This Washington Consumer Health Data Privacy Policy, effective December 13, 2024, is a supplement to MyFitnessPal's Privacy Policy. It applies only to Washington consumers who deal with MyFitnessPal as an individual or for their household, and only to personal information that counts as “consumer health data” under the Washington My Health My Data Act. Terms it does not define take the meaning they have in the Privacy Policy. It says it describes what consumer health data MyFitnessPal collects, how it collects and uses it, who it discloses it to and why, and the choices you may have.
Supporting quotations
Washington Consumer Health Data Privacy Policy
Effective Date: December 13, 2024
This Washington Consumer Health Data Privacy Policy (“Policy”) supplements the information in the MyFitnessPal
. It applies solely to Washington consumers who interact with us in an individual or household capacity and applies only to personal information defined as “consumer health data” under the Washington My Health My Data Act.
Capitalized terms that are not defined here have the same meaning as in the MyFitnessPal Privacy Policy.
This Policy describes what consumer health data we collect, how we collect and use it, who we disclose it to and why, and the choices you may have regarding our use or disclosure of your consumer health data.
Qualifications & exceptions
Applies solely to Washington consumers who interact with MyFitnessPal in an individual or household capacity
Applies only to personal information defined as consumer health data under the Washington My Health My Data Act
Not stated here
The MyFitnessPal Privacy Policy is linked but was not supplied, so terms this document leaves undefined (for example “Services”) cannot be read from it.
How this supplement and the Privacy Policy interact where they differ is not stated in this document.
Cross-references
qualifies (model-proposed): Your Washington consumer health data rights — qualifies: The policy's scope (Washington consumers acting individually or for a household, and only consumer health data under the Washington My Health My Data Act) limits who the listed rights are for.
Data Access & Collection · Company practice
Health information from your account and surveys
MyFitnessPal says it may collect or receive health and wellness information you submit as part of your account. It also says it may collect survey and questionnaire responses if you choose to take part in its research. Those responses can include demographics and health details such as conditions, diagnoses and medications, but only if you choose to share them.
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Categories of Consumer Health Data We Collect
We may collect or receive the categories of consumer health data listed below.
Health and wellness information submitted as part of your account or;
Survey and questionnaire responses you submit (if you choose to participate with our research), including, but not limited to information about your demographics and health (such as conditions, diagnoses, medications, or other similar information), if you choose to share such information
Qualifications & exceptions
“May collect or receive”: the list names categories that may be collected, not a statement that each is collected from every user
Survey responses are collected only if you choose to participate in research
Health details in surveys are covered only if you choose to share them
The survey list is introduced with “including, but not limited to”, so it is not exhaustive
Not stated here
The first item ends with “or;” and the saved text shows no heading naming the group these first two items belong to, so the grouping is not clear.
The policy does not define what counts as health and wellness information submitted as part of your account.
Data Access & Collection · Company practice
Fitness and wellness data
Under the heading “Fitness and Wellness Data”, MyFitnessPal lists dietary habits and restrictions; fitness activity, goals and level; lifestyle information such as sleep habits and life events; and body measurements such as height and weight, Body Mass Index, calorie count, heart rate and other measurements related to physiological condition. These are categories it may collect or receive.
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Categories of Consumer Health Data We Collect
We may collect or receive the categories of consumer health data listed below.
Fitness and Wellness Data:
Dietary habits and dietary restrictions;
Fitness activity, fitness goals, and fitness level;
Lifestyle information, such as sleep habits and life events;
Body measurements (e.g., height and weight), Body Mass Index, calorie count, heart rate, and other measurements related to physiological condition;
Qualifications & exceptions
“May collect or receive”: a list of possible categories, not a statement that every item is collected from every user
Several items are examples (“such as”, “e.g.”) and “other measurements related to physiological condition” is open-ended
Not stated here
This part of the list does not say whether each item is typed in by you, taken from a connected device or inferred; the sources are listed separately in section 2.
Data Access & Collection · Company practice
Health data from connected apps and wearables
If you connect third-party applications or wearable devices to your MyFitnessPal account, the health data they provide is also covered. The policy calls this “Connected Health Device Data” and says it is subject to the permissions you set on those apps and devices. The examples listed are heart rate and physical activity; the types and length of physical activity; sleep activity and trends; glucose information; and other activity information collected from a connected wearable or app or reported by you.
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Categories of Consumer Health Data We Collect
We may collect or receive the categories of consumer health data listed below.
