| Cookie Policy | | Cookie Policy |
| 渝ICP备2021001788号-3A | | 渝ICP备2021001788号-3A |
| This Privacy Policy has been prepared in English and translated into the followi | | This Privacy Policy has been prepared in English and translated into the followi |
| ng languages. The English version is the official version, and the other version | | ng languages. The English version is the official version, and the other version |
| s are provided for reference. In the event of any inconsistency or conflict betw | | s are provided for reference. In the event of any inconsistency or conflict betw |
| een the two versions, the English version shall prevail. | | een the two versions, the English version shall prevail. |
| n | Czech | | n | Czech | Dutch | English | French [Canada] | French [Europe] | German | Hindi | H |
| | | ungarian | Italian | Japanese | Korean | Malay | Mandarin | Polish | Portuguese |
| | | | Russian | Spanish [Latin America] | Spanish [Spain] |
| Dutch | | | Effective: March 30, 2026. |
| English | | | |
| French | | | |
| German | | | |
| Hindi | | | |
| Hungarian | | | |
| Italian | | | |
| Japanese | | | |
| Korean | | | |
| Malay | | | |
| Polish | | | |
| Portuguese | | | |
| Russian | | | |
| Simplified Chinese | | | |
| Spanish | | |
| Effective: September 30, 2025 | | |
| If you are visually impaired, have another disability, or need support in other | | If you are visually impaired, have another disability, or need support in other |
| languages, you may access this Privacy Policy by emailing us at help@headspace.c | | languages, you may access this Privacy Policy by emailing us at help@headspace.c |
| om. | | om. |
| At Headspace, our company values include putting members first. We are committed | | At Headspace, our company values include putting members first. We are committed |
| to protecting and respecting your privacy in connection with your use of our co | | to protecting and respecting your privacy in connection with your use of our co |
| ntent and products via our websites, including www.headspace.com (“Websites”); o | | ntent and products via our websites, including www.headspace.com (“Websites”); o |
| ur applications, including the Headspace mobile app (“Apps”); or other delivery | | ur applications, including the Headspace mobile app (“Apps”); or other delivery |
| methods (Websites, Apps, and other delivery methods are collectively referred to | | methods (Websites, Apps, and other delivery methods are collectively referred to |
| as our “Products”). Headspace may deliver coaching services, psychotherapy serv | | as our “Products”). Headspace may deliver coaching services, psychotherapy serv |
| ices (i.e. therapy), and psychiatry services (collectively the “Services”) using | | ices (i.e. therapy), and psychiatry services (collectively the “Services”) using |
| the Products or via other delivery methods, as applicable. Headspace provides t | | the Products or via other delivery methods, as applicable. Headspace provides t |
| he Services through its affiliated medical providers and partners, including Hea | | he Services through its affiliated medical providers and partners, including Hea |
| dspace Medical Group (CA) P.C. (“Headspace Medical”) or third party medical prov | | dspace Medical Group (CA) P.C. (“Headspace Medical”) or third party medical prov |
| iders (Headspace Medical and these third party medical providers will be collect | | iders (Headspace Medical and these third party medical providers will be collect |
| ively referred to as our “Care Providers”). Throughout this Privacy Policy, we w | | ively referred to as our “Care Providers”). Throughout this Privacy Policy, we w |
| ill collectively refer to all of our Products and Services as our “Platform.” Th | | ill collectively refer to all of our Products and Services as our “Platform.” Th |
| is Privacy Policy covers the “personal information,” meaning information about a | | is Privacy Policy covers the “personal information,” meaning information about a |
| n identified or identifiable individual that is collected through our Product or | | n identified or identifiable individual that is collected through our Product or |
| Services. | | Services. |
| Depending on how you interact with us, the following may also apply to you: | | Depending on how you interact with us, the following may also apply to you: |
| n | Our Services are delivered by our Care Providers. For Care Providers in the US, | n | Our Services are delivered by our Care Providers. For Care Providers in the US, |
| they are classified as covered entities under the Health Insurance Portability a | | they are classified as covered entities under the Health Insurance Portability a |
| nd Accountability Act (HIPAA). Headspace is subject to HIPAA as our Care Provide | | nd Accountability Act (“HIPAA”). Headspace is subject to HIPAA as our Care Provi |
| rs’ business associate. Our Care Providers may provide you an additional privacy | | ders’ business associate. Our Care Providers may provide you an additional priva |
| notice during enrollment which we encourage you to review. For example, if you | | cy notice during enrollment which we encourage you to review. For example, if yo |
| receive Services from Headspace Medical, you can access their Notice of Privacy | | u receive Services from Headspace Medical, you can access their Notice of Privac |
| Practices here. If you are outside the US and use our international Care Provide | | y Practices here. If you are outside the US and use our international Care Provi |
| rs, you may still receive an additional privacy notice from them as relevant to | | ders, you may still receive an additional privacy notice from them as relevant t |
| the applicable law in your area. | | o the applicable law in your area. |
| Some components or features of our Platform may include additional privacy notic | | Some components or features of our Platform may include additional privacy notic |
| es, such as an optional feature that uses your personal information in a unique | | es, such as an optional feature that uses your personal information in a unique |
| way. Similarly, you may have been given access to our Product or Services in a m | | way. Similarly, you may have been given access to our Product or Services in a m |
| anner that includes additional terms or privacy notices such as from your employ | | anner that includes additional terms or privacy notices such as from your employ |
| er. The language of those terms and privacy notices supplement this Privacy Poli | | er. The language of those terms and privacy notices supplement this Privacy Poli |
| cy unless there is a conflict, in which case those additional terms and privacy | | cy unless there is a conflict, in which case those additional terms and privacy |
| notices will apply. | | notices will apply. |
| You may follow links contained in our Platform or provided to you by other users | | You may follow links contained in our Platform or provided to you by other users |
| to third-party websites or products not operated by us. This Privacy Policy doe | | to third-party websites or products not operated by us. This Privacy Policy doe |
| s not apply to third-party websites or products. We strongly suggest you review | | s not apply to third-party websites or products. We strongly suggest you review |
| their privacy policies to understand how your personal information is used and s | | their privacy policies to understand how your personal information is used and s |
| tored by those third parties. | | tored by those third parties. |
| n | Similar to the above point, you may use single sign-on (SSO) features to access | n | Similar to the above point, you may use single sign-on (“SSO”) features to acces |
| our Platform, such as through your social media accounts or through your employe | | s our Platform, such as through your social media accounts or through your emplo |
| r. That use may be subject to your SSO provider’s terms and privacy policies, an | | yer. Your use may be subject to your SSO provider’s terms and privacy policies, |
| d we encourage you to review them prior to using those features. | | and we encourage you to review them prior to using those features. |
| This privacy policy does not apply to Headspace employees or applicants to Heads | | This privacy policy does not apply to Headspace employees or applicants to Heads |
| pace. Applicants can learn about how we use their personal information by readin | | pace. Applicants can learn about how we use their personal information by readin |
| g our Applicant Privacy Notice here, and employees will be provided further deta | | g our Applicant Privacy Notice here, and employees will be provided further deta |
| ils as part of onboarding. | | ils as part of onboarding. |
| Please read the following carefully to understand our practices regarding your p | | Please read the following carefully to understand our practices regarding your p |
| ersonal information. We also encourage you to review our end-user terms and cond | | ersonal information. We also encourage you to review our end-user terms and cond |
