WHOOP says it processes and uses Personal Data for service delivery, including to provide, operate, improve, develop, understand and personalize the Services and its business (including testing, research, analysis and product development); satisfy the reason you gave the information (delivering the Services and responding to requests); communicate with you about the Services, including announcements, updates or offers; provide support; create and manage accounts or profiles; customize website content and communications based on your preferences; and process orders, memberships or other transactions. "Including" and the broad verbs mean the list is not a narrow limit on what the Services and the business cover.
Supporting quotations
We process and use Personal Data for the following purposes:
Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis, and product development;
Satisfy the reason you provided the information to us, including for delivery of the Services and responding to and fulfilling requests;
Communicate with you about the Services, including Service announcements, updates, or offers;
Provide support and assistance for the Services;
Create and manage your account or other user profiles;
Customize website content and communications based on your preferences; and
Process orders, memberships, or other transactions.
Qualifications & exceptions
The first item covers improving and developing the Services and WHOOP's business, including research and product development.
Communications about the Services can include offers.
Use & Processing · Company practice
Research and development uses aggregated or de-identified data
WHOOP says it may create and use aggregated or de-identified data from the Personal Data it collects, for business improvement: analyzing the effectiveness of the Services, improving and adding features, and analyzing the general behavior and characteristics of users. It also says it uses de-identified wellness data for research purposes to help WHOOP and its research partners answer questions about human performance and to identify insights and provide new content and product features. The research use is described for de-identified wellness data, not identifiable data.
Supporting quotations
We may create and use aggregated data or de-identified Data from Personal Data we collect, for business improvement purposes
We also use de-identified wellness data for research purposes to help us and our research partners answer important questions about human performance
Qualifications & exceptions
The research use is stated for de-identified wellness data, shared with research partners as a purpose.
"De-identified" is not defined in this paragraph.
Not stated here
What de-identification method is used, and who the research partners are, is not stated here.
Use & Processing · Company practice
Direct marketing and advertising, with consent where required for consumer health data
WHOOP says it may use data from the Personal Data it collects, and certain data collected when you browse its website, to send you direct offers or other marketing messages or to advertise the Services or other WHOOP product offerings. A qualification elsewhere in the policy says WHOOP will obtain consent where required by applicable law before using consumer health data for marketing or promotional purposes, and that you can opt out of that use at any time.
Supporting quotations
We may use data from the Personal Data we collect and certain data collected when you browse our website, to send you direct offers or other marketing messages or to advertise the Services or other WHOOP product offerings.
We will obtain consent where required by applicable law before using consumer health data for marketing or promotional purposes. You can opt out of this use at any time.
Qualifications & exceptions
The consumer health data qualification applies to consumer health data and only "where required by applicable law."
Use & Processing · Company practice
WHOOP Coach is a generative AI feature that uses your WHOOP metrics
WHOOP Coach is described as a generative AI feature intended to help you set goals and make progress, understand WHOOP concepts, provide educational guidance and integrate with the rest of your WHOOP experience. It combines your WHOOP metrics, such as strain, recovery or sleep scores, with the science of WHOOP. It uses third-party AI technology from WHOOP's LLM partner; responses are based on your prompts and relevant information collected through your WHOOP metrics. WHOOP gives an example in which a sleep question is answered with tips based on your de-identified sleep data.
Supporting quotations
WHOOP Coach is a generative AI feature that is intended to help you set and make progress toward your goals, understand WHOOP concepts, provide educational guidance, and integrate with the rest of your WHOOP experience.
WHOOP Coach creates a coaching experience by combining your WHOOP metrics, such as your strain, recovery, or sleep scores, with the science of WHOOP
Please note that WHOOP Coach leverages third-party AI technology provided by our LLM partner. Responses from WHOOP Coach are based on your prompts and relevant information collected through your WHOOP metrics.
Qualifications & exceptions
Responses use your prompts and relevant information from your WHOOP metrics.
The example describes the sleep data used as de-identified.
Not stated here
The LLM partner is not named in this section.
