This Coaches Privacy Policy applies to personal information we, Noom, Inc. and our controlled affiliates and subsidiaries, collect, use, and disclose about our Noom Mindset coaches. This policy is not intended to create any new rights beyond those that exist in the law, but rather help you understand our practices and what choices you have.
What We Collect & Where It Comes From
Personal information is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you or (where applicable) your household. We collect personal information about you from different sources and in various ways when you’re a Noom Mindset coach, including information you provide directly, information collected automatically, information from third-party sources, and data we infer or generate:
| Personal Information Categories and Examples |
|---|
| Contact information and identifiers, such as first and last name, online identifiers, account and usernames, aliases, IP address, email addresses, home and postal addresses, telephone numbers, signatures, and other information described below. |
| Demographic data, such as age, date of birth, gender,and other information described below. |
| Professional and background information, such as academic and education background and qualifications, work skills and experience, professional certifications and registrations, language capabilities, training courses attended, and inferences from other data we collect for purposes other than creating a profile, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). |
| Performance information, such as date joined, rewards, training, performance appraisals/assessments, absences and reasons for absences, time tracking information, communications, documents, files, or forms generated as part of your work with Noom, letters of appreciation and commendation, grievances or disciplinary matters, and resignation or termination of the relationship. |
| Compensation, payroll, and tax information, such as amounts paid, banking and other financial institution details. |
| Audio, electronic, visual, thermal, olfactory, or similar information, including facial images and voice information, such as photos, videos, CCTV, voice recordings, and sensor data. |
| Geolocation and location data, such as approximate location based on an IP address or device identifier, and office location. |
| Internet or other electronic network activity, including analytics or monitoring data as related to your communications and access to and use of company devices, systems, wi-fi, internet service, internal and external websites, equipment, applications, databases, network resources, and infrastructure (“Company Systems”); personal devices used to connect to Company Systems; usernames and passwords; system log data such as IP address, browser type, and language, device information, access times, and referring website addresses; information collected through web beacons, like cookie IDs; information collected through mobile apps, like mobile device IDs; usage data, such as time spent on Company Systems, features used, and actions taken in Company Systems, including page views, links clicked, and documents downloaded; content and other metadata relating to voice calls, voicemail, emails, chats, messaging, documents, and other communications, data, and files stored or transmitted through Company Systems. |
| Other information necessary for legitimate human resources, business, security, or safety-related purposes. |
Sensitive Personal Information
We may also collect certain “sensitive” or “special categories” of personal information, including:
- Government issued identifiers, such as social security information, driver’s license, state identification card, or passport number;
- Account log-in, financial account, debit card, or credit card number in combination with a security or access code, password, or credentials that allow access to an account; and
- Precise geolocation.
Third Party Sources
We also may receive personal information from our third-party partners, including service providers (e.g., vendors, payment services).
How We Use Personal Information
We use the personal information to support the term of our relationship, including:
| Purposes of Use | Categories of Personal Information |
|---|---|
| HR Uses | |
| Payroll and compensation | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; geolocation and location information; internet or other electronic network activity; and other information |
| Coach development and training | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; internet or other electronic network activity; and other information |
| Performance management and review | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; internet or other electronic network activity; and other information |
| Support services | Contact information and identifiers; demographic data; professional and background information; performance information; compensation, payroll, and tax information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Legal and policy compliance | Contact information and identifiers; demographic data; professional and background information; performance information; compensation, payroll, and tax information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Disciplinary matters and investigations | Contact information and identifiers; performance information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Business Uses | |
| Managing, monitoring, protecting, and improving Company Systems, assets, and resources, including managing and protecting unauthorized access and use | Contact information and identifiers; performance information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Managing and improving workplace efficiency and effectiveness | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; and other information |
| Communications and collaboration | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; and other information |
| Personalization to enhance the coaching experience | Contact information and identifiers; performance information; travel information; internet or other electronic network activity; and other information |
| Delivery of coaching-related goods and services | Contact information and identifiers; sensitive personal information; and other information |
| Research and improvement of Company Systems, processes, products, services, and technology | Contact information and identifiers; professional and background information; performance information; compensation, payroll, and tax information; audio, electronic, visual, thermal, olfactory, or similar information; geolocation and location information; internet or other electronic network activity; and other information |
How We Share Personal Information
We sometimes disclose personal information, including sensitive personal information, if necessary and as required by law.
