| March 19, 2026 14:57 UTC | April 11, 2026 06:05 UTC | ||||
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| n | n | 1 | Table of Contents | ||
| 2 | 1. Collection of personal information | ||||
| 3 | 2. Use of personal information | ||||
| 4 | 3. Sharing of personal information | ||||
| 5 | 4. Data security and retention | ||||
| 6 | 5. Your privacy rights | ||||
| 7 | 6. Children’s privacy | ||||
| 8 | 7. Cookies | ||||
| 9 | 8. Changes | ||||
| 10 | 9. Contact us | ||||
| 11 | 10. Supplemental notices | ||||
| 1 | Headspace Privacy Policy | 12 | Headspace Privacy Policy | ||
| n | n | 13 | Table of Contents | ||
| 14 | 1. Collection of personal information | ||||
| 15 | 2. Use of personal information | ||||
| 16 | 3. Sharing of personal information | ||||
| 17 | 4. Data security and retention | ||||
| 18 | 5. Your privacy rights | ||||
| 19 | 6. Children’s privacy | ||||
| 20 | 7. Cookies | ||||
| 21 | 8. Changes | ||||
| 22 | 9. Contact us | ||||
| 23 | 10. Supplemental notices | ||||
| 2 | PRIVACY LINKS | 24 | PRIVACY LINKS | ||
| 3 | Privacy Policy | 25 | Privacy Policy | ||
| 4 | Consumer Health Data Privacy Policy | 26 | Consumer Health Data Privacy Policy | ||
| 6 | Cookie Policy | 28 | Cookie Policy | ||
| 7 | 渝ICP备2021001788号-3A | 29 | 渝ICP备2021001788号-3A | ||
| 8 | This Privacy Policy has been prepared in English and translated into the followi | 30 | 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 | 9 | Czech | | n | 31 | Czech | Dutch | English | French [Canada] | French [Europe] | German | Hindi | H |
| > | ungarian | Italian | Japanese | Korean | Malay | Mandarin | Polish | Portuguese | ||||
| > | | Russian | Spanish [Latin America] | Spanish [Spain] | ||||
| 10 | Dutch | | 32 | Effective: March 30, 2026. | ||
| 11 | English | | ||||
| 12 | French | | ||||
| 13 | German | | ||||
| 14 | Hindi | | ||||
| 15 | Hungarian | | ||||
| 16 | Italian | | ||||
| 17 | Japanese | | ||||
| 18 | Korean | | ||||
| 19 | Malay | | ||||
| 20 | Polish | | ||||
| 21 | Portuguese | | ||||
| 22 | Russian | | ||||
| 23 | Simplified Chinese | | ||||
| 24 | Spanish | ||||
| 25 | Effective: September 30, 2025 | ||||
| 26 | If you are visually impaired, have another disability, or need support in other | 33 | 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. | ||
| 27 | At Headspace, our company values include putting members first. We are committed | 34 | 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. | ||
| 28 | Depending on how you interact with us, the following may also apply to you: | 35 | Depending on how you interact with us, the following may also apply to you: | ||
| n | 29 | Our Services are delivered by our Care Providers. For Care Providers in the US, | n | 36 | 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. | ||
| 30 | Some components or features of our Platform may include additional privacy notic | 37 | 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. | ||
| 31 | You may follow links contained in our Platform or provided to you by other users | 38 | 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 | 32 | Similar to the above point, you may use single sign-on (SSO) features to access | n | 39 | 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. | ||
| 33 | This privacy policy does not apply to Headspace employees or applicants to Heads | 40 | 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. | ||
| 34 | Please read the following carefully to understand our practices regarding your p | 41 | 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. | ||
| 35 | Table of Contents | 42 | Table of Contents | ||
| n | 36 | This Privacy Policy is provided in a layered format. We provided summaries for e | n | 43 | 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. | ||||
| 37 | 1. | ||||
| 38 | Collection of personal information | 44 | 1. Collection of personal information | ||
| 39 | We may collect your personal information through our Platform, or when | 45 | 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. | ||||
| 40 | you otherwise share your information with us. Our collection may require | ||||
| 41 | your input or can be automatically collected while you engage with us. | ||||
| 42 | 2. | ||||
| 43 | Use of personal information | 46 | 2. Use of personal information | ||
| 44 | We primarily use your personal information for our Products and Websites | 47 | 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. | ||||
| 45 | to function and to deliver you the Services. We also may use your | ||||
| 46 | personal information for other purposes like communicating to you about | ||||
| 47 | your interest in our Platform, processing payments, complying with legal | ||||
| 48 | obligations, or to develop new features or improvements. | ||||
| 49 | 3. | ||||
| 50 | Sharing of personal information | 48 | 3. Sharing of personal information | ||
| 51 | We may share your personal information with certain third-party service | 49 | 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. | ||||
| 52 | providers to help make our Platform function. We may also share personal | ||||
| 53 | information as directed by you, to provide you with opportunities we | ||||
| 54 | think may interest you, or as legally required, such as to comply with a | ||||
| 55 | court order. | ||||
| 56 | 4. | ||||
| 57 | Data security and retention | 50 | 4. Data security and retention | ||
| 58 | The security of your personal information is of utmost importance to us. | 51 | 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. | ||||