Use & Processing · Company practice
WHOOP employee access and support requests from WHOOP Coach
WHOOP says that, consistent with its Privacy Principles, its employees will only access your Personal Data when required to provide services and support. This may include collecting information about your experience with WHOOP Coach, and (in the Membership Services AI paragraph) your experience with Membership Services, to assess performance and improve those features and other product offerings. If WHOOP Coach suggests connecting to Membership Services, you can opt in to have your support request automatically filed with the team, and the support team will then only have access to that specific conversation.
Supporting quotations
WHOOP employees will only access your Personal Data when required to provide services and support. This may include collecting information about your experience with WHOOP Coach to assess the performance of and improve WHOOP Coach and other product offerings.
you can opt in to have your support request automatically filed with our team. In this case, our support team will only have access to that specific conversation to provide you with the best support.
WHOOP employees will only access member Personal Data when required to provide services and support, which may include collecting information about your experience with Membership Services to assess the performance of and improve Membership Services AI and other product offerings.
Qualifications & exceptions
Employee access is stated as limited to when it is "required to provide services and support," but that purpose is defined to include assessing and improving the AI features and other product offerings.
Automatic filing of a support request is something you opt in to, and access is limited to that conversation.
Not stated here
The Privacy Principles are a separate document and are not supplied here.
Use & Processing · Company practice
Membership Services AI answers using your prompts and membership information
WHOOP Membership Services includes a generative AI feature intended to help you get member support. It uses third-party AI technology from WHOOP's LLM partner. Responses are based on your prompts and relevant information collected through your WHOOP membership; for example, a question about your order will draw on your purchase records.
Supporting quotations
WHOOP Membership Service includes a generative AI feature that is intended to assist you in receiving member support.
Membership Services uses third-party AI technology provided by our LLM partner. Responses from Membership Services are based on your prompts and relevant information collected through your WHOOP membership.
if you ask Membership Services a question regarding your order, Membership Services will draw on your purchase records.
Qualifications & exceptions
Responses use "relevant information collected through your WHOOP membership," including purchase records for order questions.
Not stated here
The text does not say whether purchase records or other membership information are sent to the LLM partner, or only the de-identified WHOOP metrics described in the next paragraph.
Use & Processing · User right or choice
Personalization settings control use of health data for personalization
You can control how your health data is used to personalize your WHOOP experience in the WHOOP app's Privacy Settings. Depending on your location, WHOOP may ask for your permission before using certain types of data for personalization. You can update your preference at any time. If you turn the setting off, WHOOP says it will no longer use your health data to personalize recommendations, offers or similar features within WHOOP, which may affect certain features of the Services.
Supporting quotations
You can control how your health data is used to personalize your WHOOP experience in the WHOOP app in Privacy Settings.
Depending on your location, we may ask for your permission before using certain types of data for personalization.
If you turn this setting off, we will no longer use your health data to personalize recommendations, offers, or similar features within WHOOP, which may affect certain features of the Services.
Qualifications & exceptions
Permission requests depend on your location.
Turning the setting off may affect certain features of the Services.
Not stated here
Which locations trigger a permission request, and which data types, are not specified here.
Use & Processing · User right or choice
California right to limit use and disclosure of sensitive personal information
California residents have the right to limit WHOOP's use and disclosure of their sensitive personal information to uses that are necessary to provide the Services or goods they request, or as otherwise permitted by law. WHOOP says sensitive personal information may include consumer health data, biometric information, precise geolocation and other information defined as sensitive under California law.
Supporting quotations
California Right to Limit Use and Disclosure of Sensitive Personal Information.
If you are a California resident, you have the right to limit our use and disclosure of your sensitive personal information to those uses that are necessary to provide the Services or goods you request, or as otherwise permitted by law.
Sensitive personal information may include consumer health data, biometric information, precise geolocation, and other information defined as sensitive under California law.
Qualifications & exceptions
The limit allows uses necessary to provide requested Services or goods, "or as otherwise permitted by law."
