Headspace transfers personal information internationally, including from the EU and UK to the United States, and relies on data transfer mechanisms such as Standard Contractual Clauses to legitimise those transfers.
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 provision specifies the legal frameworks under which Headspace transfers personal data internationally. This establishes the regulatory basis and compliance mechanism for moving data across borders, which affects the legal standards and accountability structures applicable to the company's data handling practices.
Removal of cross-border data transfer provision eliminates explicit disclosure of international data movement mechanisms and legal frameworks.
View full change record →If you are in the EU or UK, your sensitive mental health and therapy data is transferred to the United States where it may be subject to US surveillance laws, though Headspace uses contractual safeguards to protect it.
How other platforms handle this
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
"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-U.S. DPF) as set forth by the U.S. Department of Commerce.Excerpt from Headspace's Privacy Policy
(1) REGULATORY FRAMEWORK: GDPR Chapter V (Arts.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The provision specifies the legal frameworks under which Headspace transfers personal data internationally. This establishes the regulatory basis and compliance mechanism for moving data across borders, which affects the legal standards and accountability structures applicable to the company's data handling practices.
If you are in the EU or UK, your sensitive mental health and therapy data is transferred to the United States where it may be subject to US surveillance laws, though Headspace uses contractual safeguards to protect it.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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