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 updated policy expands language accessibility by adding support for five additional languages and explicitly guarantees free language assistance and accessible formats for all users. For users enrolled in the CMS ACCESS Program, the policy now discloses that Headspace may share health information with the Centers for Medicare & Medicaid Services (CMS), and that CMS may access or request health information consistent with applicable privacy and security law; separate program disclosures will be provided before enrollment. You can access language assistance services and accessible formats by emailing help@headspace.com.
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We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser "Do Not Track" settings and/or signals or other mechanisms that provide consumers the ability to exercise choice...
as such disclosure may be required by the order or requirement of a court, administrative agency or other governmental body, subject to the Receiving Party providing to the Disclosing Party reasonable written notice...
If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties' direct marketing purposes...
"Headspace is not a data broker and does not sell your personal information to third parties for payment. However... we may disclose limited personal information to third parties for our cross-context behavioral and targeted advertising purposes...Excerpt from Headspace's Privacy Policy
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The clause states: “Headspace is not a data broker and does not sell your personal information to third parties for payment. However... we may disclose limited personal information to third parties for our cross-context behavioral and targeted advertising purposes...”
ConductAtlas has identified this type of provision across 267 platforms. See the full comparison.
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