The list of sensitive information is introduced with "may include."
Use & Processing · Company practice
How WHOOP uses sensitive personal information and how to limit personalization
WHOOP says it uses sensitive personal information primarily to provide and improve the Services, including delivering health metrics, insights and features you request. If it uses sensitive personal information for additional purposes, such as certain personalization or promotional features, you may have the right to limit that use. WHOOP says it does not share sensitive personal information with third parties for their own advertising or marketing purposes. You can control how sensitive personal information is used for personalization in Privacy Settings in the WHOOP app; if you choose to limit it, WHOOP says it will stop using it to personalize recommendations, offers or similar features, which may affect certain personalized features.
Supporting quotations
We use sensitive personal information primarily to provide and improve the Services, including delivering health metrics, insights, and features you request.
If we use sensitive personal information for additional purposes, such as certain personalization or promotional features within WHOOP, you may have the right to limit that use.
We do not share your sensitive personal information with third parties for their own advertising or marketing purposes.
You can control how your sensitive personal information is used for personalization by visiting Privacy Settings in the WHOOP app. If you choose to limit this use, we will stop using your sensitive personal information to personalize recommendations, offers, or similar features within WHOOP.
Qualifications & exceptions
"Primarily" means other uses are possible, such as certain personalization or promotional features, which you may be able to limit.
The statement on not sharing for third-party advertising is about sensitive personal information.
Use & Processing · Company practice
Personal Data is processed in the United States
To provide the Services, WHOOP says it will process Personal Data in the United States, where WHOOP is based. To the extent it transfers a European resident's Personal Data to the United States, it says it will do so in accordance with European data protection laws.
Supporting quotations
To provide the Services, we will process your Personal Data in the United States, where WHOOP is based.
To the extent we transfer your Personal Data to the United States, we will do so in accordance with European data protections laws.
Qualifications & exceptions
The commitment on transfers is that they will follow European data protection laws.
Use & Processing · User right or choice
Brazil: explicit consent for special-category wellness data and withdrawal
To the extent wellness data WHOOP collects is considered consumer health data or another special category of Personal Data, WHOOP says it asks for your explicit consent to process it. You can use account settings and tools to withdraw consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing WHOOP's access to a third-party service, or deleting your data or account. In some cases, such as when you direct WHOOP to share it, processing is based on consent you expressly grant at the time of collection, which you can withdraw at any time in the manner indicated then or listed in the Services.
Supporting quotations
To the extent that wellness data that we collect is considered consumer health data or another special category of Personal Data, we ask for your explicit consent to process this data.
You can use your account settings and tools to withdraw your consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing our access to a Third-Party service, or deleting your data or your account.
Qualifications & exceptions
Explicit consent applies "to the extent" wellness data is consumer health data or another special category.
Use & Processing · User right or choice
Israel: consent for marketing communications; service emails are not marketing
In the Israel notice, WHOOP says it will request your consent to send marketing materials and will give you the ability to opt out of marketing emails and other communications through the Data Management feature in the Privacy Center or by following the unsubscribe instructions in the message. Emails related to the Services you are provided are treated as Service Related Communications, not marketing communications, and are not subject to this section.
Supporting quotations
We will request your consent to send you marketing materials.
We will also give you the ability to opt-out of marketing-related emails and other communications by going to our “Data Management” feature available in the WHOOP Privacy Center privacy.whoop.com, or by following the opt-out or unsubscribe instructions contained in the marketing-related message.
emails related to the Services you are provided with by WHOOP will not be considered as Marketing Communications but as Service Related Communications, and therefore shall not be subject to this section
Qualifications & exceptions
Service Related Communications are outside the marketing opt-out in this section.
Not stated here
Which emails count as Service Related Communications is not specified.