| itions here. | | itions here. |
| Table of Contents | | Table of Contents |
| n | This Privacy Policy is provided in a layered format. We provided summaries for e | n | This Privacy Policy is provided in a layered format. You can jump to a specific |
| ach section, but we encourage you to read each section in detail. | | section by clicking or tapping on the section below. We provided summaries for e |
| | | ach section, but we encourage you to read each section in detail. |
| 1. | | |
| Collection of personal information | | 1. Collection of personal information |
| We may collect your personal information through our Platform, or when | | We may collect your personal information through our Platform, or when you other |
| | | wise share your information with us. Our collection may require your input or ca |
| | | n be automatically collected while you engage with us. |
| you otherwise share your information with us. Our collection may require | | |
| your input or can be automatically collected while you engage with us. | | |
| 2. | | |
| Use of personal information | | 2. Use of personal information |
| We primarily use your personal information for our Products and Websites | | We primarily use your personal information for our Products and Websites to func |
| | | tion and to deliver you the Services. We also may use your personal information |
| | | for other purposes like communicating to you about your interest in our Platform |
| | | , processing payments, complying with legal obligations, or to develop new featu |
| | | res or improvements. |
| to function and to deliver you the Services. We also may use your | | |
| personal information for other purposes like communicating to you about | | |
| your interest in our Platform, processing payments, complying with legal | | |
| obligations, or to develop new features or improvements. | | |
| 3. | | |
| Sharing of personal information | | 3. Sharing of personal information |
| We may share your personal information with certain third-party service | | We may share your personal information with certain third-party service provider |
| | | s to help make our Platform function. We may also share personal information as |
| | | directed by you, to provide you with opportunities we think may interest you, or |
| | | as legally required, such as to comply with a court order. |
| providers to help make our Platform function. We may also share personal | | |
| information as directed by you, to provide you with opportunities we | | |
| think may interest you, or as legally required, such as to comply with a | | |
| court order. | | |
| 4. | | |
| Data security and retention | | 4. Data security and retention |
| The security of your personal information is of utmost importance to us. | | The security of your personal information is of utmost importance to us. We reta |
| | | in your personal information for as long as necessary, and we maintain appropria |
| | | te safeguards to protect it. |
| We retain your personal information for as long as necessary, and we | | |
| maintain appropriate safeguards to protect it. | | |
| 5. | | |
| Your privacy rights | | 5. Your privacy rights |
| We want you to have choice in how your personal information is used. We | | We want you to have choice in how your personal information is used. We provide |
| | | you rights to request actions regarding your personal information including dele |
| | | tion, no matter where you reside. Further rights may be provided for your specif |
| | | ic jurisdiction, which are outlined in Section 10. |
| provide you rights to request actions regarding your personal | | |
| information including deletion, no matter where you reside. Further | | |
| rights may be provided for your specific jurisdiction, which are | | |
| outlined in Section 10. | | |
| 6. | | |
| Children's Privacy | | 6. Children’s Privacy |
| Our Platform is generally intended for adults, except in limited | | Our Platform is not intended for individuals under the age of 13 years old or th |
| | | e equivalent age in your jurisdiction. |
| circumstances depending on your offering. | | |
| 7.Cookies | | 7. Cookies |
| When you visit our Websites, we may collect certain information from you | | When you visit our Websites, we may collect certain information from you automat |
| | | ically through cookies and other tracking technologies. You can decide what cook |
| | | ies are deployed using the cookies settings on our Websites. |
| automatically through cookies and other tracking technologies. You can | | |
| decide what cookies are deployed using the cookies settings on our | | |
| Websites. | | |
| 8.Changes | | 8. Changes |
| We may change this Privacy Policy to reflect new services, changes in | | We may change this Privacy Policy to reflect new services, changes in our data p |
| | | ractices, or to comply with relevant laws. |
| our data practices, or to comply with relevant laws. | | |
| 9.Contact us | | 9. Contact us |
| You may contact us for comments, questions, or to exercise your privacy | | You may contact us for comments, questions, or to exercise your privacy rights i |
| | | n various ways including emailing help@headspace.com. |
| rights in various ways including emailing help@headspace.com | | |
| 10. | | |
| Supplemental notices | | 10. Supplemental notices |
| This section provides additional information specific to certain | | This section provides additional information specific to certain jurisdictions. |
| | | Please note, that our Platform is operated in the United States where your perso |
| | | nal information will be primarily processed and stored. |
| jurisdictions. Please note, that our Platform is operated in the United | | |
| States where your personal information will be primarily processed and | | |
| stored. | | |
| 1. Collection of personal information | | 1. Collection of personal information |
| We may collect or process the following personal information about you from what | | We may collect or process the following personal information about you from what |
| you provide us directly, what we receive from others, and personal information | | you provide us directly, what we receive from others, and personal information |
| we may automatically collect when you interact with our Platform. | | we may automatically collect when you interact with our Platform. |
| n | (a) Information you provide to us | n | a. Information you provide to us |
| Contact information and identifiers. When you use our Platform, we may ask you t | | Contact information and identifiers. When you use our Platform, we may ask you t |
| o provide certain contact information, including your first and last name and em | | o provide certain contact information, including your first and last name and em |
| ail address. We may also collect your social media identification number if you | | ail address. We may also collect your social media identification number if you |
| choose to access the Products via a social media account. | | choose to access the Products via a social media account. |
| Account Information. If you decide to set up an account with us, we may ask you | | Account Information. If you decide to set up an account with us, we may ask you |
| to provide certain additional contact information including, for example, your f | | to provide certain additional contact information including, for example, your f |
| irst and last name, e-mail address (personal and/or work), telephone number, mai | | irst and last name, e-mail address (personal and/or work), telephone number, mai |
| ling address, employer or company name, job title, student identification number | | ling address, employer or company name, job title, student identification number |
| , emergency contact information, as well as password and other authentication-re | | , emergency contact information, as well as password and other authentication-re |
| lated information. For individuals who participate in special subscriptions and | | lated information. For individuals who participate in special subscriptions and |
| features, including group plans, we may collect additional personal information, | | features, including group plans, we may collect additional personal information, |
| for example, home address and names and emails of household members. | | for example, home address and names and emails of household members. |
| Health information. We will collect the information you provide about your healt | | Health information. We will collect the information you provide about your healt |
| h and wellness as you use our Products or engage with the Services. You may prov | | h and wellness as you use our Products or engage with the Services. You may prov |
| ide this information through the Products, such as through survey responses abou | | ide this information through the Products, such as through survey responses abou |
| t your current mental or physical health status, setting your health or wellness | | t your current mental or physical health status, setting your health or wellness |
