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For Ginger only members, see our Ginger Privacy Policy here
Headspace Health is now Headspace, merging Ginger's clinical expertise with
Headspace's meditations and mindfulness for comprehensive mental health care.


HEADSPACE HEALTH – PRIVACY POLICIES & NOTICES

Sept. 25, 2023

‍Headspace Health – Privacy Policies & Notices

‍

If you are a visually impaired customer, a customer who has another disability
or a customer who seeks support in other languages, you may access this Privacy
Policy by emailing us at help@headspace.com.

‍

Our Privacy Commitment to You

‍

First, a note about Headspace Health’s commitment to your privacy.

‍

Headspace Health deeply values its role as a trusted provider of meditation,
mindfulness and mental health offerings through the Headspace and Ginger apps.
Headspace provides meditation and mindfulness content for stress, sleep, focus,
and movement, and Ginger provides on-demand mental health support through
coaching, therapy, psychiatry, and self-care resources. Ginger is a licensed
medical provider in the United States. For information about Ginger services
outside of the United States, please contact us at help@headspace.com. Central
to that role is our promise to safeguard the privacy of your personal
information.  Here are a few things we want you to know:

‍

 1. We only collect the personal information we need in order to provide you
    with Headspace Health’s services and products. We do not collect more
    information than we need. The personal information that we ask you to
    provide us, or give you the option to provide us, is intended to help us
    direct you to and deliver meditation, mindfulness, and mental health-related
    services, as applicable, that adhere to our standards of high quality and
    exceptional member service.

‍

 2. We do not use your personal information for purposes unrelated to the
    reasons for which it was collected, or that would not conform to your
    reasonable expectations.  We know it is important to you that you be aware
    of all the reasons that your information is collected, used and shared by
    Headspace Health. Our responsibility to safeguard your privacy is of the
    utmost importance to us.

‍

 3. We do not retain personal information for longer than is necessary.  We
    understand the importance of minimizing the personal information that we may
    maintain.  We will only retain your data for the period of time necessary to
    fulfill the purposes for which it was collected, including delivering
    requested products and services, protecting the interests of our users and
    other stakeholders, and as otherwise consistent with our legal obligations
    or your reasonable expectations.

‍

 4. We do not sell your personal information to others.  We will not sell your
    personal information to third parties, except to the extent that our sharing
    of personal information to facilitate targeted digital advertising may be
    considered “selling” or “sharing” your personal information under certain
    state laws.

‍

 5. We offer you ways to control your personal information and express your
    preferences.  We provide you with a variety of ways to exercise control over
    your personal information, including providing you with options regarding
    what personal information you provide to us, exercising your account and
    communications preferences, and updating your user profile. You may have
    other rights depending on your location and applicable law.

Headspace Health Privacy Policy

‍

Headspace Health (Headspace Health entities include Headspace, Inc., Ginger.io,
Inc. and its subsidiaries and affiliates, collectively referred to as “Headspace
Health,” “us,” “we,” or “our”) is committed to protecting and respecting your
privacy in connection with your use of our websites, including
www.headspacehealth.com, www.headspace.com, and www.ginger.com (the “Websites”)
and the products, services and features that may be referenced on the Websites
or otherwise offered by Headspace Health (our “Products and Services”). These
include but are not limited to our mobile applications and administrative tools
related to our Headspace Health mental health offerings, including the websites
and mobile apps offered by Headspace and Ginger, and the products and services
offered through those respective sites and apps (“Headspace App” and “Ginger
App” respectively), collectively for purposes of this Privacy Policy referred to
as the “Headspace Health Platform” or “Platform,” which may be updated from time
to time at the sole discretion of Headspace Health.