| 59 | We retain your personal information for as long as necessary, and we | ||||
| 60 | maintain appropriate safeguards to protect it. | ||||
| 61 | 5. | ||||
| 62 | Your privacy rights | 52 | 5. Your privacy rights | ||
| 63 | We want you to have choice in how your personal information is used. We | 53 | 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. | ||||
| 64 | provide you rights to request actions regarding your personal | ||||
| 65 | information including deletion, no matter where you reside. Further | ||||
| 66 | rights may be provided for your specific jurisdiction, which are | ||||
| 67 | outlined in Section 10. | ||||
| 68 | 6. | ||||
| 69 | Children's Privacy | 54 | 6. Children’s Privacy | ||
| 70 | Our Platform is generally intended for adults, except in limited | 55 | Our Platform is not intended for individuals under the age of 13 years old or th | ||
| > | e equivalent age in your jurisdiction. | ||||
| 71 | circumstances depending on your offering. | ||||
| 72 | 7.Cookies | 56 | 7. Cookies | ||
| 73 | When you visit our Websites, we may collect certain information from you | 57 | 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. | ||||
| 74 | automatically through cookies and other tracking technologies. You can | ||||
| 75 | decide what cookies are deployed using the cookies settings on our | ||||
| 76 | Websites. | ||||
| 77 | 8.Changes | 58 | 8. Changes | ||
| 78 | We may change this Privacy Policy to reflect new services, changes in | 59 | We may change this Privacy Policy to reflect new services, changes in our data p | ||
| > | ractices, or to comply with relevant laws. | ||||
| 79 | our data practices, or to comply with relevant laws. | ||||
| 80 | 9.Contact us | 60 | 9. Contact us | ||
| 81 | You may contact us for comments, questions, or to exercise your privacy | 61 | You may contact us for comments, questions, or to exercise your privacy rights i | ||
| > | n various ways including emailing help@headspace.com. | ||||
| 82 | rights in various ways including emailing help@headspace.com | ||||
| 83 | 10. | ||||
| 84 | Supplemental notices | 62 | 10. Supplemental notices | ||
| 85 | This section provides additional information specific to certain | 63 | 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. | ||||
| 86 | jurisdictions. Please note, that our Platform is operated in the United | ||||
| 87 | States where your personal information will be primarily processed and | ||||
| 88 | stored. | ||||
| 89 | 1. Collection of personal information | 64 | 1. Collection of personal information | ||
| 90 | We may collect or process the following personal information about you from what | 65 | 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 | 91 | (a) Information you provide to us | n | 66 | a. Information you provide to us |
| 92 | Contact information and identifiers. When you use our Platform, we may ask you t | 67 | 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. | ||
| 93 | Account Information. If you decide to set up an account with us, we may ask you | 68 | 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. | ||
| 94 | Health information. We will collect the information you provide about your healt | 69 | 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. | ||
| 97 | Survey information. We may present you with surveys for Product functionality, t | 72 | 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. | ||
| 98 | Communication information. When you send or respond to emails, messages, chats, | 73 | 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. | ||
| 99 | Support information. When you submit a support request or otherwise engage with | 74 | 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 | 100 | (b) Information from others | n | 75 | b. Information from others |
| 101 | In certain circumstances, we may collect personal information about you from oth | 76 | In certain circumstances, we may collect personal information about you from oth | ||
| > | ers. This may include the following: | > | ers. This may include the following: | ||
| 102 | If you receive access to Headspace through your employer, health plan, or anothe | 77 | 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. | ||
| 103 | We may collect the name, email address, content engagement, and preferences of i | 78 | 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 | 104 | We may collect personal information from parents or guardians for operating acco | n | 79 | 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. | ||
| 105 | If you choose to have your account verified to confirm your eligibility for a se | 80 | 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 | 106 | (c) Information we automatically collect | n | 81 | c. Information we automatically collect |
| 107 | Our Products and Websites may collect information from you automatically during | 82 | Our Products and Websites may collect information from you automatically during | ||
| > | your use which may include: | > | your use which may include: | ||
| 108 | Browser and device data, such as IP address, device identifier, device type, ope | 83 | 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. | ||
| 109 | Usage data, such as time spent on the Products and Websites including pages visi | 84 | 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 | 110 | (d) Aggregated, anonymous, and de-identified data | n | 85 | d. Aggregated, anonymous, and de-identified data |
