1. What this policy covers
This policy explains what Lumenos AI Inc., a Delaware corporation doing business as Oona (“Oona”, “we”, “us”), collects about you when you use withoona.com, take the Clinical Skin Analysis, order a program and use your account; how we use it; who we share it with; how long we keep it; and the choices you have.
Two kinds of information are in play, and two documents cover them:
- Information Oona holds: your contact details, your Clinical Skin Analysis answers, your photo and your Clinical Skin Analysis report, your order, your messages to the care team, your consents and how you reached Oona. This policy covers it.
- Your medical information: what your physician reviews, decides and prescribes, and your DNA results. Your physician’s practice, [pending: the Practice’s legal name] (the “Practice”), holds it. The Practice’s Notice of Privacy Practices covers it. Oona processes medical information for the Practice as its service company [pending: the Oona–Practice services agreement].
Oona is not a “covered entity” under HIPAA, and Oona bills no insurer. [pending: the Practice’s HIPAA status] Whether or not HIPAA applies, Florida law (s. 456.057, Florida Statutes) keeps your medical records confidential, and the Practice’s Notice describes how they are handled.
2. What we collect
| What | When | Examples |
|---|---|---|
| Contact and account details | The Clinical Skin Analysis email step, checkout, your account | Name, email address, phone number, shipping and billing address, your ZIP code and state |
| Clinical Skin Analysis answers | The quiz | Your age range and date of birth, sex, height and weight, whether you are pregnant or breastfeeding, your health history, conditions and medications, your skin concerns and goals, your sun, sleep, diet, alcohol, smoking and stress habits, and your email preferences |
| Your photo and face data | The photo step | The photo you take with Perfect Corp.’s camera kit in your browser, and data derived from it, which may include your face geometry. You give express written consent to this at the photo step |
| Your report | After the photo | Your Skin Age and pace of aging, the scores and findings, and the images generated from your photo |
| Your DNA results | After you return your kit | Oona receives your genetic data from Gencove (your genome-wide variant file and the markers your program uses) and holds it for your program; your physician receives your results. [pending: the laboratory’s confirmation] Your results make your supplement formula and, at your physician’s discretion, adjust your metformin schedule |
| Your order and payments | Checkout and after | Your plan, the amounts and dates of each charge, refund or cancellation, your payment method’s type and last four digits, and your Klarna account reference. Stripe and Klarna hold your card and account details; Oona never sees your full card number |
| Your consents | Each time you agree to something | The time our server received your agreement, your IP address and browser, the version of each document you agreed to and the exact words the page showed you. One record per agreement; never changed afterwards |
| Messages | Chat and your account | What you write to the sales team and the care team, the photos and files you attach, your questions to your physician and the physician’s answers, and the care team’s notes |
| How you reached Oona | Your first and later visits | The campaign tags on the link you clicked (UTM parameters), the click id a platform adds (for example Meta’s or Google’s), the site that referred you and the page you landed on. We drop any value that looks like an email address |
| Technical data | Every request to our servers | IP address, browser type, the pages you request, timings and errors. Session identifiers are shortened in our logs |
| Waitlist | If you are outside Florida | Your email address and state |
Cookies. We set one cookie, to keep you signed in to your account. On the pages that show the sales chat, Intercom, which runs it, sets its own cookies to keep your conversation open across pages and visits. We set no advertising or analytics cookies, and we load no analytics, advertising pixel or tag manager. We do not collect a government ID, your Social Security number or your insurance details. We do not ask for your race or ethnicity.
What your browser stores. Our pages keep, on your device: your session id, your quiz answers and step, your checkout order, a retake reason, your privacy choice and how you reached Oona (above, for up to 90 days). This is first-party storage for the site to work. Stripe sets its fraud-prevention cookies on the checkout. The quiz’s photo step loads Perfect Corp.’s camera kit, and our pages load fonts from Google Fonts and two libraries from the jsDelivr and cdnjs content networks; each of those providers sees your IP address when your browser fetches from it.
3. How we use it
- To build your report and show you your plan.
- To give your physician what your physician needs to decide whether to treat you, and what to prescribe: your answers, your photo, your report and your DNA results.
- To take your order, save your payment method, charge you when your physician approves and your order ships, renew your plan and refund you, as the Payment & Billing Consent and the Refunds and Cancellation Policy say.
- To ship your kit, medications and supplements.