Health data from third-party applications and wearable devices that you may connect with your MyFitnessPal account and subject to the permissions you may set on those third-party applications and wearable devices ("Connected Health Device Data"), including, without limitation:
Heart rate, and physical activity information;
Information about the types of physical activities you engage in, and the duration of your physical activity;
Sleep activity information and sleep trends;
Glucose information;
Other Information about your activity as may be collected from your wearable device and applications (if connected) or self reported;
Qualifications & exceptions
Covers health data from third-party applications and wearables that you connect to your MyFitnessPal account
Subject to the permissions you may set on those third-party applications and wearable devices
“Including, without limitation”: the examples are not an exhaustive list
Not stated here
The policy does not explain how the permissions you set on a third-party app or device determine what MyFitnessPal receives.
The last item says activity information “may be collected from your wearable device and applications (if connected) or self reported” without saying more about the self-reported part.
Data Access & Collection · Company practice
Profile information that includes health data
MyFitnessPal lists profile information that includes health data as a category it may collect: for example demographic information, age, gender, and an image or photo from your MyFitnessPal account profile.
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Profile Information that includes health data: such as demographic information, age, gender, image or photo, etc. from your MyFitnessPal account profile
Qualifications & exceptions
The profile items are examples (“such as”, “etc.”), not a complete list
Not stated here
The policy does not say which profile fields it treats as health data.
Data Access & Collection · Company practice
Other similar information it may request
The list of categories ends with a catch-all: MyFitnessPal may also collect other similar information that it requests and that is specific to the products or Services you use.
Supporting quotations
Other similar information, as may be requested by us that is specific to the relevant products or Services you engage with.
Qualifications & exceptions
Limited to similar information, as requested by MyFitnessPal, specific to the relevant products or Services you engage with
Not stated here
The policy does not say what counts as “similar information”, so the list of categories is open-ended.
Data Access & Collection · Company practice
Where it collects health data: you, your devices and your use
For consumer health data, MyFitnessPal lists three sources tied to you: information you provide directly; information collected from a device associated with you or from a third-party application you authorized to share information with it; and information collected from your interactions with its apps, Services and platforms. It says its sources are also described in the “Information We Collect About You” section of the MyFitnessPal Privacy Policy.
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Categories of Sources From Which We Collect Consumer Health Data
We may obtain consumer health data from different sources, as described in the Information We Collect About You section of the MyFitnessPal Privacy Policy. With respect to consumer health data, we collect that from the following sources:
Provided directly by you;
Collected from a device associated with you or a third-party application you have authorized to share information with us;
Collected from your interactions with our apps, Services, platforms, etc.;
Qualifications & exceptions
The device and third-party application source applies to apps you have authorized to share information
“May obtain”: a statement of possible sources
Not stated here
The Privacy Policy section it points to was not supplied, so the fuller description of sources is not available here.
The policy does not describe which interactions with its apps and platforms produce consumer health data (the line ends with “etc.”).
Data Access & Collection · Company practice
Health data received from third parties
MyFitnessPal also lists third parties as a source of consumer health data. It names other MyFitnessPal users, business partners, customers, marketing and advertising partners, analytics providers, operating systems, social media platforms, public databases and service providers.
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Categories of Sources From Which We Collect Consumer Health Data
Received from third parties such as other MyFitnessPal users, business partners, customers, marketing and advertising partners, analytics providers, operating systems, social media platforms, public databases, and service providers.
Qualifications & exceptions
“Such as”: the list of third parties is not exhaustive
Not stated here
The policy does not say which kinds of consumer health data each of these third parties would provide, or on what basis they share it.
Use & Processing · Company practice
Providing and developing its products and Services
MyFitnessPal says it may collect and use consumer health data to provide, administer, personalize, manage, develop, improve, repair and maintain its products and Services.
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Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Provide, administer, personalize, manage, develop, improve, repair, and maintain our products and Services;
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
Not stated here
The policy does not say how consumer health data is used for product development or improvement.
Use & Processing · Company practice
Communicating with you
MyFitnessPal says it may use consumer health data to communicate with you: to respond to your questions and requests, to ask for feedback, and to send administrative information about your account, such as information about the products and Services you use and changes to its terms, conditions and policies.
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Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Communicate with you, including to respond to your questions and requests, to request feedback from you, and to send you administrative information about your account such as information regarding the products and Services you use and the changes to our terms, conditions, and policies.