‍

This privacy policy (“Privacy Policy”) and any other documents referred to
herein cover personal information collected through the Headspace Health
Platform and in connection our Products and Services.  We may provide additional
privacy disclosures regarding the Websites, Headspace App, and/or Ginger App,
and the products and services offered through those respective sites and apps,
and we encourage you to please review the Headspace Privacy Policy and Ginger
Privacy Policy for those disclosures, as well as the Headspace Cookie Policy for
more information about our use of cookies and other tracking technologies. We
also encourage you to review our other terms and notices, including: 

‍

 * Headspace Terms and Conditions regarding your use of the Headspace Website
   and Apps
 * Ginger Terms of Service regarding your use of the Ginger Website, Services,
   and App

‍

If you are based in the United States and engage with the Ginger App and related
services in connection with coaching and mental health services, we may collect
or receive certain personal information and other data about you that is
governed by federal or state health privacy laws, such as the Health Insurance
Portability and Accountability Act (“HIPAA”) and California Medical Information
Act (“CMIA”).  Please review our Notice of Privacy Practices, which governs our
use, disclosure and access to information protected by HIPAA. This Privacy
Policy does not intend to include information about how we handle
HIPAA-regulated personal health information (“Protected Health Information”,
“PHI”).

‍

Please also note that residents of certain jurisdictions may have certain unique
rights with respect to our collection, use, and sharing of personal information,
including residents of California, the European Union, and the United Kingdom.
Please refer to Sections 10 and 11 for information about these
jurisdiction-specific rights. 

‍

Please read the following carefully to understand our practices regarding your
personal information and how we will collect, use and disclose your personal
information.

‍

Linkable Table of Contents

‍

This Privacy Policy is provided in a layered format. You can jump to a specific
section by clicking on the section below:

 1. Collection of personal information

We may collect your personal information when you interact with us through the
Headspace Health Platform, share your information with us, or by other means. We
may also automatically collect information regarding your use of our Platform.

 2. Use of personal information

We may use your personal information for various purposes connected with your
interest in the Headspace Health Platform, and our Products and Services, and to
allow us to maintain and improve them.

 3. Sharing of personal information

We may share your personal information with certain third parties, such as with
our service providers, as directed by you, and to provide you with opportunities
that we believe may be of interest to you.

 4. Your rights and choices

You may have certain rights and choices regarding our collection, use, and
disclosure of your personal information.

 5. Data security 

The security of your personal information is of utmost importance to us and we
maintain appropriate safeguards to protect it.

 6. Cookies and tracking technologies

When you visit the Headspace Health Platform, we may collect certain information
from you automatically through cookies and other tracking technologies.

 7. Children’s privacy

Our Platform is intended for individuals at least 18 years old or older, except
in limited circumstances that will be clearly described to you. 

 8. International data transfers

Our Platform is operated exclusively in the United States.

 9. Likes to other websites

Our Platform may contain links to other websites that are not operated by us and
that are subject to third party privacy policies and other terms.

 10. California Privacy Notice

We provide additional disclosures and rights to California residents.

 11. European and UK Privacy Notice

We provide additional disclosures and rights to individuals located in Europe
and the United Kingdom.

 12. Changes to this Privacy Policy

We may change this Privacy Policy from time to time to reflect new services or
changes in our data practices or relevant laws.

 13. Contact us




You may contact us for comments or questions in various ways.


 1. Collection of personal information

‍

For purposes of this Privacy Policy, “personal information” means any
information that relates to an identified or identifiable individual. The
personal information we collect through the Headspace Health Platform will be
apparent by the context of the page and/or the circumstances in which the
personal information is being collected. This may include collection and
processing of personal information including, but not limited to, the following
categories of information.

‍

 1.  Information you provide to us

Headspace Health may collect the following categories of personal information
about you that you choose to provide to us when you use the Headspace Health
Platform or otherwise interact with or receive our Products and Services:

 * Contact information and identifiers.  When you use our Platform, we may ask
   you to provide certain contact information including your first and last name
   and email address. We may also collect your social media identification
   number if you choose to access the Platform via a social media platform. 
 * Account Information. If you decide to set up an account with us, we may ask
   you to provide certain additional contact information including, for example,
   your first and last name, e-mail address (personal and/or work), telephone
   number, mailing address, employer or company name, job title, student
   identification number, emergency contact information, as well as password and
   other authentication-related information. For individuals who participate in
   a special subscriptions and features, including group plans, we may collect
   additional personal information, for example, home address and names and
   emails of household members for example, the names and emails of household
   members.
 * Surveys, health, and medical information.  We may present you with surveys or
   other information forms on our Platform order to provide you with information
   about our Products and Services that we think may be of interest to you or
   for research purposes. These surveys may give you the opportunity to describe
   certain things about you, such as your current mental, emotional, and
   physical status, wellness goals, current life events, and other
   health-related information.
 * Profile and demographic information.  Through your account on our Platform,
   including the Headspace and Ginger Apps, you may have to 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, marital status, and details about your health and medical
   history. 
 * Payment information.  If you sign up for a paid product or service from us,
   you may be required to provide your payment card or bank account
   information.  Please note that Headspace Health does not directly process
   payment card information, but does rely on third party payment processors to
   do so on our behalf. Please note that third party terms may apply to these
   payment services. Personal information collected for these purposes includes
   card number, type, expiration date, and billing address, and certain
   anonymized, limited and/or truncated versions of this information may be
   provided to Headspace Health.
 * Communication information.  When you send or respond to emails, messages, or
   other communications from Headspace Health, we may collect your email
   address, name, and any other personal information you choose to include in
   the body content of your communications. In addition, when you interact with
   certain  features of our Platform, we may collect the content of those
   communications.

 2. Information from others

In certain circumstances, we may collect personal information from others. This
may include the following:

 * If you receive access to Headspace Health through your employer, health plan,
   or other Headspace Health Partner, we collect your name and email address and
   demographic information that such Partner submits to us to facilitate your
   enrollment in our programs. 
 * We may collect the name, email address, content engagement, and  preferences
   of individuals that our users identify through our sharing and referral
   features. We use this data for the sole purpose of sharing content and
   referring individuals to join the Products. 
 * We may collect personal information from parents or guardians who wish to
   enroll their adolescent dependents ages 13-17 in our Ginger for Teens
   offering. We will use this data to enroll the teen.  
 * If you choose to have your account verified to confirm your eligibility for a
   select subscription offering, we may allow a third party platform to access
   the specific personal information you provide in order to perform the
   verification. Any failure to provide sufficient information or any response
   Headspace considers abnormal may result in Headspace refusing (or being
   unable) to verify your eligibility

‍

If you would like us to delete personal information that may have been provided
to us by others as described above, you can do so by opting out as described in
the invitation or other communication that we may have sent to you, or by
contacting us at help@headspace.com.

 3. Information we automatically collect

Our Platform, including the Websites, may collect information from you
automatically as your use our Platform, including individual Websites and Apps 
This information may include: 

 * Browser and device data, such as IP address, device identifier, device type,
   operating system and Internet browser type, screen resolution, operating
   system name and version, device manufacturer and model, language, plug-ins,
   add-ons, and the language version of the Websites and Apps you are visiting;
   and
 * Usage data, such as geolocation data, browsing history, time spent on the
   Platform, pages visited, links clicked, language preferences, performance of
   features, patterns of use, and the pages that led or referred you to our
   Platform including individual Websites and Apps.  For example, we use Google
   Analytics on our Websites to help us analyze your use of our Websites and
   diagnose technical issues.
 * Cookies and web-beacons  We may use cookies and other tracking technologies
   such as pixels, web beacons, embedded scripts, and tags (“Cookies”). We also
   collect information about your online activities on websites and connected
   devices over time and across third-party websites, devices, apps, and other
   online features and services. 

Please review our Cookies and tracking technologies section below, as well as
our Cookie Policy  for more information about our use of these technologies.

 4. Aggregated, anonymous, and de-identified data

We may create aggregated, anonymous, or de-identified data from personal
information by removing data components that make the data personally
identifiable to you, or potentially personally identifiable to you, or through
obfuscation or other means. Once information is aggregated, anonymized, or
de-identified such information is no longer personal information, and use of the
data is not subject to this Privacy Policy.

