Legal
Privacy Policy
ORIN is committed to protecting your privacy. This policy explains how we handle nutrition, wearable, and account information when you use the website, applications, wearable, and related services.
Draft for review. Anything in brackets has not been decided and must be confirmed before launch. This page is not a substitute for review by counsel.
1. Overview
This Privacy Policy explains how ORIN (“we,” “us,” or “our”) collects, uses, shares, and protects information when you use our products, services, and website (collectively, the “Service”).
ORIN is a U.S.-based company building a wearable nutrition intelligence system. The Service may include a wearable, a website, and mobile or web software, and may use a camera, microphone, motion sensors, and automated systems to understand eating and nutrition. [TO CONFIRM BEFORE LAUNCH: legal entity name, and the products this policy covers at launch.]
2. Information We Collect
We collect information to provide and operate the Service. What we actually collect depends on the product you use, what you choose to provide, and the permissions you grant. [TO CONFIRM BEFORE LAUNCH: which categories are collected at launch, and which are optional.]
Account information
Name, email address, and login or account credentials, if you create an account. [TO CONFIRM BEFORE LAUNCH: whether accounts exist at launch, and what fields are required.]
Profile and goal information
Nutrition goals, preferences, and other profile details you choose to give us, which may include age or similar information. [TO CONFIRM BEFORE LAUNCH: the profile fields the product asks for.]
Nutrition and meal information
Information about meals, foods, portions, and nutrition estimates, including records you correct or add yourself.
Wearable sensor information
Signals from the wearable that are used to understand eating. The specific sensors and what they record are [TO CONFIRM BEFORE LAUNCH].
Images or visual information
Visual information the wearable’s camera may capture while you are wearing it, if that sensor is part of the product you use. [TO CONFIRM BEFORE LAUNCH: whether images are stored, for how long, and in what form.]
Audio information
Audio the wearable may capture, if a microphone is enabled and used. [TO CONFIRM BEFORE LAUNCH: whether audio is captured, when it is on, and what is retained.]
Motion information
Motion or inertial-sensor data from the wearable, if those sensors are used. [TO CONFIRM BEFORE LAUNCH]
Device and connectivity data
Device identifiers, app version, operating system, connection status, and similar technical data needed to operate and support the Service.
Location information
Location, if you permit it. [TO CONFIRM BEFORE LAUNCH: whether the product requests location, and for what purpose.]
Connected health or wellness data
Information from another health or wellness service, if you choose to connect one. [TO CONFIRM BEFORE LAUNCH: which connections, if any, will exist at launch.]
App and website usage and diagnostics
How you use the website or app, including pages viewed, features used, and diagnostic or crash information. [TO CONFIRM BEFORE LAUNCH: analytics tools, if any.]
Customer support communications
Messages you send us, and the information you include so we can respond.
Purchase, preorder, and payment information
If you preorder or buy, we may receive order details such as your name, email, and what you purchased. Payment-card data is expected to be processed by a payment processor rather than stored by ORIN. [TO CONFIRM BEFORE LAUNCH: the processor, and which order fields ORIN receives.]
3. Wearable Capture and Bystander Privacy
ORIN is a sensor wearable. Depending on the product, it may capture visual, audio, or motion information while you wear it, in order to understand eating and nutrition. It is not intended as a general camera or recorder. [TO CONFIRM BEFORE LAUNCH: the sensors that ship, when they are active, and what a person sees or feels when they are.]
Because the wearable is with you in ordinary life, it may incidentally capture other people, conversations, or surroundings. You are responsible for using it lawfully and respectfully, including by following the rules of places you enter and the expectations of people around you.
Where the product supports it, you will be able to pause or otherwise control capture. [TO CONFIRM BEFORE LAUNCH: the actual controls — pause, off, indicator, and where they live.]
Raw images or audio, if captured, are not the same thing as a nutrition estimate derived from them. What is kept, what is discarded, and whether processing happens on the wearable, on your phone, or in the cloud is [TO CONFIRM BEFORE LAUNCH]. Until that is decided, this policy does not claim that capture stays on the device, that images are never stored, or that audio is never retained.
4. How We Use Information
We use information for the purposes below, as they apply to the Service you use.
- Provide and operate ORIN
- Identify meals and estimate nutrition
- Personalize nutrition guidance
- Keep a nutrition history
- Help you move toward goals you set
- Improve performance and reliability
- Troubleshoot and provide support
- Secure accounts and prevent abuse
- Comply with law
We do not describe your information as training data for models in this policy. [TO CONFIRM: MODEL TRAINING POLICY]
5. AI and Automated Processing
ORIN may use automated systems, including AI, to analyze sensor information and information you provide. Those systems may produce food recognition, portion estimates, nutrition estimates, insights, and recommendations.