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
“Including” introduces examples; the purpose is not limited to those listed
Use & Processing · Company practice
Surveys, research and analytics
MyFitnessPal says it may use consumer health data to ask you to complete surveys and questionnaires, to understand how MyFitnessPal users access and use the Services, and for other research and analytics purposes.
Supporting quotations
Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Ask you to complete surveys and questionnaires and help us better understand how MyFitnessPal users access and use the Services and for other research and analytics purposes;
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
“Other research and analytics purposes” is open-ended
Not stated here
The policy does not say which other research or analytics purposes this covers.
Linking & Identification · Company practice
Combining health data with other information
MyFitnessPal says it may combine consumer health data with other information about you or the MyFitnessPal community, including information from third-party applications and services. Separately, it says profile information that includes health data may be combined with any personal information or other data it has collected.
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Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Combine the information collected, including from third-party applications and services, with other information about you or the MyFitnessPal community;
which we may combine with any personal information or other data we have collected
Qualifications & exceptions
Introduced as purposes for which MyFitnessPal “may” collect and use consumer health data
The profile combination statement refers to “any personal information or other data we have collected”, which has no stated limit
Not stated here
The policy does not say what the combined information is then used for beyond the purposes listed.
Cross-references
related (model-proposed): Profile information that includes health data — references: The profile category repeats, in the collection list, the statement that profile information with health data may be combined with other data.
Use & Processing · Company practice
Uses when it has your consent
One of the listed purposes is use of consumer health data when MyFitnessPal has your consent, such as through your participation in a study, research or another program.
Supporting quotations
Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
When we have your consent, such as pursuant to your participation in a study, research, or other program;
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
Applies when MyFitnessPal has your consent, for example through participation in a study, research or other program
Not stated here
The policy does not say what uses this consent covers, or whether other listed purposes also depend on consent.
Use & Processing · Company practice
De-identifying, aggregating and creating datasets
MyFitnessPal says it may de-identify, tokenize or aggregate your information, or otherwise make it so you are not reasonably identifiable, and may create or derive datasets. It says this is as part of the Services and for other purposes consistent with the purposes for which the information was collected and with MyFitnessPal's mission.
Supporting quotations
Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
De-identify, tokenize, or aggregate your information (or otherwise render the information so you are not reasonably identifiable), or to create or derive datasets, as part of the Services and for other purposes consistent with the purposes for which the information was collected and MyFitnessPal’s mission;
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
Other purposes must be consistent with the purposes for which the information was collected and with MyFitnessPal's mission
Not stated here
The policy does not say what is done with de-identified, tokenized or aggregated data or the datasets it creates, or who may receive them.
“MyFitnessPal's mission” is not defined in this document.
Use & Processing · Company practice
Personalizing, advertising and marketing
MyFitnessPal says it may use consumer health data to personalize, advertise and market its products and services to you, including the Services.
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Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Personalize, advertise, and market our products and services to you, including the Services;
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
As written, the advertising and marketing is of MyFitnessPal's own products and services, directed to you
Not stated here
The policy does not describe which consumer health data is used for personalization or advertising.
Cross-references
related (model-proposed): Who consumer health data may be shared with — references: The advertising and marketing purpose is read alongside the statement that consumer health data may be shared with business partners providing advertising and technology services.
Inference & Profiling · Company practice
Generating inferences about you
MyFitnessPal says it may use consumer health data to generate inferences about you, such as your interests or preferences.
Supporting quotations
Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Generate inferences about you, such as your interests or preferences; and
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
“Such as”: interests and preferences are examples
Not stated here
The policy does not say whether inferences are drawn about health and how they are used or kept.
Legal Rights & Agreement Rules · Company practice
Legal obligations and internal policies
MyFitnessPal says it may use consumer health data to comply with its legal obligations and its internal policies.
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Purposes for Collecting Your Consumer Health Data
We may collect and use consumer health data for one or more of the following purposes:
Comply with our legal obligations and internal policies.
Qualifications & exceptions
Purposes are introduced as ones for which MyFitnessPal “may” collect and use consumer health data, “one or more of the following”; the policy does not say every purpose applies to every user or every item of data
The purpose covers MyFitnessPal's own internal policies as well as legal obligations
Sharing & Disclosure · Company practice
Sharing any category of health data, including with your consent
MyFitnessPal says it may share each of the categories of consumer health data described in the policy. It adds, in particular, that it may share personal data, including consumer health data, with your consent to complete transactions or provide products or services you have requested, and for the purposes described in the policy.
