The policy states that Oura does not sell personal data, which under CCPA/CPRA includes the exchange of personal information for monetary or other valuable consideration.
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
This provision asserts that Oura does not sell personal data; however, the policy separately discloses advertising-related data processing on behalf of partners using cookies and similar technologies, which may constitute 'sharing' of personal information for cross-context behavioral advertising under CPRA even if it does not meet the definition of 'sale.' Compliance teams should assess whether the advertising practices described elsewhere in the policy require a CPRA 'opt out of sharing' mechanism in addition to the no-sale representation.
Interpretive note: Whether Oura's cookie-based advertising practices constitute 'sharing' under CPRA is a legal determination that depends on the specific nature of the data exchanged with advertising partners, which is described in the Cookie Policy rather than this document.
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 →This addition directly addresses consumer concerns about data commercialization and provides an explicit commitment that may satisfy privacy law requirements in jurisdictions like California.
View full change record →The agreement states that Oura does not sell personal data. Separately, the policy discloses that Oura processes data for advertising on behalf of partners using cookie-based technologies, which may be subject to CPRA's opt-out-of-sharing requirements independent of the no-sale assertion.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
"Oura does not sell your personal data.Excerpt from Oura's Privacy Policy
1) REGULATORY LANDSCAPE: CCPA/CPRA defines 'sale' as disclosure of personal information for monetary or other valuable consideration, and separately defines 'sharing' as disclosure for cross-context behavioral advertising regardless of monetary consideration.
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This provision asserts that Oura does not sell personal data; however, the policy separately discloses advertising-related data processing on behalf of partners using cookies and similar technologies, which may constitute 'sharing' of personal information for cross-context behavioral advertising under CPRA even if it does not meet the definition of 'sale.' Compliance teams should assess whether the advertising practices described elsewhere …
The agreement states that Oura does not sell personal data. Separately, the policy discloses that Oura processes data for advertising on behalf of partners using cookie-based technologies, which may be subject to CPRA's opt-out-of-sharing requirements independent of the no-sale assertion.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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