‍

 2. Use of personal information

‍

We may use your personal information in the following ways:

 * To provide our Products and Services, including the delivery of content and
   facilitation of interactive features;
 * To communicate with you regarding the Headspace Health Platform, Products and
   Services;
 * To notify you about updates or changes to the Headspace Health Platform,
   Products and Services;
 * To provide customer service, answer your questions or requests for
   information, or handle your complaints;
 * To facilitate payment transactions, manage your orders, and account for
   applicable sales taxes;
 * To inform businesses, government entities, hospitals, universities and other
   organizations and groups that wish to make our Products and Services
   available to their members, employees and their families, patients,
   customers, residents or others (collectively, our “Partners”) about your
   registration and, in limited cases, use of the Products and Services;
 * To effectuate our performance on any agreements that we may have with you;
 * To maintain and improve the quality of the Headspace Health Platform,
   Products and Services, including to perform research and development,
   understanding our user trends, and understand the effectiveness of our
   marketing and advertising;
 * 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;
 * To serve our advertisements to you through third-party platforms, such as
   Facebook or Google, on other sites and apps or across your devices, to the
   extent that you have provided consent and/or consistent with notice and any
   opt-out rights for such uses under applicable law;
 * To protect ourselves, you and others; preventing fraud and other unlawful or
   unauthorized activity; and creating and maintaining a trusted, secure, and
   reliable online environment; and
 * To comply with our legal obligations; respond to subpoenas, court orders or
   legal process; and to establish or exercise our legal rights or defense
   against legal claims.

Please note that we may also use your personal information to cross-reference or
convert various types of accounts that you may be associated with on our
Platform. For example, we may cross reference the account information you
provide to ensure your access to both Headspace and Ginger using the same
credentials. 

‍

 3. Sharing of personal information

‍

We may share your personal information with any member of our group, which
includes Headspace, Inc., Ginger.io, Inc. and our subsidiaries and affiliates,
for any of the purposes described in this Privacy Policy. 

We may also disclose your personal information with the following categories of
third parties:

 * Our service providers. In some circumstances, based on your specific
   requests, we may need to disclose your personal information to a third party
   so that they can provide a service on our behalf, such as to help deliver
   Products or Services that you have requested. These service providers may
   include services such as analytics , payment processing, advertising and
   marketing, website hosting, customer and technical support, and other
   services. 

Our service providers have access to your personal information only to perform
these tasks on our behalf and are obligated to maintain the confidentiality and
security of your personal information, and to not disclose or use the
information for any other purpose, consistent with this Privacy Policy and
applicable law.

 * Third party advertising platforms. We may share your personal information
   with third party platform providers who assist us in serving advertising
   regarding the Headspace Health Platform, Products and Services to others who
   may be interested.  We also partner with third parties who use Cookies to
   serve interest-based advertising and content on their respective third-party
   platforms that may be based on your preferences, location and/or interests.
 * Our Partners. In limited cases, we may provide certain personal information
   to our Partners, which may include your employer, in order to provide the
   Headspace Health Platform, Products and Services as a benefit of your
   employment.
 * Third party business partners. In limited cases, we may provide certain
   personal information to third party businesses with which we have a joint
   promotional relationship or other trusted partnership. This type of sharing
   will most often be consistent with your notice, consent, direction, and/or
   reasonable expectations in light of the circumstances in which you provided
   the personal information.
 * Compliance and harm prevention. If we are under a duty to disclose or share
   your personal information in order to comply with any legal obligation, such
   as to comply with a subpoena, bankruptcy proceeding, similar legal process,
   or in order to enforce or apply our agreements with you; or to protect the
   rights, property, or safety of Headspace Health, our customers, or others.
   This includes exchanging information with other companies and organizations
   for the purposes of fraud protection and credit risk reduction. We may also
   disclose personal information where we believe that doing so would be in
   accordance with or required by any applicable law, regulation or legal
   process
 * Affiliate and business transfer. If Headspace Health, including any of its
   subsidiaries, brands or affiliates, is involved in a merger, acquisition,
   asset sale, or other corporate combination, your personal information may be
   transferred to the acquiring or surviving entity. If such transfer results in
   a material change to the use of your personal information, we will provide
   notice before your personal information is transferred and/or becomes subject
   to a different privacy policy.

‍

 4. Your Rights and Choices 

‍

You may have rights and choices regarding our use and disclosure of your
personal information. Unless instructed otherwise, you can exercise these rights
and choices using the information in the Contact us section at the end of this
Privacy Policy.