| goals, or in other inputs that relate to your health or wellbeing. You may also | | goals, or in other inputs that relate to your health or wellbeing. You may also |
| provide this type of information through the Services, such as talking with you | | provide this type of information through the Services, such as talking with you |
| r coach or therapist about your current health needs or during treatment. We und | | r coach or therapist about your current health needs or during treatment. We und |
| erstand that this information is very sensitive so we handle it with care, inclu | | erstand that this information is very sensitive so we handle it with care, inclu |
| ding treating this health information as protected health information under HIPA | | ding treating this health information as protected health information under HIPA |
| A where applicable. | | A where applicable. |
| Survey information. We may present you with surveys for Product functionality, t | | Survey information. We may present you with surveys for Product functionality, t |
| o provide you the Services, to provide you with information about our Products a | | o provide you the Services, to provide you with information about our Products a |
| nd Services that we think may be of interest to you, or for research purposes. T | | nd Services that we think may be of interest to you, or for research purposes. T |
| hese surveys may give you the opportunity to describe certain things about you, | | hese surveys may give you the opportunity to describe certain things about you, |
| your use of the Platform, or feedback on future improvements. | | your use of the Platform, or feedback on future improvements. |
| Communication information. When you send or respond to emails, messages, chats, | | Communication information. When you send or respond to emails, messages, chats, |
| or other communications from Headspace, we may collect your email address, name, | | or other communications from Headspace, we may collect your email address, name, |
| and any other personal information you choose to include in the body content of | | and any other personal information you choose to include in the body content of |
| your communications. In addition, when you interact with certain features of ou | | your communications. In addition, when you interact with certain features of ou |
| r Products, we may collect the content of those communications. | | r Products, we may collect the content of those communications. |
| Support information. When you submit a support request or otherwise engage with | | Support information. When you submit a support request or otherwise engage with |
| our support team, we collect the information you provide as part of that interac | | our support team, we collect the information you provide as part of that interac |
| tion. We also utilize live chat and/or chatbot technology, which allow you to co | | tion. We also utilize live chat and/or chatbot technology, which allow you to co |
| mmunicate directly with our automated customer service system and/or customer se | | mmunicate directly with our automated customer service system and/or customer se |
| rvice representatives via a chat window about our Products and Services. Text en | | rvice representatives via a chat window about our Products and Services. Text en |
| tered into this form prior to submission may be collected, retained, and used by | | tered into this form prior to submission may be collected, retained, and used by |
| Headspace for our business purposes, including by our customer service and othe | | Headspace for our business purposes, including by our customer service and othe |
| r personnel and service providers. | | r personnel and service providers. |
| n | (b) Information from others | n | b. Information from others |
| In certain circumstances, we may collect personal information about you from oth | | In certain circumstances, we may collect personal information about you from oth |
| ers. This may include the following: | | ers. This may include the following: |
| If you receive access to Headspace through your employer, health plan, or anothe | | If you receive access to Headspace through your employer, health plan, or anothe |
| r party that sponsors your access (your “Benefit Sponsor”), we collect your name | | r party that sponsors your access (your “Benefit Sponsor”), we collect your name |
| and email address and other information that your Benefit Sponsor submits to us | | and email address and other information that your Benefit Sponsor submits to us |
| to facilitate your enrollment in our Products and Services. | | to facilitate your enrollment in our Products and Services. |
| We may collect the name, email address, content engagement, and preferences of i | | We may collect the name, email address, content engagement, and preferences of i |
| ndividuals that our users identify through our sharing and referral features. We | | ndividuals that our users identify through our sharing and referral features. We |
| use this data for the sole purpose of sharing content and referring individuals | | use this data for the sole purpose of sharing content and referring individuals |
| to join the Products. | | to join the Products. |
| n | We may collect personal information from parents or guardians for operating acco | n | We may collect personal information from parents or guardians for operating acco |
| unts for their dependants aged 13-17 where supported. | | unts for their dependents aged 13-17 where supported. |
| If you choose to have your account verified to confirm your eligibility for a se | | If you choose to have your account verified to confirm your eligibility for a se |
| lect subscription offering, we may allow a third party platform to access the sp | | lect subscription offering, we may allow a third party platform to access the sp |
| ecific personal information you provide in order to perform the verification. An | | ecific personal information you provide in order to perform the verification. An |
| y failure to provide sufficient information or any response Headspace considers | | y failure to provide sufficient information or any response Headspace considers |
| abnormal may result in Headspace refusing (or being unable) to verify your eligi | | abnormal may result in Headspace refusing (or being unable) to verify your eligi |
| bility. | | bility. |
| n | (c) Information we automatically collect | n | c. Information we automatically collect |
| Our Products and Websites may collect information from you automatically during | | Our Products and Websites may collect information from you automatically during |
| your use which may include: | | your use which may include: |
| Browser and device data, such as IP address, device identifier, device type, ope | | Browser and device data, such as IP address, device identifier, device type, ope |
| rating system and Internet browser type, screen resolution, operating system nam | | rating system and Internet browser type, screen resolution, operating system nam |
| e and version, device manufacturer and model, language, plug-ins, add-ons, and t | | e and version, device manufacturer and model, language, plug-ins, add-ons, and t |
| he language version of the Websites and Products you are visiting. | | he language version of the Websites and Products you are visiting. |
| Usage data, such as time spent on the Products and Websites including pages visi | | Usage data, such as time spent on the Products and Websites including pages visi |
| ted, links clicked, approximate location, language preferences, performance of f | | ted, links clicked, approximate location, language preferences, performance of f |
| eatures, patterns of use, and the pages that led or referred you to our Products | | eatures, patterns of use, and the pages that led or referred you to our Products |
| and Websites. | | and Websites. |
| n | (d) Aggregated, anonymous, and de-identified data | n | d. Aggregated, anonymous, and de-identified data |
| We may create or collect aggregated, anonymous, or de-identified data from perso | | We may create or collect aggregated, anonymous, or de-identified data from perso |
| nal information by removing, masking, or otherwise altering data components that | | nal information by removing, masking, or otherwise altering data components that |
| make the data personally identifiable, or potentially personally identifiable t | | make the data personally identifiable, or potentially personally identifiable t |
| o you (“De-Identified Data”). We will maintain De-Identified Data in its deident | | o you (“De-Identified Data”). We will maintain De-Identified Data in its deident |
| ified form and not attempt to reidentify it except when testing our de-identific | | ified form and not attempt to reidentify it except when testing our de-identific |
| ation practices. De-Identified Data is not personal information and is not subje | | ation practices. De-Identified Data is not personal information and is not subje |
| ct to this Privacy Policy. | | ct to this Privacy Policy. |
| 2. Use of personal information | | 2. Use of personal information |