| 111 | We may create or collect aggregated, anonymous, or de-identified data from perso | 86 | 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. | ||
| 112 | 2. Use of personal information | 87 | 2. Use of personal information | ||
| 113 | We may use your personal information in the following ways: | 88 | We may use your personal information in the following ways: | ||
| n | 114 | To provide our Platform, including the delivery of content and interactive featu | n | 89 | To provide our Platform, including the delivery of content, interactive features |
| > | res; | > | , and tailoring your experience to you; | ||
| 115 | To communicate with you regarding our Platform including updates or changes; | 90 | To communicate with you regarding our Platform including updates or changes; | ||
| 116 | To provide you support, answer your questions or requests for information, or ha | 91 | To provide you support, answer your questions or requests for information, or ha | ||
| > | ndle your complaints; | > | ndle your complaints; | ||
| n | n | 92 | To determine the availability of certain features of services for you; | ||
| 117 | To process payment, manage your orders, and account for applicable sales taxes; | 93 | To process payment, manage your orders, and account for applicable sales taxes; | ||
| 118 | To inform your Benefit Sponsor, if you have one, about your registration and oth | 94 | 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; | ||
| 119 | To fulfill our obligations under any agreements that we may have with you; | 95 | To fulfill our obligations under any agreements that we may have with you; | ||
| 123 | To personalize the advertisements you receive about our Platform through third-p | 99 | 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; | ||
| 124 | To protect ourselves, you and others such as by taking actions to prevent fraud | 100 | 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 | ||
| 125 | To comply with our legal obligations including meeting regulatory compliance obl | 101 | 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 | 126 | to establish or exercise our legal rights or defense against legal claims. | n | 102 | To establish or exercise our legal rights or defense against legal claims. |
| 127 | AI Features. We use artificial intelligence (AI) which means a machine-based sys | 103 | 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. | ||
| 128 | 3. Sharing of personal information | 104 | 3. Sharing of personal information | ||
| 129 | We may disclose your personal information with the following categories of third | 105 | We may disclose your personal information with the following categories of third | ||
| > | parties: | > | parties: | ||
| n | 130 | Our service providers. In some circumstances we may need to disclose your person | n | 106 | 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. | ||||
| 107 | 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. | ||||
| 131 | Your integrations. You may connect your account through supported integrations w | 108 | 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. | ||
| 132 | Community Activity. If you engage with other Platform users using our community | 109 | 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. | ||
| 133 | Your Benefit Sponsor. In limited cases, we may provide certain personal informat | 110 | 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. | ||
| 150 | Upon receiving your request, we may ask for additional information from you in o | 127 | 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. | ||
| 151 | We do not charge a fee to process your verifiable request unless it is excessive | 128 | 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. | ||
| 152 | Your rights are not absolute, and exceptions may apply. These exceptions can ari | 129 | 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 | 153 | Some US jurisdictions provide residents with certain rights with respect to thei | n | 130 | 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. | ||
| 154 | 6. Children’s privacy | 131 | 6. Children’s privacy | ||
| n | 155 | At Headspace, we are committed to protecting and respecting children’s privacy. | n | 132 | 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. | ||||
| 156 | 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. | ||||
| 157 | 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. | ||||
| 158 | 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. | ||||
| 159 | 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. | ||||
| 160 | If you are a parent or guardian and you are aware that a child under age 13 has | 133 | 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. | ||
| 161 | 7. Cookies | 134 | 7. Cookies | ||
| 162 | When you visit our Websites, we may collect information from you automatically t | 135 | 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. | ||
| 163 | 8. Changes | 136 | 8. Changes | ||
| 166 | We want to hear from you if you have questions, concerns, or requests regarding | 139 | 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. | ||
| 167 | 10. Supplemental notices | 140 | 10. Supplemental notices | ||
| 168 | Depending on your jurisdiction, you have additional rights that apply to you und | 141 | 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 | 169 | (a) Privacy Notice for EU and the UK | n | 142 | a. Privacy Notice for EU and the UK |