 1. Privacy rights, choices, and preferences. If you have an account on our
    Platform, please visit your account for any privacy rights, choices, or
    preference options that may be offered. In your Headspace Health user
    profile, you are able to make additions or edits to any of your personal,
    payment, or membership information, and you may request to delete your
    account. You may also submit a request to help@headspace.com. For more
    information about your available privacy rights in certain jurisdictions for
    both accountholders and non-accountholders, please review our California
    Privacy Notice and European and UK Privacy Notice in the sections below.
 2. Opting out of receiving electronic communications from us. You will not
    receive promotional electronic communications from us if you have opted out
    of receiving such communications. If you wish to opt out, you may opt out
    via the unsubscribe link included in such emails or by contacting us at
    help@headspace.com. We will comply with your request as soon as reasonably
    practicable. Please note that if you opt out of receiving promotional emails
    from us, we may still send you important administrative messages that are
    required in order to provide you with our Products and Services or for other
    reasons disclosed in this Privacy Policy. For EU-based users only, we will
    ask for your consent prior to sending you any promotional electronic
    communications. 
 3. Your Nevada privacy rights. Nevada residents have the right to request to
    opt out of any “sale” of their personal information under Nevada SB 220. We
    do not currently sell personal information under Nevada law; however, you
    may still request to opt out of the future sale of your personal
    information. If you are a Nevada resident and would like to make such a
    request, please contact us using the information in the Contact us section
    at the end of this Privacy Policy, and provide “Nevada Privacy Rights” in
    the subject line. You must include your full name, email address, and postal
    address in your request so that we can verify your Nevada residence and
    respond. In the event we sell your personal information after the receipt of
    your request, we will make reasonable efforts to comply with such request.

‍

 5. Data security 

‍

The security of your personal information is important to us. We follow
generally accepted standards, practices, and procedures to protect the personal
information submitted to us, both during transmission and once it is received.
We maintain appropriate technical, administrative and physical safeguards to
help protect the security of your personal information against unauthorized
access, destruction, loss, alteration, disclosure or misuse.  

‍

If you have an account with us and you suspect unauthorized use of your account
or its credentials, you should notify us immediately using the information in
the Contact Us section at the end of this Privacy Policy.

‍

 6. Cookies and tracking technologies 

When you visit the Headspace Health Platform, we may collect information from
you automatically through Cookies. We also rely on service providers and other
partners to provide many features of our Platform using data about your use of
the Platform, which may include personal information. Please review the Cookie
Policy for more information regarding our collection of Cookies, the purposes
for which we use them, and how to exercise your preferences regarding them
including the ability to opt-out through our Platform or via your browser.

The Headspace Health Platform uses Google Analytics code to gather statistical
data. Google Analytics sets cookies to help us accurately estimate the number of
visitors to the Platform and the volumes of usage of the Products and Services.
This is done to ensure that the Platform and its associated Products and
Services are available when you want them and are fast. For more data on how
Google Analytics processes this data, visit www.google.com/analytics.

‍

We will acquire consent from you in order to use such trackers or provide you
with the opportunity to opt-out of such trackers, to the extent required by
applicable law. For more information on the types of cookies used by Headspace
Health and your ability to restrict the behavior of cookies or disable them in
your browser’s settings, please refer to the Cookie Policy.

‍

We do not support Do Not Track functionality. Do Not Track is a preference you
can set in your web browser to inform websites that you do not want to be
tracked. You can enable or disable Do Not Track by visiting the Preferences or
Settings page of your web browser.

‍

Other tracking on our Platform.  Our Platform, including our Websites, may
utilize tracking technologies to collect and record your activities and
movements across our Websites throughout your browsing session, including to
track button clicks, mouse movements, scrolling, resizing, touches, keystrokes,
data entered, device information and orientation, browser visual elements, and
screen size (“Session Data”), for purposes of our own internal analytics and
improving our products, services, and user experience. Such tracking may include
recorded sessions, which we may play back for these purposes.

