Allē

Data Privacy Team

One of the biggest challenges in this project was getting approval from our Data Privacy team. What we thought would be a quick, routine meeting turned into a three-month-long process involving senior leadership.

After our initial presentation of the experience in Figma, the team raised a key concern: the referral program could unintentionally reveal HIPAA-sensitive treatment data. Specifically, because referrers only receive their reward after their friend makes a purchase, they could infer when that treatment occurred by monitoring their wallet closely. This was seen as a privacy issue, since it meant one Allē member could indirectly access another’s treatment information—something not covered in our existing terms and conditions.

This became a major roadblock for launch.

We explored several options to solve this:

1. Reward on account creation instead of purchase
   This would satisfy privacy concerns but break our financial model and increase fraud risk, as users could create fake accounts to earn rewards. We ruled this out pretty quickly.
   
   
   

2. Update general terms and conditions
   This would require adding a specific opt-out for data sharing between users, per GDPR guidelines. That would further complicate our already high-friction registration process, so we also ruled this out.
   
   
   

Our solution:

We added an opt-in screen during registration for users joining via a referral. This keeps the change targeted to a small user group. To reduce friction, we worked with our copy team to make the language sound friendly and non-alarming—while still meeting compliance standards.

Importantly, we’re not sharing exact treatment dates, provider names, services, costs, or points earned; Just enough to trigger the referral reward. That made this the best balance between privacy, user experience, and business needs