| 170 | Data Transfers. This section is for individuals in the European Union (EU), the | 143 | 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. | ||
| 171 | Headspace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK | 144 | 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/. | ||
| 172 | The following entities are included under Headspace’s DPF certification and adhe | 145 | 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: | ||
| 194 | Right not to be subject to automated decision making - You have the right not to | 167 | 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. | ||
| 195 | Right to lodge a complaint - You may also have the right to lodge a complaint ab | 168 | 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. | ||
| 196 | Exceptions may still apply as described in Section 5. | 169 | Exceptions may still apply as described in Section 5. | ||
| n | 197 | Representatives: Individuals and the data protection supervisory authorities in | n | 170 | 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: | ||
| 198 | EU: DP-Dock GmbH, Attn.: Headspace, Inc., Ballindamm 39, 20095 Hamburg, Germany | 171 | EU: DP-Dock GmbH, Attn.: Headspace, Inc., Ballindamm 39, 20095 Hamburg, Germany | ||
| 199 | UK: DP Data Protection Services UK Ltd., Attn.: Headspace, Inc., 16 Great Queen | 172 | 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 | ||
| 200 | www.dp-dock.com | 173 | www.dp-dock.com | ||
| 201 | headspace@gdpr-rep.com | 174 | headspace@gdpr-rep.com | ||
| 202 | Our data protection officer can be reached at privacy@headspace.com. | 175 | Our data protection officer can be reached at privacy@headspace.com. | ||
| n | 203 | (b) Privacy Notice for California | n | 176 | b. Privacy Notice for California |
| 204 | We include this section for residents of California in order to comply with the | 177 | 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. | ||
| 205 | Categories of personal information. The CCPA includes categories of personal inf | 178 | 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. | ||
| 206 | Headspace is not a data broker and does not sell your personal information to th | 179 | 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 | 207 | CATEGORYCOLLECTED | n | 180 | CATEGORY |
| 181 | COLLECTED | ||||
| 208 | “SOLD” / “SHARED” | 182 | “SOLD” / “SHARED” | ||
| 209 | A. Identifiers. | 183 | A. Identifiers. | ||
| n | 210 | Name, alias, mailing address, unique personal identifier, online | n | 184 | 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 | ||||
| 211 | identifier, IP address, email (personal and/or work), account name, | ||||
| 212 | telephone number, password, account credentials, National Provider | ||||
| 213 | Identifier (NPI), driver’s license / government ID number (if provided | ||||
| 214 | for identity verification), or other similar identifiers | ||||
| 215 | Yes | 185 | Yes | ||
| 216 | Yes | 186 | Yes | ||
| n | 217 | email, online identifier, personal unique identifier, IP | n | 187 | email, online identifier, personal unique identifier, IP address |
| 218 | address | 188 | B. Personal information categories listed in the California Customer Records sta | ||
| > | tute (Cal. Civ. Code § 1798.80(e)). | ||||
| 219 | B. Personal information categories listed in the California Customer | 189 | 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 | ||||
| 220 | Records statute (Cal. Civ. Code § 1798.80(e)). | ||||
| 221 | Name, signature, mailing address, telephone number, driver’s license | ||||
| 222 | / government ID number (if provided for identity verification), | ||||
| 223 | payment card number, employment, employment history, bank account | ||||
| 224 | information, medical information, and health insurance | ||||
| 225 | information | ||||
| 226 | Yes | 190 | Yes | ||
| 227 | Yes | 191 | Yes | ||
| 228 | 192 | ||||
| n | 229 | C. Protected classification characteristics under California or | n | 193 | C. Protected classification characteristics under California or federal law. |
| 230 | federal law. | 194 | 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 | ||||
| 231 | Age (40 years or older), race, color, ancestry, national origin, | ||||
| 232 | citizenship, religion or creed, marital status, medical condition, | ||||
| 233 | physical or mental disability, sex (including gender, gender identity, | ||||
| 234 | gender expression, pregnancy or childbirth and related medical | ||||
| 235 | conditions), sexual orientation, veteran or military status | ||||
| 236 | YesNo | 195 | Yes | ||
| 196 | No | ||||
| 237 | D. Commercial information. | 197 | D. Commercial information. | ||
| n | 238 | Payment history, balances, Products or Services purchased or | n | 198 | Payment history, balances, Products or Services purchased or considered |
| 239 | considered | ||||
| 240 | Yes | 199 | Yes | ||
| 241 | Yes | 200 | Yes | ||
| 242 | Products or Services purchased or considered | 201 | Products or Services purchased or considered | ||
| 243 | E. Biometric information. | 202 | E. Biometric information. | ||
| 244 | Sleep, health, or exercise data | 203 | Sleep, health, or exercise data | ||
| n | 245 | YesNo | n | 204 | Yes |
| 205 | No | ||||
| 246 | F. Internet or other similar network activity. | 206 | F. Internet or other similar network activity. | ||
| n | 247 | Browsing history, search history, information on how you interact | n | 207 | Browsing history, search history, information on how you interact with our websi |