| We may use your personal information in the following ways: | | We may use your personal information in the following ways: |
| n | To provide our Platform, including the delivery of content and interactive featu | n | To provide our Platform, including the delivery of content, interactive features |
| res; | | , and tailoring your experience to you; |
| To communicate with you regarding our Platform including updates or changes; | | To communicate with you regarding our Platform including updates or changes; |
| To provide you support, answer your questions or requests for information, or ha | | To provide you support, answer your questions or requests for information, or ha |
| ndle your complaints; | | ndle your complaints; |
| n | | n | To determine the availability of certain features of services for you; |
| To process payment, manage your orders, and account for applicable sales taxes; | | To process payment, manage your orders, and account for applicable sales taxes; |
| To inform your Benefit Sponsor, if you have one, about your registration and oth | | To inform your Benefit Sponsor, if you have one, about your registration and oth |
| er information as described in Section 3 below; | | er information as described in Section 3 below; |
| To fulfill our obligations under any agreements that we may have with you; | | To fulfill our obligations under any agreements that we may have with you; |
| To personalize the advertisements you receive about our Platform through third-p | | To personalize the advertisements you receive about our Platform through third-p |
| arty platforms, on other websites and apps; | | arty platforms, on other websites and apps; |
| To protect ourselves, you and others such as by taking actions to prevent fraud | | To protect ourselves, you and others such as by taking actions to prevent fraud |
| and other unlawful or unauthorized activity, and creating and maintaining a trus | | and other unlawful or unauthorized activity, and creating and maintaining a trus |
| ted, secure, and reliable online environment; and | | ted, secure, and reliable online environment; and |
| To comply with our legal obligations including meeting regulatory compliance obl | | To comply with our legal obligations including meeting regulatory compliance obl |
| igations, responding to subpoenas, court orders or other legal processes; and | | igations, responding to subpoenas, court orders or other legal processes; and |
| n | to establish or exercise our legal rights or defense against legal claims. | n | To establish or exercise our legal rights or defense against legal claims. |
| AI Features. We use artificial intelligence (AI) which means a machine-based sys | | AI Features. We use artificial intelligence (AI) which means a machine-based sys |
| tem that is designed to operate on varying levels of autonomy to infer from the | | tem that is designed to operate on varying levels of autonomy to infer from the |
| input it receives to generate outputs that can influence physical or virtual env | | input it receives to generate outputs that can influence physical or virtual env |
| ironments. Much of our AI use is behind the scenes, such as in our security moni | | ironments. Much of our AI use is behind the scenes, such as in our security moni |
| toring of our infrastructure, our content recommendation system, and for quality | | toring of our infrastructure, our content recommendation system, and for quality |
| assurance. In other instances, we may develop features in our Products where yo | | assurance. In other instances, we may develop features in our Products where yo |
| u interact with AI directly (“AI Feature”), such as when you reflect with Ebb. B | | u interact with AI directly (“AI Feature”), such as when you reflect with Ebb. B |
| efore you use or activate an AI Feature, we will let you know that you will be i | | efore you use or activate an AI Feature, we will let you know that you will be i |
| nteracting with AI and give you the choice of whether to do so. To learn more ab | | nteracting with AI and give you the choice of whether to do so. Learn more about |
| out our approach to using AI, go here. | | our approach to using AI here. |
| 3. Sharing of personal information | | 3. Sharing of personal information |
| We may disclose your personal information with the following categories of third | | We may disclose your personal information with the following categories of third |
| parties: | | parties: |
| n | Our service providers. In some circumstances we may need to disclose your person | n | Our service providers. In some circumstances we may need to disclose your person |
| al information to a third party so that they can provide a service on our behalf | | al information to a third party so that they can provide a service on our behalf |
| , such as to help deliver Products or Services that you have requested. These se | | , such as to help deliver Products or Services that you have requested. These se |
| rvice providers may include services such as analytics, payment processing, adve | | rvice providers may include services such as analytics, payment processing, adve |
| rtising and marketing, website hosting, customer and technical support, and othe | | rtising and marketing, website hosting, customer and technical support, and othe |
| r services. Our service providers have access to your personal information only | | r services. |
| to perform these tasks on our behalf, based on our instructions and are contract | | |
| ually obligated to maintain the confidentiality and security of your personal in | | |
| formation, and to not disclose or use your personal information for any other pu | | |
| rpose inconsistent with this Privacy Policy and applicable law. | | |
| | | Our service providers have access to your personal information only to perform t |
| | | hese tasks on our behalf, based on our instructions and are contractually obliga |
| | | ted to maintain the confidentiality and security of your personal information, a |
| | | nd to not disclose or use your personal information for any other purpose incons |
| | | istent with this Privacy Policy and applicable law. |
| Your integrations. You may connect your account through supported integrations w | | Your integrations. You may connect your account through supported integrations w |
| ith third parties and we will share your personal information with those third p | | ith third parties and we will share your personal information with those third p |
| arties. If you do connect an integration, that third party’s terms and privacy p | | arties. If you do connect an integration, that third party’s terms and privacy p |
| olicy may apply to the personal information shared as a result and we encourage | | olicy may apply to the personal information shared as a result and we encourage |
| you to review those before setting up the integration. For example, if you are o | | you to review those before setting up the integration. For example, if you are o |
| n iOS, you may connect our Products to Apple’s Health Kit. If you do, iOS Privac | | n iOS, you may connect our Products to Apple’s Health Kit. If you do, iOS Privac |
| y Policy and Terms of Use apply, and can be reviewed at www.apple.com/legal/priv | | y Policy and Terms of Use apply, and can be reviewed at www.apple.com/legal/priv |
| acy. | | acy. |
| Community Activity. If you engage with other Platform users using our community | | Community Activity. If you engage with other Platform users using our community |
| features, we will share some information about you such as your name associated | | features, we will share some information about you such as your name associated |
| with your comment on a forum or other information you choose to share with other | | with your comment on a forum or other information you choose to share with other |
| users. | | users. |
| Your Benefit Sponsor. In limited cases, we may provide certain personal informat | | Your Benefit Sponsor. In limited cases, we may provide certain personal informat |
| ion to your Benefit Sponsor, including your name, email address, your registrati | | ion to your Benefit Sponsor, including your name, email address, your registrati |
| on date, and the date on which you last used our Platform. Generally, we restric | | on date, and the date on which you last used our Platform. Generally, we restric |
| t this sharing to not include specific details of your in-app activity or any de | | t this sharing to not include specific details of your in-app activity or any de |
| tails about your use of Services, like therapy. This restriction may not apply w | | tails about your use of Services, like therapy. This restriction may not apply w |
| here sharing some of your activity is necessary for your treatment, payment, or | | here sharing some of your activity is necessary for your treatment, payment, or |
| healthcare operations such as if your Benefit Sponsor is your other healthcare p | | healthcare operations such as if your Benefit Sponsor is your other healthcare p |
