-generated content into service delivery, product development, and distribution channels without requiring per-use compensation or individual authorization. The sublicensing right permits Noom to extend these usage rights to third parties, expanding the universe of parties with access to user content.

Recent Activity

This document changed recently

Medium Apr 19, 2026

Noom's updated terms make clearer that the platform provides behavioral support, not medical treatment, and that coaching and food data features may not be fully accurate. This clarification is important for users who might view Noom as a substitute for medical advice or treatment. The terms now explicitly reserve Noom's right to suspend or revoke your access at any time, which expands the company's unilateral control over your account. Review the updated terms carefully, especially if you rely on Noom for health management or have shared sensitive health information on the platform.

View change record →

Consumer impact (what this means for users)

Health-related content you share on Noom, including progress updates or community posts, may be used, adapted, and redistributed by Noom or its partners across various platforms under this license, potentially in contexts you did not anticipate.

How other platforms handle this

Peloton Medium

By submitting or posting User Content on or through the Services, you grant us a worldwide, non-exclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute such User Content in any and all media or distribu...

Calm Medium

By making any User Content available to Calm, you hereby grant to Calm a non-exclusive, transferable, sublicensable, worldwide, royalty-free, license to use, store, publish, translate, reproduce, adapt, copy, modify, create derivative works based upon, publicly display, publicly perform, and distrib...

Headspace Medium

By submitting User Material you hereby grant Headspace an irrevocable, perpetual, non-exclusive, royalty free, worldwide license to use, telecast, copy, perform, display, edit, distribute and otherwise exploit the User Material you post on the Products, or any portion thereof, and any ideas, concept...

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▸ View Original Clause Language DOCUMENT RECORD
"
By submitting, posting or displaying Content on or through the Services, you grant us a worldwide, non-exclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute such Content in any and all media or distribution methods now known or later developed.

— Excerpt from Noom's Noom Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The breadth of this content license engages FTC Act Section 5 if the actual uses of user content are not clearly disclosed during collection. For health-adjacent content, the license may also interact with applicable state privacy laws including the CCPA, particularly where user content constitutes personal information. The GDPR and UK GDPR require that processing of personal data, including user-generated content, have a lawful basis, and a broad contractual license may not independently satisfy that requirement for EU and UK users. GOVERNANCE EXPOSURE: Medium. While broad content licenses are common in consumer platforms, the health-adjacent nature of Noom's user content, which may include weight loss progress, food logs, and personal health disclosures, raises the sensitivity of the license's application. Sublicensing rights amplify potential distribution scope. JURISDICTION FLAGS: EU and UK users are protected by GDPR and UK GDPR data minimization and purpose limitation principles, which may constrain how broadly this license can be operationalized regardless of contractual assertion. California users retain rights under CCPA to know about and limit certain uses of their personal information. CONTRACT AND VENDOR IMPLICATIONS: The sublicensing right means user content could be passed to third-party partners without additional notice to users. Procurement teams and data protection officers should assess whether this license scope is reflected in Noom's data processing agreements and privacy notices. COMPLIANCE CONSIDERATIONS: Evaluate whether the content license scope is clearly disclosed at the point of content submission, and whether users have a meaningful mechanism to limit or retract their content. For EU and UK users, conduct a legal basis assessment for each category of content use under the license to ensure GDPR compliance.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices related to consumer data and content use that exceeds reasonable user expectations
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal

Provision details

Document information
Document
Noom Terms of Service
Entity
Noom
Document last updated
May 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 10, 2026
Record ID
CA-P-001837
Document ID
CA-D-00396
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
de01a3efcc4be9e8cb194056bfe5fceebf1b9c6feb473a060565313528073c29
Analysis generated
April 28, 2026 06:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Noom
Document: Noom Terms of Service
Record ID: CA-P-001837
Captured: 2026-04-28 06:48:11 UTC
SHA-256: de01a3efcc4be9e8…
URL: https://conductatlas.com/platform/noom/noom-terms-of-service/user-content-license/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Noom's User Content License clause do?

This clause establishes Noom's operational rights to incorporate user-generated content into service delivery, product development, and distribution channels without requiring per-use compensation or individual authorization. The sublicensing right permits Noom to extend these usage rights to third parties, expanding the universe of parties with access to user content.

How does this clause affect you?

Health-related content you share on Noom, including progress updates or community posts, may be used, adapted, and redistributed by Noom or its partners across various platforms under this license, potentially in contexts you did not anticipate.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 25 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.