‍

Our Platform also utilizes live chat and/or chat bot technology, which visitors
to communicate directly with our automated customer service system and/or
customer service representatives via a chat window about our Products and
Services. Text entered into this form prior to submission may be collected,
retained, and used by Headspace Health for our business purposes, including by
our customer service and other personnel and service providers.

‍

We may share Session Data and chat bot correspondence data with our third-party
analytics or service providers, which may change from time-to-time, for these
purposes, who will use the data solely on the behalf of, and for the benefit of,
Headspace Health. 

‍

 7. Children’s privacy

‍

Our Platform is intended for individuals at least 18 years of age, or the age of
majority in your province, territory or country. Individuals ages 13 of 18, or
the applicable age of majority, may utilize the Headspace Health Platform only
with the consent and involvement of a parent or legal guardian. This provision
is not applicable to registrations made under select subscriptions or special
offerings, including business to business sales and enterprise partnerships,
where specified in applicable contracts.

‍

If you are a parent or guardian and you are aware that a child under age 13 has
provided us with personal information without parental consent, please contact
us at help@headspace.com. If we become aware that we have collected personal
information from children under age 13 without parental consent, we will take
steps to remove that information from our servers.

‍

 8. International data transfers

‍

The Headspace Health Platform is operated exclusively in the United States. To
the extent Headspace Health offers Products and Services to individuals located
in the European Union or United Kingdom, or to the extent the Headspace Health
Platform is intentionally available to such individuals, please review our
European and UK Privacy Notice below for more information about disclosures and
privacy rights associated with that activity.  

‍

The subsidiaries, service providers or other third parties described in this
Privacy Policy and to whom Headspace Health may disclose your personal
information may be domiciled abroad, and, in particular, outside the European
Union and the United Kingdom. In such case, Headspace Health will require them
to take, in accordance with applicable legislation, contractual, organizational
and technical measures designed to ensure an adequate level of protection of
your personal information, such as the use of Standard Contractual Clauses
approved by the European Commission.

‍

We remain certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy
Shield (https://www.privacyshield.gov/) and are committed to the important
privacy principles set forth in Privacy Shield. To learn more about the Privacy
Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
https://www.privacyshield.gov/list.

‍

However, in light of the Schrems II decision by the European Court of Justice on
July 16, 2020, we are no longer relying exclusively on EU-U.S. Privacy Shield
and the Swiss-U.S. Privacy Shield and have implemented other transfer mechanisms
such as Standard Contractual Clauses to address any transfers of personal
information to the U.S., consistent with applicable law.

‍

For personal information collected from individuals located in the European
Union, Switzerland and the United Kingdom, you have the ability to opt out of
whether such personal information is disclosed to a third-party (apart from
service providers) or is to be used for a purpose that is materially different
for the purpose for which it was originally collected or subsequently
authorized. You can contact Headspace Health at help@headspace.com in order to
make such choices.

‍

General disputes arising from your use of the Headspace Health Platform, as well
as our Products and Services, can be found in our Terms & Conditions. However,
if you have any questions or concerns regarding our information collection, use,
and sharing practices as described in this Privacy Policy, you may reach us
using the Contact us section at the end of this Privacy Policy and we will
investigate the matter and resolve any issues, if we can. In the event that we
are unable to resolve any such questions or concerns, you may be able to invoke
binding arbitration, under certain conditions and as permitted by Privacy
Shield, by contacting our U.S.-based third party dispute resolution provider
(free of charge) at http://go.adr.org/privacyshield.html. Headspace Health is
subject to the investigatory and enforcement powers of the U.S. Federal Trade
Commission (“FTC”).

‍

Headspace Health is mindful of its responsibility and potential liability for
onward transfers of personal information to third parties where Headspace Health
deems such transfers necessary and those transfers are subject to Privacy
Shield.

‍

 9. Links to other websites

‍

Our Platform, including its Websites and Apps, may contain links to other
websites that are not operated by Headspace Health. We are not responsible for
the content or privacy policy policies of websites we do not own or control, and
our Privacy Policy does not apply to third-party websites. We strongly suggest
you review the privacy policies for third-party websites to understand how your
personal information is used and stored by those websites.

‍

 10. California Privacy Notice

 

This California Privacy Notice supplements information contained in our Privacy
Policy and applies to any California residents about whom we have collected
personal information from any source, including offline, and through your use of
the Headspace Health Platform.

