Oura calls health data very personal and says you should be in charge of it
Oura says it takes protecting personal data seriously and describes its products as helping you track daily habits, reproductive health and sleep quality, data it says does not get much more personal. It says it believes you should be in charge of your personal data, and that the Policy is meant to give you the information you need to take control of it.
Supporting quotations
protecting your personal data is a task we take seriously
track important aspects of your health like your daily habits, reproductive health, and the quality of your sleep
you should be in charge when it comes to your personal data
designed to provide you with the information you need to take control of your personal data
Qualifications & exceptions
This is a general statement of approach; the specific rules and choices are in later sections.
Use & Processing · Context
Device and application users: purposes Oura lists
This part of the Policy is addressed to people who use Oura Services (device and application users). It introduces the purposes for which Oura says it collects and processes their personal data. The sections that follow also cover the categories of data, the legal basis for processing and the sources of the data.
Supporting quotations
The sections below explain the categories of personal data we collect and process, as well as the reasons we do so
Device & application users
When you use Oura Services, we collect and process your personal data for the following purposes
Use & Processing · Company practice
Purpose: customer service, including through an AI assistant
Oura processes personal data to provide customer service and manage customer communication. For example, if you contact its AI assistant with questions about your account, Oura may use the information you provide to answer your questions and solve issues.
Supporting quotations
We process personal data to provide customer service and manage our customer communication
if you contact our AI assistant with questions regarding your account, we may use the provided information to answer your questions, and for solving any issues you may have
Qualifications & exceptions
The use of information provided to the AI assistant is stated with "may".
Use & Processing · Company practice
Purpose: protect your privacy; aggregated or anonymized data is no longer personal data
Oura may process personal data about your use of the Services in order to protect your privacy, which may involve privacy enhancing technologies and other privacy-protective techniques. The Policy says that when information is aggregated or anonymized it is no longer personal data.
Supporting quotations
We may process personal data regarding your use of the Services to protect your privacy
When information is aggregated or anonymized, it is no longer personal data
Not stated here
The source does not define what level of aggregation or anonymization it relies on.
Use & Processing · Company practice
Purpose: improve the Services and develop or refine AI-powered features
Oura processes personal data about how you use the Services to understand usage and improve the Services, including your experience in the Oura App. It may also use personal data to develop or refine AI-powered features that give you new insights about your health. It says that where appropriate it uses privacy-protective measures such as pseudonymization, aggregation or de-identification.
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We process personal data regarding your use of our Services to understand how you use our Services and how we can improve them
We may also use personal data to develop or refine AI-powered features that provide you with new insights about your health
Where appropriate, we use privacy-protective measures, like pseudonymization, aggregation, or de-identification
Qualifications & exceptions
Privacy-protective measures are applied "where appropriate", not stated as always.
Use & Processing · Company practice
Purpose: analysis of performance and wellbeing data, including third-party automated technology
Oura may process personal data about human performance and wellbeing to benefit users and improve the insights it provides. Some features may use third-party automated technology to personalize the experience, and Oura says intelligent features may use responses you provide. When feasible it uses data that has been processed to protect your privacy.
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We may process personal data about human performance and wellbeing to benefit our users and improve the cutting-edge insights we provide with our Services
Some features of our Services may use third-party automated technology to provide a more personalized experience
When feasible, we do this using data that has been processed in a manner to protect your privacy
The third-party automated technology providers are not named.
Use & Processing · Company practice
Purpose: market Oura Services; no sale or cross-context behavioral advertising sharing
Oura processes personal data to provide marketing communications for Oura Services and partner opportunities. The Policy says it uses cookies and similar technologies on its website to create audiences for online advertisement, and refers to the Cookie Policy. It says it does not sell or share your personal data for cross-context behavioral advertising. You can opt out of direct marketing from Oura by unsubscribing within emails, and you may see personalized opportunities in the Services to connect with partners.
Supporting quotations
We process personal data to provide marketing communications for Oura Services and partner opportunities
we use cookies and similar technologies on our website to create audiences for online advertisement
We do not sell or share your personal data for cross-context behavioral advertising
You can opt out of direct marketing communications from Oura by unsubscribing within emails
You may see personalized opportunities surfaced within our Services to connect with partners who can support your health journey
Qualifications & exceptions
The opt-out described is for direct marketing communications from Oura by unsubscribing within emails.
The Cookie Policy is referred to but not part of this source.
Cross-references
contrast (model-proposed): Right to object or opt out; Oura says it does not sell data, profile or engage in targeted advertising — contrast: The marketing purpose says cookies are used to create audiences for online advertisement, while the rights section says Oura does not engage in targeted advertising based on your personal data. The source does not say how audience creation relates to targeted advertising as defined by law.
Use & Processing · Company practice
Oura uses aggregated Enterprise Platform data for analytics and research and development
Oura says it uses aggregated Oura Enterprise Platform data for analytics, statistics, research and development, and that Oura is the controller of that aggregated data, which may no longer be personal data because of aggregation. For other data Oura processes that is not at the Data Recipient's direction, the rest of the Policy applies.