| rovider, health insurance provider, or health plan. | | rovider, health insurance provider, or health plan. |
| Upon receiving your request, we may ask for additional information from you in o | | Upon receiving your request, we may ask for additional information from you in o |
| rder to verify the request or confirm how you would like to proceed. We endeavor | | rder to verify the request or confirm how you would like to proceed. We endeavor |
| to respond to a verifiable request without undue delay. If we require an extend | | to respond to a verifiable request without undue delay. If we require an extend |
| ed amount of time, we will inform you using the email associated with your accou | | ed amount of time, we will inform you using the email associated with your accou |
| nt or the email you used to make the request. | | nt or the email you used to make the request. |
| We do not charge a fee to process your verifiable request unless it is excessive | | We do not charge a fee to process your verifiable request unless it is excessive |
| , repetitive, or clearly unfounded. If we determine that your request requires a | | , repetitive, or clearly unfounded. If we determine that your request requires a |
| fee, we will tell you why and provide you with a cost estimate before completin | | fee, we will tell you why and provide you with a cost estimate before completin |
| g your request. | | g your request. |
| Your rights are not absolute, and exceptions may apply. These exceptions can ari | | Your rights are not absolute, and exceptions may apply. These exceptions can ari |
| se from different factors including our legal obligations, the rights of others, | | se from different factors including our legal obligations, the rights of others, |
| your or another’s safety, and our ability to bring or defend against legal clai | | your or another’s safety, and our ability to bring or defend against legal clai |
| ms. Additionally, we will not fulfill your request if you do not provide suffici | | ms. Additionally, we will not fulfill your request if you do not provide suffici |
| ent information to verify your identity or to verify that a third party making t | | ent information to verify your identity or to verify that a third party making t |
| he request is authorized to act as your representative. | | he request is authorized to act as your representative. |
| n | Some US jurisdictions provide residents with certain rights with respect to thei | n | Some US jurisdictions provide residents with certain rights with respect to thei |
| r personal information as defined under applicable law. These rights are subject | | r personal information as defined under applicable law. These rights are subject |
| to the specific laws of that jurisdiction and that certain other rights might a | | to the specific laws of that jurisdiction and that certain other rights might a |
| pply. Please review our Supplemental Notices, including our Privacy Notice for E | | pply. Please review our Supplemental Notices, including our Privacy Notice for E |
| U and UK, our Privacy Notice for California, and our Privacy Notice for Virginia | | U and UK, our Privacy Notice for California, and our Privacy Notice for other US |
| , Connecticut, Colorado, Utah, and Nevada for more information on rights and ter | | states for more information on rights and terms specific to your location or pl |
| ms specific to your location or place of residence. | | ace of residence. |
| 6. Children’s privacy | | 6. Children’s privacy |
| n | At Headspace, we are committed to protecting and respecting children’s privacy. | n | At Headspace, we are committed to protecting and respecting children’s privacy. |
| Our Platform is generally intended for individuals at least 18 years old and we | | Our Platform is not intended for individuals below 13 years old or the equivalen |
| do not intentionally collect personal information from individuals under 18 year | | t age in your jurisdiction. We do not intentionally collect personal information |
| s old. There are limited exceptions: | | from individuals under that age. There is a limited exception if you are a pare |
| | | nt under a supported employee assistance program (EAP), you may refer your child |
| | | of at least 6 years old to our Care Providers for in-person care but cannot cre |
| | | ate an app account for them. |
| If you are in the US and participate in our Headspace for Teens offering or thro | | |
| ugh certain Benefit Sponsors’ offerings, you may register an account as long as | | |
| you are at least 13 years old. | | |
| If you are a US user 13 to 17 years old who may have joined as noted above, you | | |
| may enroll in the Services with verifiable parent or guardian consent. | | |
| If you are a parent under our employee assistance program (EAP), you may refer y | | |
| our child of at least 6 years old to our Care Providers for in-person care but c | | |
| annot create an app account for them. | | |
| You also may notice some content in our Products that appears geared towards chi | | |
| ldren. This content is only meant for you to share with your child under your su | | |
| pervision, and does not require or allow your child to create an app account. | | |
| If you are a parent or guardian and you are aware that a child under age 13 has | | If you are a parent or guardian and you are aware that a child under age 13, or |
| provided us with their personal information without parental consent, please con | | equivalent age in your jurisdiction, has provided us with their personal informa |
| tact us at help@headspace.com and we will take steps to remove that personal inf | | tion without parental consent, please contact us at help@headspace.com and we wi |
| ormation from our servers. | | ll take steps to remove that personal information from our servers. |
| 7. Cookies | | 7. Cookies |
| When you visit our Websites, we may collect information from you automatically t | | When you visit our Websites, we may collect information from you automatically t |
| hrough cookies including cookies provided by third parties. We use cookies and t | | hrough cookies including cookies provided by third parties. We use cookies and t |
| he information they collect for a variety of purposes including functionality, a | | he information they collect for a variety of purposes including functionality, a |
| nalyzing performance, security, personalizing Website content, and advertising. | | nalyzing performance, security, personalizing Website content, and advertising. |
| We will get your consent in order to use such trackers or provide you with the o | | We will get your consent in order to use such trackers or provide you with the o |
| pportunity to opt-out of cookies, to the extent required by applicable law. You | | pportunity to opt-out of cookies, to the extent required by applicable law. You |
| may use an opt-out preference signal, such as the Global Privacy Control (GPC), | | may use an opt-out preference signal, such as the Global Privacy Control (GPC), |
| to opt-out of the sale/sharing of your personal information. For more informatio | | to opt-out of the sale/sharing of your personal information. For more informatio |
| n on the types of cookies we use and your choices regarding them, please review | | n on the types of cookies we use and your choices regarding them, please review |
| our Cookie Policy. | | our Cookie Policy. |
| 8. Changes | | 8. Changes |
| We want to hear from you if you have questions, concerns, or requests regarding | | We want to hear from you if you have questions, concerns, or requests regarding |
| this Privacy Policy. You can reach us by emailing help@headspace.com or calling | | this Privacy Policy. You can reach us by emailing help@headspace.com or calling |
| 855.432.3822. | | 855.432.3822. |
| 10. Supplemental notices | | 10. Supplemental notices |
| Depending on your jurisdiction, you have additional rights that apply to you und | | Depending on your jurisdiction, you have additional rights that apply to you und |
| er your jurisdiction's privacy laws. We provide the supplemental information in | | er your jurisdiction's privacy laws. We provide the supplemental information in |
| this section in our efforts to comply with those additional privacy laws and inf | | this section in our efforts to comply with those additional privacy laws and inf |
| orm you about your rights. If you do not see your jurisdiction below please do n | | orm you about your rights. If you do not see your jurisdiction below please do n |
| ot interpret that to mean that we do not respect your privacy and we encourage y | | ot interpret that to mean that we do not respect your privacy and we encourage y |
| ou to still contact us using the contact details above with your questions or co | | ou to still contact us using the contact details above with your questions or co |
| ncerns. Please note that Headspace is a US based company and your personal infor | | ncerns. Please note that Headspace is a US based company and your personal infor |
| mation will be stored within the US. | | mation will be stored within the US. |