| Category of Recipient & Purpose for Disclosure | Categories of Personal Information |
|---|---|
| Vendors or agents working on our behalf, including companies we’ve hired to provide online payment services and administrative services; detect fraudulent, deceptive, or illegal activity; measure and analyze the use of Company Systems, network, and to protect and secure our systems and services | Contact information and identifiers; compensation, payroll, and tax information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Parties to a corporate transaction, such as a merger; financing; acquisition; bankruptcy; dissolution; or a transfer, divestiture, or sale of all or a portion of our business or assets | Contact information and identifiers; demographic data; work permit status and mobility information; professional and background information; performance information; compensation, payroll, and tax information; benefits information; benefits administration information; travel information; audio, electronic, visual, thermal, olfactory, or similar information; personal vehicle information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
| Law enforcement and those legally required, including to comply with applicable law or respond to valid legal process; to operate and maintain the security of Company Systems; to protect the rights or property or ourselves or others; and to act in urgent circumstances, such as protecting the health or personal safety of an individual | Contact information and identifiers; demographic data; work permit status and mobility information; professional and background information; performance information; compensation, payroll, and tax information; benefits information; benefits administration information; travel information; audio, electronic, visual, thermal, olfactory, or similar information; personal vehicle information; geolocation and location information; internet or other electronic network activity; sensitive personal information; and other information |
How Long We Keep Personal Information
We keep personal information only so long as we need it to fulfill the purposes described in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Actual retention periods can vary significantly based on your expectations and consent, the sensitivity of the data, the availability of automated controls, and our legal or contractual obligations.
Transferring Personal Information
Personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in the United States. These locations were chosen to operate efficiently and improve our performance.
We take steps to protect your information as described in this policy wherever the data are located, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://ec.europa.eu/commission/presscorner/detail/en/ip_22_7631
California Residents
If you are a California resident, you have certain rights you should know about:
Notice at Collection: You have a right to receive notice of our practices before or when we collect your personal information, including the categories of information and sensitive personal information collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this policy under the headers above.
Right to Know: You have a right to see the personal information we have collected about you. You may request your personal information by contacting us at nmcdata@noom.com.You also have a right to request additional information about our collection, use, disclosure, selling or sharing of such information. You can find those details in this policy under the headers above.
Rights to Request Correction or Deletion: You also have rights to request that we correct inaccurate information about you or delete your personal information. You can update your personal information by emailing nmcdata@noom.com, and delete your data at any time by contacting us at nmcdata@noom.com. Please note that there may be legal reasons for us to keep your data, such as for tax records.
Right to Opt-Out/Right to Limit Use and Disclosure of Sensitive Personal Information: You have a right to opt-out from the “sale” or “sharing” of your personal information and limit the disclosure of your sensitive personal information. However, Noom does not sell or share coaches personal information, or use sensitive personal information for anything other than to support your relationship with Noom as described above.
Right Against Discrimination: We will never discriminate against you for exercising these rights.
You may designate, in writing or through a power of attorney, an authorized agent to exercise these rights on your behalf. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
EEA, UK, and Switzerland Residents
If the processing of your information is subject to the European Economic Area (EEA), United Kingdom (UK), or Swiss data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, your information by contacting us at nmcdata@noom.com;
- If any automated processing of your information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
- If the processing of your information is based on your consent, you can withdraw consent at any time for future processing;
- You can object to, or obtain a restriction of, the processing of your information under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, please contact us at nmcdata@noom.com. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing your information. For example, with your consent or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
If you have any questions about our data processing activities, please contact us at nmcdata@noom.com.
If you think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.
Policy Updates
We may change this policy from time to time and if we do, we’ll post any changes on this page. If you continue to work at Noom after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide more prominent notice or obtain your consent to the changes.
Contact Us
The best way to get in touch with us is by emailing nmcdata@noom.com or at
Noom, Inc.
- Attention: Privacy Officer
- One Palmer Square, Suite 441
- Princeton, NJ 08542.
Updated August 1, 2024.
