The short answer is no. WHOOP sells memberships, and a company charging $239 a year has considerably less incentive to monetise data than a free app does. That is the honest headline and it is also where most articles on this stop, which is a shame, because it is the least interesting part.
Why “do they sell it” is the wrong question
“Sell” is a narrow word and privacy policies are written by people who know that. A company can accurately say it does not sell your data while sharing it with service providers, using de-identified aggregates commercially, disclosing it under legal process, and transferring it wholesale in an acquisition.
None of that is sinister and all of it is standard. But it means the useful question is not what the marketing page says. It is what the privacy policy permits, because the policy is the thing that binds and the practice can change without your involvement.
The HIPAA misconception
A lot of people assume health data is health data and therefore protected. It is not. HIPAA applies to healthcare providers, insurers and their business associates. A company that sold you a fitness membership is generally none of those.
So your continuous heart rate, sleep and HRV history has roughly the legal standing of your shopping history, not your medical record. That is true of WHOOP, Oura, Fitbit and every consumer wearable, and it is worth internalising once rather than assuming otherwise.
What actually protects you, where you live in the right place, is general data protection law rather than health law: the GDPR in the EU and UK, the CCPA in California. Those give you access, deletion and portability rights that apply regardless of what the policy says.
The acquisition clause
This is the one worth caring about. Consumer privacy policies almost universally treat customer data as an asset transferable in a merger, acquisition or bankruptcy.
The practical implication: your judgement about whether to trust WHOOP with years of biometric data is a judgement about WHOOP today, and the data may outlive that company in someone else’s hands. If that bothers you, the mitigation is not choosing a nicer vendor. It is holding less data with anyone, or holding it yourself.
What you can actually do
Export a copy. Your data being useful to you does not depend on the company continuing to exist: how to export your WHOOP data.
Delete rather than just cancel, if the holding is what bothers you. Cancelling stops the billing and keeps the data: how to delete your WHOOP account.
Check the sharing settings for team and group features. Data you shared with a coach or a team is a separate grant from the one you gave the company.
Prefer architectures that hold less. A product that never uploads your biometrics has nothing to sell, nothing to breach and nothing to transfer in an acquisition. That is a structural answer rather than a promise.
For the ring equivalent of this question, the same four clauses apply: see how to delete your Oura account.