- To email you about your report, your order, when your physician approves your request, your billing and your account; and, if you asked for them, offers.
- To answer you in chat and in your account, and to pass medical questions to your physician.
- To keep a record of what you agreed to, for your protection and ours, including if a payment is disputed.
- To measure our advertising (section 7) and to count how people use the site, without any advertising or analytics service on our pages.
- To keep Oona secure, to prevent fraud and abuse, and to meet our legal duties.
- To improve the program, using information that no longer identifies you.
4. Who we share it with
Only what each needs, and only for the purpose below.
| Who | What they receive | Why |
|---|---|---|
| Your physician and the Practice | Your answers, photo, report, DNA results, questions for the physician, and your order’s status | To decide on and provide your care |
| The pharmacy [pending: name] | Your name, date of birth, address and phone number, and your prescription, from your physician | To compound and ship your medication |
| Gencove, Inc. and its laboratories [pending: the laboratory’s confirmation] | Your name and shipping address (to send the kit), your cheek-swab sample and the kit’s reference number [pending: what the laboratory’s requisition carries] | To ship your kit and analyze your DNA |
| The supplement manufacturer [pending: name] | Your formula, your name and your shipping address | To make and ship your supplements |
| Shipping carriers (used by our pharmacy, laboratory and supplement maker) | Your name, address and phone number | To deliver to you |
| Perfect Corp. | Your photo, with its metadata removed. No name, email, answers or any identifier of yours | To analyze your skin from the photo |
| OpenAI | Your photo with its metadata removed, the analysis images made from it, and the instructions for each image, which include your estimated Skin Age from the analysis. No name, email, answers or any identifier of yours | To generate the images in your report |
| Fal.ai (Features & Labels Inc.) | The same as OpenAI, when Fal’s copy of the image model is used instead of OpenAI’s | To generate the images in your report |
| Amazon Web Services | Everything Oona stores and runs, encrypted; the care chat runs on Amazon Connect and our emails are sent through Amazon SES | Hosting, storage, chat and email delivery, under a HIPAA business associate agreement. No open or click tracking in our emails |
| Amazon Q in Connect | Your chat messages | Suggests a reply to the team member answering you, when it is switched on. It is off in our chats today, and it never writes to you |
| Intercom, Inc. | Your sales-chat messages and attachments, the page you are on, and your browser and device details, and whether you have finished your Clinical Skin Analysis | Runs the sales chat on our website, including Fin, its automated assistant, which answers first |
| Stripe | Your name, email, address, card or wallet details, and each charge | Payment processing, saved payment methods, dispute handling |
| Klarna | What you give Klarna, and each charge | If you pay with Klarna |
| Apple Pay, Google Pay | What those wallets send Stripe | If you pay with them |
| Marketing and advertising partners (Meta, Google) | When you arrived from one of their ads and have not opted out (section 8), the platform whose ad you clicked is told of each step: you land on our website (Meta only), start the Clinical Skin Analysis, give your email, your report is ready, you open your plan, you start checkout, you submit your request for physician review, and your order is confirmed after your physician approves. Meta receives with each step the click id it added, the time, and your IP address and browser; from the step you give your email, your email address in hashed form; and with the confirmed order, your phone number, name, city, state, ZIP code, country and a customer identifier, also in hashed form, with your order number and amount. Google receives with each step the click id it added and the time; and with the confirmed order, your order number and amount. Never your answers, your photo, your results, your medications or any other health information | To measure which ads bring customers (section 7) |
| Authorities and others as the law requires | What the law requires | A subpoena, a court order, a safety emergency, fraud prevention, or to protect Oona’s rights |
| A successor | Your information, under this policy | If Oona is sold or merged, you are told first |
We do not share your personal information with data brokers.
5. Your medical information and your physician
Your physician reviews your intake in a secure physician account that opens with a one-time link and an authenticator code. Your physician sees your answers as the quiz asked them, your photo and report, your DNA results and your questions. The physician’s decisions and prescriptions go into your medical record at the Practice [pending: the medical-records system the Practice uses]. The Practice keeps your record for at least five years after your last contact, as Florida’s Board of Medicine requires, and longer where the law requires. You can ask the Practice for a copy of your record; see the Notice of Privacy Practices.
Your DNA sample is analyzed only with your express consent, which you give when you activate your kit in your account, as the Telehealth Consent explains. Under Florida law the results are your property, are confidential and are not disclosed without your express consent, except as the law requires.