| > | te | ||||
| 248 | with our website | ||||
| 249 | Yes | 208 | Yes | ||
| 250 | Yes | 209 | Yes | ||
| n | 251 | Browsing history, information on how you interact with our | n | 210 | Browsing history, information on how you interact with our website |
| 252 | website | ||||
| 253 | G. Geolocation data. | 211 | G. Geolocation data. | ||
| 254 | Approximate location based on information like IP address | 212 | Approximate location based on information like IP address | ||
| n | 255 | YesNo | n | 213 | Yes |
| 214 | No | ||||
| 256 | H. Sensory data. | 215 | H. Sensory data. | ||
| 257 | Audio recordings, voicemails, photographs | 216 | Audio recordings, voicemails, photographs | ||
| n | 258 | YesNo | n | 217 | Yes |
| 218 | No | ||||
| 259 | I. Professional or employment-related information. | 219 | I. Professional or employment-related information. | ||
| 260 | Employer, job title or role, work contact information | 220 | Employer, job title or role, work contact information | ||
| n | 261 | YesNo | n | 221 | Yes |
| 262 | J. Non-public education information (per the Family Educational | 222 | No | ||
| 263 | Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part | 223 | 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)). | ||||
| 264 | 99)). | ||||
| 265 | Student identification number | 224 | Student identification number | ||
| n | 266 | YesNo | n | 225 | Yes |
| 226 | No | ||||
| 267 | K. Inferences drawn from other personal information. | 227 | K. Inferences drawn from other personal information. | ||
| n | 268 | Profile reflecting a person's preferences, characteristics, | n | 228 | Profile reflecting a person's preferences, characteristics, psychological trends |
| > | , predispositions, behavior, attitudes, intelligence, abilities, age and aptitud | ||||
| > | es | ||||
| 269 | psychological trends, predispositions, behavior, attitudes, | ||||
| 270 | intelligence, abilities, and aptitudes | ||||
| 271 | YesNo | 229 | Yes | ||
| 230 | No | ||||
| 272 | L. Sensitive personal information. | 231 | L. Sensitive personal information. | ||
| n | 273 | Password, health information, payment information, racial and/or | n | 232 | Password, health information, payment information, racial and/or ethnic origin, |
| > | information concerning your sexual orientation, and gender identity | ||||
| 274 | ethnic origin, information concerning your sexual orientation, and | ||||
| 275 | gender identity | ||||
| 276 | YesNo | 233 | Yes | ||
| 234 | No | ||||
| 277 | Please note that because of the overlapping nature of certain categories identif | 235 | 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. | ||
| 278 | Use of personal information. We may use your personal information in the followi | 236 | Use of personal information. We may use your personal information in the followi | ||
| > | ng ways: | > | ng ways: | ||
| 279 | To provide our Platform, including the delivery of content and interactive featu | 237 | To provide our Platform, including the delivery of content and interactive featu | ||
| > | res; | > | res; | ||
| 298 | Right to opt out of sale and/or sharing. You have the right to opt-out of the sa | 256 | 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. | ||
| 299 | Right to limit use and disclosure. You have the right to limit the use or disclo | 257 | 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. | ||
| 300 | Sharing with third parties for their own direct marketing purposes. Headspace do | 258 | 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 | 301 | Notice of right to Opt-Out. | n | 259 | 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. | ||||
| 302 | 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. | ||||
| 303 | (c) Privacy Notice for other US states | 260 | c. Privacy Notice for other US states | ||
| 304 | We include this section for residents of other US states with privacy laws that | 261 | 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. | ||||
| 305 | Collection of personal information. Headspace may collect the personal informati | 262 | 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. | ||
| 306 | Use of personal information. Headspace may collect, use, or disclose personal in | 263 | 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. | ||
| 307 | Disclosure of personal information. We may disclose your personal information to | 264 | 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. | ||
| 308 | Your privacy rights. We generally provide the privacy rights described in Sectio | 265 | 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. | ||
| t | 309 | Residents of Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and | t | 266 | 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. | ||
| 310 | For users in Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and | 267 | 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. | ||
| 311 | Nevada provides its residents a limited right to opt out of the sale of personal | 268 | 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. | ||
| 312 | Residents in Minnesota and Oregon may obtain a list of the specific third partie | 269 | 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. | ||
| 313 | The RIDTPA entitles Rhode Island residents to know the third parties to which we | 270 | 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. | ||
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