Supporting quotations
Oura uses aggregated Oura Enterprise Platform data for analytics, statistics, research and development purposes
Oura is the controller of such aggregated data, which may no longer qualify as personal data due to aggregation
the rest of the terms in this Policy apply
Qualifications & exceptions
The source says aggregated data "may" no longer qualify as personal data.
Oura Research App: separate application for voluntary research studies
The Oura Research App is a separate application that lets people take part in research studies run by or for Oura or an independent research sponsor (Research Sponsor). Participation in any study is voluntary.
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The Oura Research App is a separate application that enables individuals to participate in research studies conducted by or on behalf of Oura or an independent research sponsor
Participation in any research study is voluntary
Use & Processing · Company practice
Research App: the Research Sponsor is controller and Oura may act as processor
If you enroll in a research study, the Research Sponsor acts as controller (or the equivalent role under applicable law) of the research data collected for the study. Oura may act as a processor or service provider to the Research Sponsor for hosting, storage or technical administration of the Oura Research App, unless the applicable ICF says otherwise. Questions about the protocol, use of research data or exercising data protection rights relating to research data should go to the Research Sponsor named in the ICF.
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the Research Sponsor acts as the controller (or equivalent legal role under applicable data protection laws) of research data collected for the study
Oura may act as a processor or service provider to the Research Sponsor in connection with the hosting, storage, or technical administration of the Oura Research App, unless otherwise described in the applicable ICF
should be directed to the Research Sponsor as identified in the ICF
Qualifications & exceptions
Applies if you enroll in a research study.
Oura's processor role is stated as "may" and subject to what the ICF says.
Use & Processing · Restriction or exception
Research App: blinded studies can limit your access to your own data
Research studies may involve data blinding or other protocol-based restrictions. During a blinded period you may not be able to access certain personal data, scores or insights in the Oura Research App even though your ring keeps collecting sensor data. These limits follow the study protocol and the Research Sponsor's direction, and the ICF describes whether and when access will be restored and any conditions.
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During a blinded period, you may not be able to access certain personal data, scores, or insights in the Oura Research App, even though your Oura Ring continues to collect sensor data
at the direction of the Research Sponsor
The ICF will describe whether and when access to such data will be restored, and any conditions that apply
Qualifications & exceptions
Applies during a blinded period of a study that uses blinding.
Use & Processing · Context
Online customers and site visitors: purposes Oura lists
This part of the Policy is addressed to people who visit Oura's Sites or complete orders in its online store. It lists the purposes for which Oura says it processes their personal data.
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SITE VISITORS
Processing purposes
If you visit Oura's Sites or complete orders on Oura's online store, we process personal data for the following purposes
Use & Processing · Company practice
Site purpose: provide the Services, including an AI customer support chatbot
Oura processes personal data to power its offerings, which may include when you visit its Sites and to enable Site performance. Some features use AI. For example, when you use its virtual support agent, Finn, you are interacting with an AI-powered customer support chatbot.
Supporting quotations
We process personal data to power our offerings, which may include when you visit our Sites
you are interacting with an AI-powered customer support chatbot when you interact with our virtual support agent, Finn
Use & Processing · Company practice
Site purpose: complete and deliver orders
Oura processes personal data to process, handle and deliver your purchases and to facilitate your shopping.
Supporting quotations
We process personal data to process, handle, and deliver your purchases, and to facilitate your shopping
Use & Processing · Company practice
Site purpose: customer service through a virtual assistant
Oura processes personal data to provide customer service and manage customer communication. For example, if you contact its virtual assistant with questions about the Sites or Services, it may use the information you provide to answer your questions and solve issues.
Supporting quotations
We process personal data to provide customer service and manage customer communication
if you contact our virtual assistant with questions regarding our Sites or Services, we may use the provided information to answer your questions, and for solving any issues you may have
Use & Processing · Company practice
Site purpose: protect your privacy with aggregation or anonymization
Oura may process personal data about your use of the Services to protect your privacy, which may involve privacy enhancing technologies. The Policy says that aggregated or anonymized information is no longer personal data.
Supporting quotations
We may process personal data regarding your use of our Services to protect your privacy
When information is aggregated or anonymized, it is no longer personal data
Use & Processing · Company practice
Site purpose: analyze and improve the Sites, including AI features
Oura processes personal data to analyze and improve its Sites, for example to analyze Site performance, improve user experience and optimize content and layout. It may also use personal data to improve AI-powered features on the Sites, including its virtual support agent. When feasible it uses data processed to protect your privacy.
Supporting quotations
We process personal data to analyze and improve our Sites
We may also use personal data to improve AI-powered features on our Sites, including our virtual support agent
When feasible, we will do this using data that has been processed to protect your privacy
Site purpose: advertise and market; contextual advertising; no cross-context behavioral advertising
Oura processes personal data to provide marketing communications about Oura Services and partner opportunities. Under its Cookie Policy it uses cookies on its Site to measure marketing effectiveness, understand how visitors interact with the Sites and provide contextual advertising. It says it does not sell or share personal data for cross-context behavioral advertising. You can always opt out of Oura direct marketing communications, though you may still see marketing messages within the Oura App. If a third-party partner sends Oura-branded advertising, the Policy tells you to review that third party's privacy policy and contact it about opt-out requests.
