Headspace maintains a separate privacy policy specifically for health data collected outside of HIPAA-covered clinical services, reflecting that some mental health and wellness data may be regulated under newer state consumer health data laws.
This analysis describes what Headspace's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The existence of a separate Consumer Health Data Privacy Policy signals that Headspace collects health-related data in contexts not fully protected by HIPAA, such as mood tracking or meditation usage, and that additional state-level rights may apply to this data depending on your location.
Interpretive note: The specific scope of data covered by the Consumer Health Data Privacy Policy and the full list of applicable state laws is not detailed in the main policy text; the Consumer Health Data Privacy Policy must be reviewed separately to assess complete protections and obligations.
Headspace now explicitly references a separate Consumer Health Data Privacy Policy for state-regulated consumer health data, creating a dual-track governance framework distinct from HIPAA coverage.
View full change record →Mental wellness data collected through non-clinical Headspace features may be subject to state consumer health data laws rather than HIPAA, meaning the applicable protections, rights, and sharing restrictions depend on which feature generated the data and which state you reside in; users in Washington State, for example, may have specific consent rights under the My Health MY Data Act for this category of data.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Our Services are delivered by our Care Providers... Depending on how you interact with us, the following may also apply to you... Please refer to our Consumer Health Data Privacy Policy for more information about how we handle consumer health data regulated under applicable state consumer health data laws.Excerpt from Headspace's Privacy Policy
REGULATORY LANDSCAPE: This provision engages Washington State's My Health MY Data Act, Connecticut's An Act Concerning Personal Data Privacy and Online Monitoring, Nevada's consumer health data law, and potentially other state frameworks that extend privacy …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
The existence of a separate Consumer Health Data Privacy Policy signals that Headspace collects health-related data in contexts not fully protected by HIPAA, such as mood tracking or meditation usage, and that additional state-level rights may apply to this data depending on your location.
Mental wellness data collected through non-clinical Headspace features may be subject to state consumer health data laws rather than HIPAA, meaning the applicable protections, rights, and sharing restrictions depend on which feature generated the data and which state you reside in; users in Washington State, for example, may have specific consent rights under the My Health MY Data Act for …
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Headspace.