Use & Processing · User right or choice
Japan: explicit consent for special-care wellness data and withdrawal
In the Japan notice, to the extent wellness data WHOOP collects is considered Special Care-Required Personal Information (as defined in what the text calls the "APPT"), WHOOP says it asks for your explicit consent to process it. You can use account settings and tools to withdraw consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing WHOOP's access to a third-party service, or deleting your data or account. In some cases, such as when you direct WHOOP to share data, it processes Personal Data on consent you expressly grant when collected, and you can withdraw that consent at any time in the manner indicated or listed in the Services.
Supporting quotations
To the extent that wellness data that we collect is considered Special Care-Required Personal Information (as defined in the APPT), we ask for your explicit consent to process this data.
You can use your account settings and tools to withdraw your consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing our access to a Third-Party service, or deleting your data or your account.
When we process Personal Data based on your consent, you have the right to withdraw it any time in the manner indicated at the time you give consent or as listed in our Services.
Qualifications & exceptions
Explicit consent applies "to the extent" wellness data is considered Special Care-Required Personal Information.
The text refers to the "APPT," while the notice elsewhere names the APPI; the saved text says APPT.
Use & Processing · User right or choice
Singapore: marketing with consent, Do Not Call Registry and opt-out
In the Singapore notice, with your consent WHOOP may use Personal Data and certain data collected when you browse its website to send direct offers or marketing messages or advertise its Services and products. If you have registered your telephone number with the National Do Not Call (DNC) Registry, WHOOP says it will not send such marketing messages by phone calls and text messages, unless you previously gave consent to be contacted for those purposes and have not withdrawn it. You can withdraw consent and opt out of marketing emails and other communications through Data Management in the Privacy Center or the unsubscribe instructions; after opting out you may still receive certain non-marketing emails and text messages about the Services as permitted by applicable laws.
Supporting quotations
With your consent, we may use the Personal Data we collect and certain data collected when you browse our website, to send you direct offers, marketing messages or advertise the Services or other WHOOP product offerings.
If you have registered your telephone number with the National Do Not Call (DNC) Registry, we will not send you such marketing messages via phone calls and text messages, unless you have previously given us consent to contact you for such purposes and such consent has not been withdrawn.
We give you the ability to withdraw your consent and opt-out of marketing-related emails and other communications by going to our “Data Management” feature available in the WHOOP Privacy Center privacy.whoop.com, or by following the opt-out or unsubscribe instructions contained in the marketing-related message.
After opting-out, you may still receive certain non-marketing emails and text messages regarding the Services as permitted under applicable laws and regulations.
Qualifications & exceptions
The DNC commitment does not apply if you previously consented to be contacted and have not withdrawn consent.
Opting out does not stop certain non-marketing emails and texts about the Services.
Use & Processing · User right or choice
South Africa: marketing with consent and opt-out
In the South Africa notice, with your consent WHOOP may use data from your Personal Data and certain data collected when you browse its website to send direct offers or marketing messages or advertise its Services and products. You can withdraw consent and opt out of marketing emails and other communications through Data Management in the Privacy Center or the unsubscribe instructions in the message, but you cannot opt out of certain non-marketing emails regarding the Services.
Supporting quotations
With your consent, we may use data from the Personal Data we collectand certain data collected when you browse our website, to send you direct offers, marketing messages or advertise the Services or other WHOOP product offerings.
We give you the ability to withdraw your consent and opt-out of marketing-related emails and other communications by going to our “Data Management” feature available in the WHOOP Privacy Center privacy.whoop.com, or by following the opt-out or unsubscribe instructions contained in the marketing-related message.
You cannot opt-out of receiving certain non-marketing emails regarding the Services.
Qualifications & exceptions
Certain non-marketing emails regarding the Services cannot be opted out of.
Use & Processing · User right or choice
Explicit consent for special-category wellness data, and withdrawing consent
To the extent wellness data WHOOP collects is considered consumer health data or another special category of Personal Data subject to the GDPR, WHOOP says it will ask for your explicit consent to process it. You can use account settings and tools to withdraw consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing WHOOP's access to a third-party service, or deleting your data or your account. In some cases, such as when you direct WHOOP to share data, processing is based on consent you expressly give at the time of collection, and you have the right to withdraw it at any time in the manner indicated then or listed in the Services.
