Oura uses a legal basis called 'legitimate interest' to process your personal data for marketing and service improvement purposes, meaning it does not always require your explicit consent for these activities.
This analysis describes what Oura's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Legitimate interest as a lawful basis for marketing-related processing means Oura may use your data for these purposes without a separate consent prompt, though you have the right to object to this processing under GDPR.
Interpretive note: The scope of data processed under the legitimate interest basis is not fully specified, and whether health-adjacent data is included in marketing or service improvement processing under this basis is ambiguous from the policy text.
The updated policy explicitly discloses that Oura uses artificial intelligence and machine learning in the service, including an AI assistant called Oura Advisor that provides personalized wellness guidance based on information you submit or that Oura collects. The revised terms state that Oura may use AI and algorithmic analysis to suggest partner services and may use personal data to develop or refine AI-powered health features. The policy establishes that you retain choice about whether to engage with these AI features or share personal data with partner services when suggestions are offered.
View change record →Your personal data may be used for marketing and service improvement without explicit consent under the legitimate interest basis, but EEA and UK users have the right to object to this processing at any time.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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"We process your personal data based on our legitimate interests when we process it for the purposes of marketing our Services and Sites, providing our customer service, and improving our Services. When choosing to use your personal data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.— Excerpt from Oura's Oura Privacy Policy
REGULATORY LANDSCAPE: GDPR Article 6(1)(f) permits processing based on legitimate interests after a balancing test. GDPR Recital 47 addresses legitimate interest for direct marketing. However, GDPR Article 9 prohibits reliance on legitimate interest for special category data including health data. If health-adjacent data is involved in marketing or service improvement processing, the legitimate interest basis may be insufficient and could require consent. The FTC does not recognize a legitimate interest concept but evaluates whether data use is consistent with consumer expectations under FTC Act Section 5. GOVERNANCE EXPOSURE: Medium. The policy asserts legitimate interest covers marketing and service improvement, but does not specify with precision what data is processed under this basis. If health data is processed under legitimate interest for these purposes, this may conflict with GDPR Article 9 requirements and create regulatory exposure in the EEA and UK. JURISDICTION FLAGS: EEA and UK regulators have increasingly scrutinized legitimate interest claims for health-adjacent data. California residents have opt-out rights under CCPA for certain uses of personal information. The legitimacy of the balancing test Oura asserts it conducts is not verifiable from the policy text alone. CONTRACT AND VENDOR IMPLICATIONS: Marketing technology vendors and analytics providers receiving data processed under legitimate interest should be assessed to confirm the processing chain is consistent with the asserted lawful basis and does not extend to special category data without consent. COMPLIANCE CONSIDERATIONS: Legal teams should audit which specific data categories and processing activities are covered by the legitimate interest basis, confirm that a documented balancing test exists, and verify that health data is excluded from legitimate interest processing in favor of consent-based mechanisms. Users' right to object should be operationally implemented and easily accessible.
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Legitimate interest as a lawful basis for marketing-related processing means Oura may use your data for these purposes without a separate consent prompt, though you have the right to object to this processing under GDPR.
Your personal data may be used for marketing and service improvement without explicit consent under the legitimate interest basis, but EEA and UK users have the right to object to this processing at any time.
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