Captured before automated identity checks (Oct 14, 2026): accurate as of its capture on Oct 1, 2026; our capture on Oct 15, 2026 found the same text, but its identity was not checked by them.
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“Before you use or activate an AI Feature, we will let you know that you will be interacting with AI and give you the choice of whether to do so.”
“We work with third party platforms who provide us with analytics and advertising services... serving advertisements on our behalf to those who may be interested, and measuring the performance of those advertisements.”
“we may provide certain personal information to your Benefit Sponsor, including your name, email address, your registration date, and the date on which you last used our Platform.”
“This restriction may not apply where sharing some of your activity is necessary for your treatment, payment, or healthcare operations such as if your Benefit Sponsor is your other healthcare provider, health insurance provider, or health plan.”
“In the event that we are unable to resolve your issues through the above channels, you may be able to invoke binding arbitration, under certain conditions and as permitted by the EU-U.S. DPF, its UK Extension, or the Swiss-U.S. DPF.”
“We will collect the information you provide about your health and wellness as you use our Products or engage with the Services... such as through survey responses about your current mental or physical health status...”
Headspace collects sensitive health, wellness, and demographic information when you use its services and shares some of that data with advertisers, analytics partners, and—if your employer or health plan sponsors your access—your Benefit Sponsor. Your sensitive information is not used to personalize ads, but your general personal information is used to tailor Headspace ads you see on other websites and apps. Before any AI feature is activated, Headspace will tell you and give you the choice to proceed.
Headspace's Privacy Policy establishes the conditions under which Headspace collects, uses, and shares personal information, including sensitive categories such as health and wellness data, mental and physical health status, and demographic identity attributes. The Policy defines how personal information is used for service delivery, marketing, and personalized advertising through third-party platforms, while carving out sensitive personal information from ad personalization. It governs data-sharing relationships with third-party analytics and advertising providers, Benefit Sponsors, and—under specified healthcare-related exceptions—healthcare providers and health plans. Supplemental terms and privacy notices take precedence over the main Policy where conflicts arise, and binding arbitration is available as a conditional last-resort mechanism under the EU-U.S. DPF, its UK Extension, or the Swiss-U.S. DPF frameworks. Health information Headspace collects is treated as protected health information under HIPAA where applicable.
As a Headspace user, your health and wellness data, including mental and physical health survey responses, is collected and treated as protected health information under HIPAA where that law applies. If your access is sponsored by an employer or health plan, Headspace may share your name, email address, registration date, and last use date with that Benefit Sponsor, and that restriction may not apply when sharing is necessary for treatment, payment, or healthcare operations. Your general personal information is used to personalize Headspace ads you see on third-party websites and apps, though your sensitive personal information is not used for ad personalization. Before any AI Feature is activated, Headspace will disclose that you are interacting with AI and give you the choice of whether to proceed.
Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.
1 important change detected
8 versions captured · Latest change detected by ConductAtlas: October 2026
We withheld clauses we had published from this document. Each withholding is recorded in our correction log:
“We work with third party platforms who provide us with analytics and advertising services... serving advertisements on our behalf to those who may be interested, and measuring the performance of those advertisements.”
“Before you use or activate an AI Feature, we will let you know that you will be interacting with AI and give you the choice of whether to do so.”
“we may provide certain personal information to your Benefit Sponsor, including your name, email address, your registration date, and the date on which you last used our Platform.”
“This restriction may not apply where sharing some of your activity is necessary for your treatment, payment, or healthcare operations such as if your Benefit Sponsor is your other healthcare provider, health insurance provider, or health plan.”
“In the event that we are unable to resolve your issues through the above channels, you may be able to invoke binding arbitration, under certain conditions and as permitted by the EU-U.S. DPF, its UK Extension, or the Swiss-U.S. DPF.”
“We will collect the information you provide about your health and wellness as you use our Products or engage with the Services... such as through survey responses about your current mental or physical health status...”
“you may have the opportunity to provide additional information about yourself, such as your age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender identity, sex at birth...”
“We understand that this information is very sensitive so we handle it with care, including treating this health information as protected health information under HIPAA where applicable.”
“Use of sensitive personal information. We use sensitive personal information for the same purposes listed above except for personalizing ads.”
“The language of those terms and privacy notices supplement this Privacy Policy unless there is a conflict, in which case those additional terms and privacy notices will apply.”
“To personalize the advertisements you receive about our Platform through third-party platforms, on other websites and apps;”
“To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;”
Every distinct legal provision identified in this document. Featured provisions appear above with analysis.
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