| n | (a) Privacy Notice for EU and the UK | n | a. Privacy Notice for EU and the UK |
| Data Transfers. This section is for individuals in the European Union (EU), the | | Data Transfers. This section is for individuals in the European Union (EU), the |
| United Kingdom (UK), and Switzerland. Headspace operates as a data controller un | | United Kingdom (UK), and Switzerland. Headspace operates as a data controller un |
| der the General Data Protection Regulation (GDPR) for the majority of the person | | der the General Data Protection Regulation (GDPR) for the majority of the person |
| al information detailed in section 1 and as a data processor for the limited per | | al information detailed in section 1 and as a data processor for the limited per |
| sonal information we may receive from your Benefit Sponsor. | | sonal information we may receive from your Benefit Sponsor. |
| Headspace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK | | Headspace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK |
| Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss- | | Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss- |
| U.S. DPF) as set forth by the U.S. Department of Commerce. Headspace has certifi | | U.S. DPF) as set forth by the U.S. Department of Commerce. Headspace has certifi |
| ed to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privac | | ed to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privac |
| y Framework Principles (EU-U.S. DPF Principles) with regard to the processing of | | y Framework Principles (EU-U.S. DPF Principles) with regard to the processing of |
| personal data received from the European Union in reliance on the EU-U.S. DPF a | | personal data received from the European Union in reliance on the EU-U.S. DPF a |
| nd from the United Kingdom (and Gibraltar) in reliance on the UK Extension to th | | nd from the United Kingdom (and Gibraltar) in reliance on the UK Extension to th |
| e EU-U.S. DPF. Headspace has certified to the U.S. Department of Commerce that i | | e EU-U.S. DPF. Headspace has certified to the U.S. Department of Commerce that i |
| t adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Pr | | t adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Pr |
| inciples) with regard to the processing of personal data received from Switzerla | | inciples) with regard to the processing of personal data received from Switzerla |
| nd in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms | | nd in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms |
| in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF | | in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF |
| Principles, the Principles shall govern. To learn more about the Data Privacy F | | Principles, the Principles shall govern. To learn more about the Data Privacy F |
| ramework (DPF) program, and to view our certification, please visit https://www. | | ramework (DPF) program, and to view our certification, please visit https://www. |
| dataprivacyframework.gov/. | | dataprivacyframework.gov/. |
| The following entities are included under Headspace’s DPF certification and adhe | | The following entities are included under Headspace’s DPF certification and adhe |
| re to the EU-U.S. DPF Principles, its UK Extension, and the Swiss-U.S. DPF Princ | | re to the EU-U.S. DPF Principles, its UK Extension, and the Swiss-U.S. DPF Princ |
| iples: | | iples: |
| Right not to be subject to automated decision making - You have the right not to | | Right not to be subject to automated decision making - You have the right not to |
| be subject to a decision based solely on automated processing. Please know that | | be subject to a decision based solely on automated processing. Please know that |
| we do not currently make decisions about you in this manner. | | we do not currently make decisions about you in this manner. |
| Right to lodge a complaint - You may also have the right to lodge a complaint ab | | Right to lodge a complaint - You may also have the right to lodge a complaint ab |
| out our data collection and processing actions with the appropriate supervisory | | out our data collection and processing actions with the appropriate supervisory |
| authority. If you are in the EU, you can view the contact information for your d | | authority. If you are in the EU, you can view the contact information for your d |
| ata protection authority here. If you are in the UK, please visit this page. We | | ata protection authority here. If you are in the UK, please visit this page. We |
| ask that you contact us first to see if we can resolve your issue. | | ask that you contact us first to see if we can resolve your issue. |
| Exceptions may still apply as described in Section 5. | | Exceptions may still apply as described in Section 5. |
| n | Representatives: Individuals and the data protection supervisory authorities in | n | Representatives. Individuals and the data protection supervisory authorities in |
| the EU/EEA and individuals and the data protection supervisory authority (“ICO”) | | the EU/EEA and individuals and the data protection supervisory authority (“ICO”) |
| in the UK may also contact our data protection representatives according to Art | | in the UK may also contact our data protection representatives according to Art |
| icle 27 GDPR: | | icle 27 GDPR: |
| EU: DP-Dock GmbH, Attn.: Headspace, Inc., Ballindamm 39, 20095 Hamburg, Germany | | EU: DP-Dock GmbH, Attn.: Headspace, Inc., Ballindamm 39, 20095 Hamburg, Germany |
| UK: DP Data Protection Services UK Ltd., Attn.: Headspace, Inc., 16 Great Queen | | UK: DP Data Protection Services UK Ltd., Attn.: Headspace, Inc., 16 Great Queen |
| Street, Covent Garden, London, WC2B 5AH, United Kingdom | | Street, Covent Garden, London, WC2B 5AH, United Kingdom |
| www.dp-dock.com | | www.dp-dock.com |
| headspace@gdpr-rep.com | | headspace@gdpr-rep.com |
| Our data protection officer can be reached at privacy@headspace.com. | | Our data protection officer can be reached at privacy@headspace.com. |
| n | (b) Privacy Notice for California | n | b. Privacy Notice for California |
| We include this section for residents of California in order to comply with the | | We include this section for residents of California in order to comply with the |
| California Consumer Privacy Act of 2018, and its amendment, the California Priva | | California Consumer Privacy Act of 2018, and its amendment, the California Priva |
| cy Rights Act of 2020 (together, the “CCPA”). This section is intended to comply | | cy Rights Act of 2020 (together, the “CCPA”). This section is intended to comply |
| with the CCPA by supplementing the information provided elsewhere in the Privac | | with the CCPA by supplementing the information provided elsewhere in the Privac |
| y Policy. | | y Policy. |
| Categories of personal information. The CCPA includes categories of personal inf | | Categories of personal information. The CCPA includes categories of personal inf |
| ormation that businesses like us are required to identify to you which of them w | | ormation that businesses like us are required to identify to you which of them w |
| e have collected from you. To comply with those requirements, we have provided t | | e have collected from you. To comply with those requirements, we have provided t |
| he table below disclosing the categories of personal information we have collect | | he table below disclosing the categories of personal information we have collect |
| ed through our Platform within the last twelve (12) months. | | ed through our Platform within the last twelve (12) months. |
| Headspace is not a data broker and does not sell your personal information to th | | Headspace is not a data broker and does not sell your personal information to th |
| ird parties for payment. However, as with many online companies, Headspace partn | | ird parties for payment. However, as with many online companies, Headspace partn |
| ers with third parties to manage our advertising on other platforms. For that pu | | ers with third parties to manage our advertising on other platforms. For that pu |
| rpose, we may disclose limited personal information to third parties for our cro | | rpose, we may disclose limited personal information to third parties for our cro |
| ss-context behavioral and targeted advertising purposes and this activity may fa | | ss-context behavioral and targeted advertising purposes and this activity may fa |
| ll under broader concepts of “selling” and/or “sharing” under the CCPA. We have | | ll under broader concepts of “selling” and/or “sharing” under the CCPA. We have |
| noted in the table below what categories we have “sold” and/or “shared” in the l | | noted in the table below what categories we have “sold” and/or “shared” in the l |
| ast twelve (12) months. Please review the section below the table about your pri | | ast twelve (12) months. Please review the section below the table about your pri |
| vacy rights for more information on how to opt-out of this activity. | | vacy rights for more information on how to opt-out of this activity. |
