Provision record
Whoop · Whoop Terms of Use · View original document ↗

Health Data Collection and Use

High severity Medium confidence Inferred from context Common · 290 of 352 platforms
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Document Record

What it is

WHOOP collects continuous physiological measurements including heart rate, heart rate variability, respiratory rate, blood oxygen levels, skin temperature, sleep data, and activity data via the wearable device and app, which are used to generate personalized health insights.

This analysis describes what Whoop'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)

The agreement discloses collection of a range of physiological and biometric-adjacent data categories on a continuous basis; the handling of this data is governed primarily by the Privacy Policy rather than these Terms, and the Terms incorporate the Privacy Policy by reference without reproducing its data sharing or retention provisions here.

Interpretive note: The full text of WHOOP's health data collection and use disclosures is contained in the Privacy Policy rather than these Terms; the operational scope of data sharing and retention cannot be fully assessed from the Terms alone.

Clause Stability Stable

0
Changes
3
Months Monitored
May 20, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

modified Aug 5, 2026

Expanded list of collected data types to explicitly include 'respiratory rate' and 'blood oxygen levels' and 'skin temperature,' and added statement of purpose regarding personalized insights.

View full change record →

Consumer impact (what this means for users)

The agreement establishes that WHOOP collects heart rate, heart rate variability, respiratory rate, blood oxygen, skin temperature, sleep, and activity data continuously through the device and app. Data practices including sharing, retention, and user rights over this data are governed by the separately maintained Privacy Policy, which is incorporated by reference.

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.
  • Delete Your Data
    To request deletion of your personal or health data, contact WHOOP's privacy team by email and specify the data categories you wish to have deleted, referencing your account information.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
WHOOP collects physiological data including heart rate, heart rate variability, respiratory rate, blood oxygen levels, skin temperature, sleep data, and activity data through the WHOOP device and application. This data is used to provide personalized health and fitness insights and is subject to WHOOP's Privacy Policy.

Excerpt from Whoop's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: Collection of physiological data including heart rate variability, blood oxygen, and skin temperature may implicate state biometric privacy statutes including Illinois BIPA and Texas CUBI, depending on whether these measurements are characterized …

Insight

Unlock the full institutional analysis

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

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • 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

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Whoop Terms of Use
Entity
Whoop
Document last updated
May 5, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-012569
Document ID
CA-D-00739
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
5f29e9584b02ee1892d283283b7b7e2feeff5fcd158e60267b251c22ec840a80
Analysis generated
May 20, 2026 22:54 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Whoop
Document: Whoop Terms of Use
Record ID: CA-P-012569
Captured: 2026-05-20 22:54:47 UTC
SHA-256: 5f29e9584b02ee18…
URL: https://conductatlas.com/platform/whoop/whoop-terms-of-use/provision/CA-P-012569/health-data-collection-and-use/
Accessed: Aug. 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Whoop's Health Data Collection and Use clause do?

The agreement discloses collection of a range of physiological and biometric-adjacent data categories on a continuous basis; the handling of this data is governed primarily by the Privacy Policy rather than these Terms, and the Terms incorporate the Privacy Policy by reference without reproducing its data sharing or retention provisions here.

How does this clause affect you?

The agreement establishes that WHOOP collects heart rate, heart rate variability, respiratory rate, blood oxygen, skin temperature, sleep, and activity data continuously through the device and app. Data practices including sharing, retention, and user rights over this data are governed by the separately maintained Privacy Policy, which is incorporated by reference.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Whoop?

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