Provision record
Headspace · Headspace Privacy Policy · View original document ↗

Sharing Mental Health Data with Advertising and Analytics Partners

High severity Common · 288 of 352 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The provision creates a dual privacy framework: HIPAA compliance applies when Care Providers are engaged, while state-specific consumer health data laws apply to other health data collected. This establishes different regulatory obligations and data handling standards depending on the user's interaction type.

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 3, 2026
First Seen
May 8, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Change history

removed Jun 24, 2026

This provision was replaced with more detailed 'Third-Party Advertising and Analytics Data Sharing' provision that explicitly characterizes the practice as potential CCPA/CPRA 'sale' or 'sharing'.

View full change record →

Consumer impact (what this means for users)

Users may be subject to either HIPAA protections (when using Care Provider services) or state consumer health data privacy laws (for other health data), with Care Providers potentially issuing separate privacy notices during enrollment that users should review to understand which framework applies to their data.

How other platforms handle this

Adobe Medium

The types of third parties your information may be disclosed to include: our resellers and other sales and advertising partners, retailers, advertisers, ad agencies, advertising networks and platforms, information service providers, fraud monitoring and prevention providers, and publishers.

Skillshare Medium

Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud

Squarespace Medium

we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Headspace is subject to HIPAA as our Care Providers' business associate. Our Care Providers may provide you an additional privacy notice during enrollment which we encourage you to review. Depending on how you interact with us, the following may also apply to you: Our Consumer Health Data Privacy Policy applies to certain consumer health data that is regulated under applicable state consumer health data laws.

Excerpt from Headspace's Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Headspace Privacy Policy
Entity
Headspace
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-001134
Document ID
CA-D-00216
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c1c69938a2255531d9160216a80441cc6e236ee7a78005f747b818b71812b907
Analysis generated
May 8, 2026 10:00 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Headspace
Document: Headspace Privacy Policy
Record ID: CA-P-001134
Captured: 2026-05-08 10:00:58 UTC
SHA-256: c1c69938a2255531…
URL: https://conductatlas.com/platform/headspace/headspace-privacy-policy/provision/CA-P-001134/sharing-mental-health-data-with-advertising-and-analytics-partners/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Headspace's Sharing Mental Health Data with Advertising and Analytics Partners clause do?

The provision creates a dual privacy framework: HIPAA compliance applies when Care Providers are engaged, while state-specific consumer health data laws apply to other health data collected. This establishes different regulatory obligations and data handling standards depending on the user's interaction type.

How does this clause affect you?

Users may be subject to either HIPAA protections (when using Care Provider services) or state consumer health data privacy laws (for other health data), with Care Providers potentially issuing separate privacy notices during enrollment that users should review to understand which framework applies to their data.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.

Is ConductAtlas affiliated with Headspace?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Headspace.