6. How long we keep it
| Data | Retention |
|---|---|
| Your Clinical Skin Analysis, photo and report, if you do not order | 30 days after your last activity; then your session, answers, photo, report and email are deleted |
| Everything with an order: your order, report, consents, messages and the medical record | Kept with your order and your medical record for at least five years after your last contact (Fla. Admin. Code 64B8-10.002; s. 456.47(3), Florida Statutes), and as long as tax, payment and consumer law require |
| Chat transcripts and attachments | Kept, including chats from before you ordered |
| Waitlist emails | 30 days after your last activity, like any Clinical Skin Analysis without an order |
| How you reached Oona (campaign tags, click ids) | 90 days on your device and on our servers; with an order, kept with the order |
| Technical logs | 30 days |
| Database backups | 7 days |
When a period ends, we delete or de-identify the information.
7. Advertising measurement
Marketing and advertising partners. We may provide personal information to marketing and advertising partners, for example to measure how our ads perform and to show our ads to you or to people with similar interests. We tell only the platform whose ad you clicked, and only the steps you take on our website (section 4). To Meta we send the click id it added, the time, your IP address and browser, and, in hashed form, your email address, phone number, name, city, state, ZIP code, country and a customer identifier, with your order number and amount. To Google we send the click id it added, the time, and your order number and amount. We never send your answers, your photo, your results, your medications or any other health information.
Data sales and targeted advertising. Some privacy laws define “sale” or “sharing” broadly to include some of these disclosures. To opt out, use your browser’s Global Privacy Control setting or select “Your privacy choices” at the bottom of our website. These choices apply to the browser you use, and to your Oona account when you are signed in.
Similar technologies. We store how you arrived at Oona, such as the ad you clicked, on your device and on our servers, with your IP address and browser, for up to 90 days, or with an order as long as we keep it (section 6), so we can measure our advertising.
8. Your privacy choices
The “Your privacy choices” sheet. The link at the bottom of our website, on the checkout and in your account opens a sheet with three boxes: Limit use of my sensitive information, Opt out of Targeted Advertising and Opt Out of Sale/Sharing of Personal Information. Tick any of them and press Confirm. When any box is ticked, we send nothing about you to our advertising partners, and anything queued is cancelled. Closing the sheet with Escape, the browser’s Back, or by leaving the page records the boxes as they were shown. We record each choice with the time, your IP address and browser, so that we can prove we honored it.
Notice of right to limit. You can limit our use of your sensitive personal information to what is needed to provide what you asked for, or as the law otherwise allows. To do so, tick Limit use of my sensitive information in the sheet.
Global Privacy Control. If your browser sends the Global Privacy Control signal, we treat it as an opt-out: the two opt-out boxes start ticked and nothing is sent. We record the signal the first time we see it. Your own later choice in the sheet, in either direction, overrides the signal. We do not ask you about cookies, and the sheet never opens on its own.
Email and texts. Every offer email has an unsubscribe link. Reply STOP to any text to stop texts. Service emails about your report, order, care and billing continue while you have an account.
Your account. You can change your address, payment method and privacy choice, read your messages and cancel your plan in your account.
Requests. You can ask us to tell you what we hold about you, to correct it, to delete it, or to send you a copy. Email concierge@withoona.com with the subject “Privacy request”. We will confirm it is you, and answer within 45 days. We cannot delete your medical record, your order or your consent records, which we must keep; we will tell you what we kept and why. We never treat you differently for making a request. If we refuse a request, you can ask us to reconsider by replying, and we will answer within 45 days.
9. Security
Everything we store is encrypted at rest and in transit. Access is limited to the people who need it to serve you, and staff access to orders is logged. Your session link is a secret; we never print it in full in our logs. Your physician’s account needs a one-time link and an authenticator code. No system is perfectly secure; if a breach affects your information, we will tell you as the law requires.
10. Children
Oona is for adults. We do not knowingly collect information from anyone under 18. If you believe we have, email concierge@withoona.com and we will delete it.
11. Changes
We may change this policy. When we do, we publish the new version with a new id and effective date, and we email you if the change matters to you. We will never change what we have told you about advertising measurement after the fact: the policy that applies to a disclosure is the one in force when it was made. The version you agreed to is recorded with your consents.
12. Contact
Lumenos AI Inc., doing business as Oona · 8 The Green, Ste B, Dover, DE 19901 · concierge@withoona.com, subject “Privacy request”