| n | CATEGORYCOLLECTED | n | CATEGORY |
| | | COLLECTED |
| “SOLD” / “SHARED” | | “SOLD” / “SHARED” |
| A. Identifiers. | | A. Identifiers. |
| n | Name, alias, mailing address, unique personal identifier, online | n | Name, alias, mailing address, unique personal identifier, online identifier, IP |
| | | address, email (personal and/or work), account name, telephone number, password, |
| | | account credentials, National Provider Identifier (NPI), driver’s license / gov |
| | | ernment ID number (if provided for identity verification), or other similar iden |
| | | tifiers |
| identifier, IP address, email (personal and/or work), account name, | | |
| telephone number, password, account credentials, National Provider | | |
| Identifier (NPI), driver’s license / government ID number (if provided | | |
| for identity verification), or other similar identifiers | | |
| Yes | | Yes |
| Yes | | Yes |
| n | email, online identifier, personal unique identifier, IP | n | email, online identifier, personal unique identifier, IP address |
| address | | B. Personal information categories listed in the California Customer Records sta |
| | | tute (Cal. Civ. Code § 1798.80(e)). |
| B. Personal information categories listed in the California Customer | | Name, signature, mailing address, telephone number, driver’s license / governmen |
| | | t ID number (if provided for identity verification), payment card number, employ |
| | | ment, employment history, bank account information, medical information, and hea |
| | | lth insurance information |
| Records statute (Cal. Civ. Code § 1798.80(e)). | | |
| Name, signature, mailing address, telephone number, driver’s license | | |
| / government ID number (if provided for identity verification), | | |
| payment card number, employment, employment history, bank account | | |
| information, medical information, and health insurance | | |
| information | | |
| Yes | | Yes |
| Yes | | Yes |
| email | | email |
| n | C. Protected classification characteristics under California or | n | C. Protected classification characteristics under California or federal law. |
| federal law. | | Age (40 years or older), race, color, ancestry, national origin, citizenship, re |
| | | ligion or creed, marital status, medical condition, physical or mental disabilit |
| | | y, sex (including gender, gender identity, gender expression, pregnancy or child |
| | | birth and related medical conditions), sexual orientation, veteran or military s |
| | | tatus |
| Age (40 years or older), race, color, ancestry, national origin, | | |
| citizenship, religion or creed, marital status, medical condition, | | |
| physical or mental disability, sex (including gender, gender identity, | | |
| gender expression, pregnancy or childbirth and related medical | | |
| conditions), sexual orientation, veteran or military status | | |
| YesNo | | Yes |
| | | No |
| D. Commercial information. | | D. Commercial information. |
| n | Payment history, balances, Products or Services purchased or | n | Payment history, balances, Products or Services purchased or considered |
| considered | | |
| Yes | | Yes |
| Yes | | Yes |
| Products or Services purchased or considered | | Products or Services purchased or considered |
| E. Biometric information. | | E. Biometric information. |
| Sleep, health, or exercise data | | Sleep, health, or exercise data |
| n | YesNo | n | Yes |
| | | No |
| F. Internet or other similar network activity. | | F. Internet or other similar network activity. |
| n | Browsing history, search history, information on how you interact | n | Browsing history, search history, information on how you interact with our websi |
| | | te |
| with our website | | |
| Yes | | Yes |
| Yes | | Yes |
| n | Browsing history, information on how you interact with our | n | Browsing history, information on how you interact with our website |
| website | | |
| G. Geolocation data. | | G. Geolocation data. |
| Approximate location based on information like IP address | | Approximate location based on information like IP address |
| n | YesNo | n | Yes |
| | | No |
| H. Sensory data. | | H. Sensory data. |
| Audio recordings, voicemails, photographs | | Audio recordings, voicemails, photographs |
| n | YesNo | n | Yes |
| | | No |
| I. Professional or employment-related information. | | I. Professional or employment-related information. |
| Employer, job title or role, work contact information | | Employer, job title or role, work contact information |
| n | YesNo | n | Yes |
| J. Non-public education information (per the Family Educational | | No |
| Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part | | J. Non-public education information (per the Family Educational Rights and Priva |
| | | cy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
| 99)). | | |
| Student identification number | | Student identification number |
| n | YesNo | n | Yes |
| | | No |
| K. Inferences drawn from other personal information. | | K. Inferences drawn from other personal information. |
| n | Profile reflecting a person's preferences, characteristics, | n | Profile reflecting a person's preferences, characteristics, psychological trends |
| | | , predispositions, behavior, attitudes, intelligence, abilities, age and aptitud |
| | | es |
| psychological trends, predispositions, behavior, attitudes, | | |
| intelligence, abilities, and aptitudes | | |
| YesNo | | Yes |
| | | No |
| L. Sensitive personal information. | | L. Sensitive personal information. |
| n | Password, health information, payment information, racial and/or | n | Password, health information, payment information, racial and/or ethnic origin, |
| | | information concerning your sexual orientation, and gender identity |
| ethnic origin, information concerning your sexual orientation, and | | |
| gender identity | | |
| YesNo | | Yes |
| | | No |
| Please note that because of the overlapping nature of certain categories identif | | Please note that because of the overlapping nature of certain categories identif |
| ied above, some of the personal information we collect may be reasonably classif | | ied above, some of the personal information we collect may be reasonably classif |
| ied under multiple categories. Please also note that some of this personal infor | | ied under multiple categories. Please also note that some of this personal infor |
| mation, especially in regards to the Products and Services, may be covered by fe | | mation, especially in regards to the Products and Services, may be covered by fe |
| deral laws like HIPAA. | | deral laws like HIPAA. |
| Use of personal information. We may use your personal information in the followi | | Use of personal information. We may use your personal information in the followi |
| ng ways: | | ng ways: |
| To provide our Platform, including the delivery of content and interactive featu | | To provide our Platform, including the delivery of content and interactive featu |
| res; | | res; |
| Right to opt out of sale and/or sharing. You have the right to opt-out of the sa | | Right to opt out of sale and/or sharing. You have the right to opt-out of the sa |
| le and/or sharing of your personal information by a business. Please see our Not | | le and/or sharing of your personal information by a business. Please see our Not |
| ice of Right to Opt-Out below for more information. | | ice of Right to Opt-Out below for more information. |
| Right to limit use and disclosure. You have the right to limit the use or disclo | | Right to limit use and disclosure. You have the right to limit the use or disclo |
| sure of your sensitive personal information to only the uses necessary for us to | | sure of your sensitive personal information to only the uses necessary for us to |
| provide goods or services to you. We will not use or disclose your sensitive pe | | provide goods or services to you. We will not use or disclose your sensitive pe |
| rsonal information after you have exercised your right unless you subsequently p | | rsonal information after you have exercised your right unless you subsequently p |
| rovide consent for the use of your sensitive personal information for additional | | rovide consent for the use of your sensitive personal information for additional |
| purposes. | | purposes. |
| Sharing with third parties for their own direct marketing purposes. Headspace do | | Sharing with third parties for their own direct marketing purposes. Headspace do |
| es not disclose personal information to third parties for their own direct marke | | es not disclose personal information to third parties for their own direct marke |
| ting purposes. However, California residents additionally have the right to requ | | ting purposes. However, California residents additionally have the right to requ |
| est information regarding such practices under California’s “Shine the Light” la | | est information regarding such practices under California’s “Shine the Light” la |
| w. If you are a California resident and would like to inquire further, please em | | w. If you are a California resident and would like to inquire further, please em |
