The policy states that users may request account closure and personal data deletion, and that Oura will delete or anonymize data unless a legal basis for retention exists, including legal obligations or protection of Oura's legal interests.
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 establishes that data deletion upon account closure is subject to carve-outs for legal obligation and protection of Oura's legal interests, the latter of which is a broad retention basis that is not further defined in the policy. Compliance teams should assess whether this carve-out is appropriately scoped and disclosed under applicable law.
Interpretive note: The scope of the 'protect our legal interests' retention basis is not defined in the policy and its alignment with GDPR Article 17(3) enumerated exceptions is uncertain.
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 clarifies user control over data upon account termination and establishes conditions for data deletion exceptions, improving transparency about data retention practices.
View full change record →Under this clause, users who close their Oura account and request data deletion may have some data retained if Oura determines a legal basis for retention applies, including protection of Oura's legal interests. The specific categories of data retained and associated retention periods are not detailed in this provision.
How other platforms handle this
You and your organization's administrator can access several types of Service Data directly from Google Cloud, including your account information, billing contact information, payment and transaction information, as well as product and communication settings and configurations.
to request that your data be transferred to a third party (data portability)
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"You can close your Oura account and request deletion of your personal data from our Services. We will delete or anonymize your data, unless we have a legal basis to retain it, such as retention required by applicable law or regulation, or retention necessary to protect our legal interests.Excerpt from Oura's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 17 (right to erasure) and its exceptions under Article 17(3), UK GDPR equivalent provisions, and CCPA/CPRA deletion rights under Section 1798.105.
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This provision establishes that data deletion upon account closure is subject to carve-outs for legal obligation and protection of Oura's legal interests, the latter of which is a broad retention basis that is not further defined in the policy. Compliance teams should assess whether this carve-out is appropriately scoped and disclosed under applicable law.
Under this clause, users who close their Oura account and request data deletion may have some data retained if Oura determines a legal basis for retention applies, including protection of Oura's legal interests. The specific categories of data retained and associated retention periods are not detailed in this provision.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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