Supporting quotations
We process personal data to provide marketing communications about Oura Services and partner opportunities
we use cookies on our Site to measure the effectiveness of our marketing, understand how visitors interact with our Sites, and provide contextual advertising
We do not sell or share your personal data for cross-context behavioral advertising
You can always opt out of Oura direct marketing communications, though you may still see marketing messaging within the Oura App
please review the third-party
Qualifications & exceptions
Opting out of direct marketing does not remove marketing messaging shown within the Oura App.
The Cookie Policy is referred to but is not part of this source.
Use & Processing · User right or choice
Text messaging: giving your phone number means agreeing to receive texts; reply STOP to opt out
By giving Oura your phone number you agree to receive text messages from Oura, such as shipping notifications or order updates. Message and data rates may apply and frequency varies. You can opt out at any time by replying STOP to any text message. Oura says it does not share or sell text messaging opt-in consent data with any third party or affiliate for marketing or promotional purposes.
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SMS/TEXT MESSAGING
By providing your phone number, you agree to receiving text messages from Oura
Message and data rates may apply
You may opt out of receiving text messages at any time by replying STOP to any text message you receive from us
Oura does not share or sell text messaging opt-in consent data with any third party or affiliate for marketing or promotional purposes
Qualifications & exceptions
The examples of texts given are shipping notifications or order updates; the source does not limit texts to those.
Not stated here
The source does not say whether other personal data (apart from opt-in consent data) can be shared with third parties for marketing.
Use & Processing · Company commitment
U.S. notice: sensitive information and consumer health data used only for the Policy's purposes
Some personal information Oura processes is classified as sensitive personal information, sensitive data or consumer health data under U.S. state law. This includes data about your health and measurements collected by Oura Services, health records you import, reproductive and sexual health information, diagnoses and other legally or socially sensitive data. Oura says it processes this information for the purposes described in the Policy and not to infer characteristics about you outside those purposes. It says it does not use sensitive personal information for targeted advertising and does not sell or share personal information for cross-context behavioral advertising.
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Some of the personal information we process is classified as
This includes data about your health and measurements collected by Oura Services, health records you import to our Services, reproductive and sexual health information, diagnoses, or other legally or socially sensitive data
We process this information for the purposes described in this Policy, and not to infer characteristics about you outside those purposes
We do not use sensitive personal information for targeted advertising and we do not sell or share personal information for cross-context behavioral advertising
Qualifications & exceptions
Presented in the U.S. notice for residents of states with enhanced privacy requirements.
Use & Processing · Company practice
U.S. notice: Oura may use personal data for its own AI and LLM features; no sale for third-party LLM training
Oura says it may collect and use personal data to develop, test, improve and support its own AI, machine learning and large language model-powered features. It says it does not sell personal data for the purpose of training third-party large language models.
Supporting quotations
We may collect and use personal data to develop, test, improve, and support Oura
We do not sell personal data for the purpose of training third party Large Language Models
Qualifications & exceptions
The statement about third-party LLM training is limited to selling personal data.
Not stated here
The source does not say whether personal data is provided to third-party LLM providers other than by sale, for example under the integrations described earlier.
Use & Processing · User right or choice
Right to object or opt out; Oura says it does not sell data, profile or engage in targeted advertising
You have the right to object to or opt out of processing of your personal data under certain circumstances. If Oura has no legitimate grounds to continue, it will stop processing after receiving and verifying your objection. As examples, under some regulations you may have the right to object to the sale of your data, profiling or targeted advertising as defined by law. Oura says it does not sell your data, profile or engage in targeted advertising based on your personal data, and that you can always opt out of direct marketing at any time.
Supporting quotations
Right to object to processing
You have the right to object to or opt out of the processing of your personal data under certain circumstances
In the event that we do not have legitimate grounds to continue processing such personal data, we will no longer process your personal data after we have received and verified your objection
Oura does not sell your data, profile, or engage in targeted advertising based on your personal data, and you always have the right to opt out of direct marketing at any time
Qualifications & exceptions
Stopping processing depends on Oura having no legitimate grounds to continue.
The terms sale, profiling and targeted advertising are described as defined under applicable law.
Not stated here
The source does not say how Oura's "profile" statement relates to the personalized insights and health inferences described in the purposes sections.
Use & Processing · User right or choice
Right to restrict processing: for example while data accuracy is contested
You have the right to ask Oura to restrict processing of some types of personal data in certain circumstances. For example, if you contest the accuracy of your data you can ask Oura not to process it until Oura has verified the accuracy.
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Right to restrict processing
You have the right to request that we restrict processing some types of personal data under certain circumstances
if you contest the accuracy of your data, you can make a restriction request that we do not process your data until Oura has verified the accuracy of your data
Qualifications & exceptions
Applies to some types of personal data under certain circumstances.