| ail help@headspace.com. | | ail help@headspace.com. |
| n | Notice of right to Opt-Out. | n | Notice of right to Opt-Out. As mentioned above, if you are a resident of Califor |
| | | nia, Headspace “sells” and “shares” personal information under the CCPA’s broade |
| | | r definition of “sale” or “share.” California law provides you a right to opt-ou |
| | | t of such “sales” and “shares.” You may exercise this right by following this li |
| | | nk and, if you are an Apps user, by going to the My Data page here or within you |
| | | r mobile app settings. The opt-out link is also available our Website’s pages by |
| | | clicking on the Your Privacy Choices link. |
| As mentioned above, if you are a resident of California, Headspace “sells” and “ | | |
| shares” personal information under the CCPA’s broader definition of “sale” or “s | | |
| hare.” California law provides you a right to opt-out of such “sales” and “share | | |
| s.”. You may exercise this right by following this link and, if you are an Apps | | |
| user, by going to the My Data page here or within your mobile app settings. The | | |
| opt-out link is also available our Website’s pages by clicking on the Your Priva | | |
| cy Choices link. | | |
| (c) Privacy Notice for other US states | | c. Privacy Notice for other US states |
| We include this section for residents of other US states with privacy laws that | | We include this section for residents of other US states with privacy laws that |
| may impact them. These privacy laws include the Virginia Consumer Data Privacy A | | may impact them. These privacy laws include the Virginia Consumer Data Privacy A |
| ct (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Priv | | ct (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Priv |
| acy Act (“UCPA”), the Colorado Privacy Act (“CPA”), and the Nevada Privacy Law ( | | acy Act (“UCPA”), the Colorado Privacy Act (“CPA”), the Delaware Personal Data P |
| “NPL”), the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPA”) | | rivacy Act (“DPDPA”), the Kentucky Consumer Data Protection Act (“KCDPA”), the M |
| , the Minnesota Consumer Data Privacy Act (“MCDPA”), and the Oregon Consumer Pri | | aryland Online Data Privacy Act (“MODPA”), the Nevada Privacy Law (“NPL”), the R |
| vacy Act (“OCPA”). This section is intended to comply with these laws by supplem | | hode Island Data Transparency and Privacy Protection Act (“RIDTPA”), the Minneso |
| enting the information provided elsewhere in the Privacy Policy. | | ta Consumer Data Privacy Act (“MCDPA”), and the Oregon Consumer Privacy Act (“OC |
| | | PA”). This section is intended to comply with these laws by supplementing the in |
| | | formation provided elsewhere in the Privacy Policy. |
| Collection of personal information. Headspace may collect the personal informati | | Collection of personal information. Headspace may collect the personal informati |
| on described in Section 1 and as categorized in the table within Section 10(b) a | | on described in Section 1 and as categorized in the table within Section 10(b) a |
| bove. Please note that some of this personal information will be considered sens | | bove. Please note that some of this personal information will be considered sens |
| itive under your state’s legal definition which can vary across different states | | itive under your state’s legal definition which can vary across different states |
| . The personal information we may collect depending on how you use our Platform | | . The personal information we may collect depending on how you use our Platform |
| includes mental or physical health information, racial or ethnic origin, and inf | | includes mental or physical health information, racial or ethnic origin, and inf |
| ormation about sexual orientation or gender identity. | | ormation about sexual orientation or gender identity. |
| Use of personal information. Headspace may collect, use, or disclose personal in | | Use of personal information. Headspace may collect, use, or disclose personal in |
| formation about US state residents for purposes listed in Section 2 of our Priva | | formation about US state residents for purposes listed in Section 2 of our Priva |
| cy Policy. We use sensitive personal information for the same purposes except fo | | cy Policy. We use sensitive personal information for the same purposes except fo |
| r personalizing ads. | | r personalizing ads. |
| Disclosure of personal information. We may disclose your personal information to | | Disclosure of personal information. We may disclose your personal information to |
| the categories of service providers and third parties identified in Section 3 o | | the categories of service providers and third parties identified in Section 3 o |
| f this Privacy Policy, and in ways that are described in that section. | | f this Privacy Policy, and in ways that are described in that section. |
| Your privacy rights. We generally provide the privacy rights described in Sectio | | Your privacy rights. We generally provide the privacy rights described in Sectio |
| n 5 above to you regardless of your location. Your state may afford you addition | | n 5 above to you regardless of your location. Your state may afford you addition |
| al privacy rights as noted below. To exercise your right, see the contact inform | | al privacy rights as noted below. To exercise your right, see the contact inform |
| ation in Section 9 or follow the instructions below for specific state rights. W | | ation in Section 9 or follow the instructions below for specific state rights. W |
| e will respond to your verifiable request within the time limit afforded under a | | e will respond to your verifiable request within the time limit afforded under a |
| pplicable law. Exceptions may still apply as described in Section 5. | | pplicable law. Exceptions may still apply as described in Section 5. |
| n | Residents of Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and | n | Residents of Colorado, Connecticut, Delaware, Kentucky, Maryland, Virginia, Utah |
| Oregon have the right to opt out of targeted advertising and sales. If you are | | , Minnesota, Rhode Island, and Oregon have the right to opt out of targeted adve |
| a resident of these states, you may opt out by following this link and, if you a | | rtising and sales. If you are a resident of these states, you may opt out by fol |
| re an Apps user, by going to the My Data page here or within your mobile app set | | lowing this link and, if you are an Apps user, by going to the My Data page here |
| tings. | | or within your mobile app settings. |
| For users in Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and | | For users in Colorado, Connecticut and Virginia, you may opt out of profiling in |
| Oregon have the right to opt out of profiling in furtherance of decisions that | | furtherance of decisions that produce legal or similarly significant effects. W |
| produce legal or similarly significant effects. While you may still make this re | | hile you may still make this request, Headspace does not currently use profiling |
| quest, Headspace does not currently use profiling in this manner. | | in this manner. |
| Nevada provides its residents a limited right to opt out of the sale of personal | | Nevada provides its residents a limited right to opt out of the sale of personal |
| information. Please know that we do not trigger this requirement because we do | | information. Please know that we do not trigger this requirement because we do |
| not sell your personal information for payment. | | not sell your personal information for payment. |
| Residents in Minnesota and Oregon may obtain a list of the specific third partie | | Residents in Minnesota and Oregon may obtain a list of the specific third partie |
| s to whom we may disclose your personal information. General information about t | | s to whom we may disclose your personal information. General information about t |
| hese third parties is available in Section 3. You can make this request using th | | hese third parties is available in Section 3. You can make this request using th |
| e contact information in Section 9. | | e contact information in Section 9. |
| The RIDTPA entitles Rhode Island residents to know the third parties to which we | | The RIDTPA entitles Rhode Island residents to know the third parties to which we |
| sell or may sell their personal information. Headspace does not sell personal i | | sell or may sell their personal information. Headspace does not sell personal i |
| nformation for payment but, like with the CCPA in Section 10b, a “sale” under th | | nformation for payment but, like with the CCPA in Section 10b, a “sale” under th |
| e RIDTPA can include sharing personal information for targeted advertising. Unde | | e RIDTPA can include sharing personal information for targeted advertising. Unde |
| r that definition, we have shared personal information, which may include yours, | | r that definition, we have shared personal information, which may include yours, |
| to the third parties listed here. | | to the third parties listed here. |