Supporting quotations
To the extent that wellness data that we collect is considered consumer health data or another special category of Personal Data subject to the GDPR, we will ask for your explicit consent to process this data.
You can use your account settings and tools to withdraw your consent at any time, including by unpairing your WHOOP Strap, stopping use of a feature, removing our access to a Third-Party service, or deleting your data or your account.
When we process Personal Data based on your consent, you have the right to withdraw it any time in the manner indicated at the time you give consent or in as listed in our Services.
Qualifications & exceptions
Explicit consent applies "to the extent" wellness data is consumer health data or another special category under the GDPR.
Use & Processing · Company practice
Use for other purposes where compatible; notice for unrelated purposes
WHOOP says it may use Personal Data for reasons not described in the policy where permitted by law and where the reason is compatible with the purpose for which it was collected. If WHOOP needs to use Personal Data for an unrelated purpose, it says it will notify you and explain the applicable legal basis.
Supporting quotations
We may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it.
If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.
Qualifications & exceptions
Compatible new uses are allowed "where permitted by law"; unrelated purposes trigger notice and an explanation of the legal basis.
Not stated here
The text does not say how WHOOP decides a purpose is "compatible."
Use & Processing · Company practice
WHOOP states it makes solely automated decisions with legal or similarly significant effects
Under "Solely automated decision-making," WHOOP says it does make decisions based solely on automated processing involving personal data, including profiling, which produce legal effects or similarly significantly affect you, including in connection with the personal data processing activities described in Section 8 (the WHOOP Coach, Membership Services AI and third-party AI technology section). The text does not say what decisions are made or what they affect.
Supporting quotations
We do make decisions based solely on automated processing involving personal data, including profiling, which produce legal effects or similarly significantly affects you, including in connection with the personal data processing activities described under Section 8 above.
Qualifications & exceptions
The statement is made in the European notice and refers to Section 8, the AI section.
Not stated here
Which decisions are made, what legal or similarly significant effects they have, and what safeguards or rights apply are not stated in this paragraph.
Use & Processing · Company commitment
Consumer health data: not sold, used for the Services, consent where required
Consumer health data is described as including, but not limited to, biomarkers, lab samples, lab results, clinical notes and other health metrics, with a pointer to the separate Consumer Health Data Privacy Notice. WHOOP says it does not sell consumer health data to third parties and may use it to provide the Services (delivering results, insights, recommendations and related features). Personalization based on health data is said to occur within WHOOP and not be used for third-party advertising. WHOOP will obtain consent where required by applicable law before using consumer health data for marketing or promotional purposes, and you can opt out of that use at any time. Elsewhere, the policy lists wellness data as a separate category and says that only to the extent wellness data is considered consumer health data or another special category does WHOOP ask for explicit consent to process it. A separate paragraph says WHOOP does not share sensitive personal information with third parties for their own advertising or marketing.
Supporting quotations
Consumer health data, including but not limited to biomarkers, lab samples, lab results, clinical notes, other health metrics.
We do not sell your consumer health data to third parties.
Any personalization based on your health data occurs within WHOOP and is not used for third-party advertising.
We will obtain consent where required by applicable law before using consumer health data for marketing or promotional purposes. You can opt out of this use at any time.
To the extent that wellness data that we collect is considered consumer health data or another special category of Personal Data, we ask for your explicit consent to process this data.
We do not share your sensitive personal information with third parties for their own advertising or marketing purposes.
Wellness data, including but not limited to physiological metrics
Qualifications & exceptions
Consent before marketing use is promised only "where required by applicable law."
Consent for wellness data applies "to the extent" it is considered consumer health data or another special category of Personal Data.
The statements on selling and third-party advertising are about consumer health data and sensitive personal information; other Personal Data is addressed in other sections.
Not stated here
The separate Consumer Health Data Privacy Notice is not in this source, so its additional terms are unknown.
Which wellness data counts as consumer health data under each law is not stated.