Outputs can be wrong. Where the product lets you correct a meal or a nutrition record, you can do so. [TO CONFIRM BEFORE LAUNCH: which estimates a person can edit, and whether a human reviews them.]
7. Advertising, Sale, and Sharing
Some U.S. privacy laws use “sale” and “sharing” to describe certain disclosures, including disclosures for cross-context advertising, even when no money changes hands.
ORIN’s position on selling personal information, sharing it for advertising, and honoring opt-out requests is [TO CONFIRM BEFORE LAUNCH]. This policy does not claim that ORIN never sells or shares personal information.
8. Data Retention
We keep information for as long as reasonably needed for the purposes in this policy, including to operate the Service, resolve disputes, and meet legal or security obligations. Specific retention periods, including for images, audio, and nutrition history, are [TO CONFIRM BEFORE LAUNCH].
9. Security
We use reasonable administrative, technical, and organizational safeguards designed to protect information. No system can be guaranteed secure, and we do not promise a particular encryption standard or certification. [TO CONFIRM BEFORE LAUNCH: the safeguards that will actually be in place at launch.]
10. Your Choices and Controls
Depending on the product and your device settings, you may be able to:
- Access and update account information
- Correct meal and nutrition records
- Delete information, or delete an account, where that is supported
- Control notifications
- Manage location permission on your device
- Connect or disconnect a health or wellness service
- Pause or manage wearable capture, where the product supports it
- Opt out of marketing messages
- Control cookies through your browser
Which of these controls ship, and where you find them, is [TO CONFIRM BEFORE LAUNCH]. To make a request we do not yet support in the product, use the contact details below.
11. U.S. State Privacy Rights
Depending on where you live, U.S. state privacy laws — including the California Consumer Privacy Act, as amended by the CPRA, and similar laws in other states — may give you rights to access, delete, correct, or obtain a copy of personal information, and to opt out of certain processing, including sale or sharing where those terms apply.
We have not determined which statutes apply to ORIN. [TO CONFIRM BEFORE LAUNCH: applicability, how to submit a request, how we verify a request, and how an authorized agent may submit one.] We will not discriminate against you for exercising a right the law gives you.
12. California Notice
If you are a California resident, this section is a notice of the categories of personal information described in this policy, the purposes in “How We Use Information,” and the categories of recipients in “How We Share Information.”
Whether ORIN sells or shares personal information as California defines those terms, whether we use sensitive personal information beyond what is needed to provide the Service, and how to use a “Do Not Sell or Share” or “Limit the Use of My Sensitive Personal Information” choice, are [TO CONFIRM BEFORE LAUNCH].
California residents may also have rights under the Shine the Light law. [TO CONFIRM BEFORE LAUNCH: whether that request path applies, and the address for it.]
13. Children’s Privacy
ORIN is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has given us information, contact us and we will take appropriate steps to delete it.
A higher minimum age, if ORIN sets one, is [TO CONFIRM AGE REQUIREMENT].
14. International Users
ORIN is based in the United States. Information may be processed in the United States and, through service providers, in other countries. Those countries may not provide the same privacy protections as the country where you live.
This policy does not claim that ORIN complies with the GDPR or any other non-U.S. law. [TO CONFIRM BEFORE LAUNCH: whether the Service is offered outside the United States, and any transfer mechanism that applies.]
15. Third-Party Services and Health Integrations
If you connect another service — for example a phone health platform, another wearable, or a location service — that service has its own privacy terms. ORIN is not responsible for how those companies handle information under their own policies.
We are not naming specific integrations here. [TO CONFIRM BEFORE LAUNCH: name a platform only if the product actually connects to it.]
17. Changes to This Privacy Policy
We may update this policy. When we do, we will change the “Last updated” date. If a change is material, we will provide notice in a way that fits the change — for example, on the website or by email if we have your email and the change warrants it. [TO CONFIRM BEFORE LAUNCH: the notice method for material changes.]
18. Contact Us
Questions about this policy or your information can be sent to:
- Legal entity: [TO CONFIRM BEFORE LAUNCH]
- Email: [TO CONFIRM BEFORE LAUNCH: privacy email]
- Mail: [TO CONFIRM BEFORE LAUNCH: mailing address]