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We may share each of the categories of consumer health data described above. In particular, we may share personal data, including consumer health data, with your consent, to complete transactions or provide products or services you have requested, and for the purposes described in this Policy.
Qualifications & exceptions
“May share”: permission to share, not a statement that all categories are shared with everyone
Names consent for sharing to complete transactions or provide products or services you have requested
Not stated here
The sentence does not make clear whether “with your consent” also applies to sharing “for the purposes described in this Policy”.
The policy does not say whether sharing described elsewhere in this section requires your consent.
Sharing & Disclosure · Company practice
Who consumer health data may be shared with
MyFitnessPal says it may share consumer health data with business partners, such as those providing advertising and technology services; with governmental agencies and legal bodies; and with purchasers of or successors to its business or assets.
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Categories of Third Parties with Whom Consumer Health Data is Shared
We may share consumer health data with business partners such as those providing advertising and technology services, governmental agencies and legal bodies, and purchasers of or successors to our business or assets.
Qualifications & exceptions
“Such as”: advertising and technology service providers are examples of business partners, not a complete list
“May share”: permission to share, not a statement that every recipient receives data
Not stated here
The policy does not name particular recipients or say whether any of this sharing is a sale of consumer health data.
The policy does not say whether sharing with these recipients depends on your consent, or what applies to government requests or a business transfer.
Cross-references
related (model-proposed): Sharing any category of health data, including with your consent — references: The recipients list sits under the same sharing section as the general statement about sharing the described categories and sharing with consent; the recipients sentence does not repeat the consent wording.
Account & Service Control · User right or choice
Your Washington consumer health data rights
Washington residents have the right to (1) request access to their consumer health data; (2) confirm whether MyFitnessPal has disclosed or sold their consumer health data; (3) delete their consumer health data; or (4) withdraw their consent or authorization relating to such data. You make these requests through MyFitnessPal's online form. The policy applies only to Washington consumers acting in an individual or household capacity and to personal information that is consumer health data under the Washington My Health My Data Act.
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Your Washington Consumer Health Data Rights
Washington residents have the right to (1) request access to their consumer health data; (2) confirm whether we have disclosed or sold their consumer health data; (3) delete their consumer health data; or (4) withdraw their consent or authorization relating to such data.
You can make these requests through our online form.
applies only to personal information defined as “consumer health data” under the Washington My Health My Data Act
Qualifications & exceptions
Rights are stated for Washington residents and relate to consumer health data
The policy as a whole applies solely to Washington consumers who interact with MyFitnessPal in an individual or household capacity
Requests are made through the online form
Not stated here
This section does not state a response deadline, identity verification steps, or any limits or exceptions to these rights.
It does not say what withdrawing consent changes for data already collected.
Account & Service Control · Procedure
How to appeal a decision on a rights request
To appeal MyFitnessPal's decision on your Washington Consumer Health Data Rights request, you contact it using the contact information listed below or by emailing support@myfitnesspal.com. When you appeal, you should enclose a copy of, or specifically reference, its decision on your request so it can review and address the appeal. It says it will respond in accordance with applicable law.
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How To Submit an Appeal
To appeal our decision on your Washington Consumer Health Data Rights request, you may contact us by using the contact information listed below or emailing us at support@myfitnesspal.com. In submitting your appeal, please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately review and address it. We will respond in accordance with applicable law.
Qualifications & exceptions
The appeal concerns a decision on a Washington Consumer Health Data Rights request
The appeal should enclose or specifically reference the decision on the request
The response is promised only “in accordance with applicable law”
Not stated here
The policy does not state a response deadline or what happens if the appeal is denied.
The only contact information listed below in this document is a postal address; the email address appears only in this section.
Cross-references
related (model-proposed): Your Washington consumer health data rights — references: The appeal procedure applies to a decision on a request made under the Washington Consumer Health Data Rights.
Legal Rights & Agreement Rules · Procedure
Contact details for questions and complaints
For questions, complaints or inquiries about this policy or MyFitnessPal's privacy practices, the policy gives a postal address: MyFitnessPal, ATTN: Privacy/Legal, 100 Congress Avenue, Suite 400, Austin, TX 78701.
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Contact Us
For any questions, complaints, or inquiries regarding this Policy, or our privacy practices, please contact us at:
MyFitnessPal
ATTN: Privacy/Legal
100 Congress Avenue, Suite 400
Austin, TX 78701
Not stated here
This section lists a postal address only; no email address or form is listed here.