 

We provide this California Privacy Notice to comply with applicable privacy laws
in the State of California, including the California Consumer Privacy Act of
2018, and its amendment, the California Privacy Rights Act of 2020 (together,
the “CCPA”). Any capitalized term used and not otherwise defined below has the
meaning assigned to it in our Privacy Policy. 

 

The CCPA provides California residents with rights to receive certain
disclosures regarding the collection, use, and sharing of personal information,
as well as rights to access, delete, correct, limit, and opt-out of the sales of
certain personal information we collect about them, as well as to opt-out of the
sharing of certain personal information for purposes of cross-context behavioral
advertising (called “sharing” under California law). California residents also
have the right not to receive discriminatory treatment by us for the exercise of
your privacy rights under the CCPA. If you are a California resident, you may
submit a request to exercise these rights by emailing us using the information
provided in the Your Privacy Rights section below. 

 

For the purposes of this California Privacy Notice, except where a different
definition is noted, “personal information” means information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular California
resident or household. Personal information does not include publicly available
information; lawfully obtained, truthful information that is a matter of public
concern; information that has been de-identified; or information that has been
aggregated. For purposes of this section, “publicly available information”
includes: information that is made available from federal, state, or local
government records; information that a business has a reasonable basis to
believe is lawfully available to the general public, either through widely
distributed media, or by the consumer; and information that is made available by
a person to whom the consumer has disclosed the information if the consumer has
not restricted the information to a specific audience.

 

For our CCPA disclosures with respect to Headspace Health’s collection, use and
disclosure of personal information for employment-related purposes, as well as
what privacy rights may be exercised as to such information, please review our
California Employee Privacy Policy.

 1. Personal information we collect

Headspace Health may collect, or has collected, the following categories of
personal information from California residents within the last twelve (12)
months:

‍

CATEGORY EXAMPLES Identifiers First and last name; e-mail address (personal
and/or work); telephone number; mailing address; social media identification
number; password and account credentials; National Provider Identifier (NPI)
Personal information categories listed in the California Civ Code § 1798.80(e)
First and last name; mailing address; payment card information; bank account
information; medical information; and health insurance information Internet or
other electronic activity information Cookie identifiers; pixel tags; embedded
scripts; tags; IP address, device identifier, device type, operating system and
Internet browser type, screen resolution, operating system name and version,
device manufacturer and model, language, plug-ins, add-ons, and the language
version of the Websites and Apps you are visiting; geolocation data, browsing
history, time spent on the Platform, pages visited, links clicked, language
preferences, patterns of use, and the pages that led or referred you to our
Platform including individual Websites and Apps Characteristics of protected
classifications under California or federal law Age; race and ethnicity; sexual
orientation; preferred pronouns; gender or gender identity; sex at birth;
marital status; mental, emotional, and physical status Commercial information
Payment histories; account balances and activity; Products and Services that you
have purchased, obtained, or considered; and/or other purchasing or consumer
histories, tendencies, and preferences Geolocation data Your precise location,
including based on Global Positioning System (“GPS”), and your approximate
location based on your IP address, device identifiers and other information
disclosed in this policy. Audio, electronic, or visual information Recordings of
calls to or from our customer service centers; customer service voicemails;
photographs Professional or employment-related information Employer name; job
title; work email; work telephone number Education information Student
identification number Inferences about you Inferences based on information about
an individual to create a profile about
a consumer reflecting the individual’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes

‍

‍

Please note that because of the overlapping nature of certain of the categories
of personal information identified above, which are required by state law, some
of the personal information we collect may be reasonably classified under
multiple categories.

Sensitive personal information.  Certain of the personal information that we
collect, as described above, may constitute “sensitive personal information”
under California law, including: 

 * Account log-in, financial account, debit card, or credit card number combined
   with any required security or access codes, passwords, or other credentials
   allowing access to an account;
 * Precise geolocation;
 * Racial and/or ethnic origin, religious or philosophical beliefs, or union
   membership;
 * Personal information concerning health; and
 * Personal information concerning sex life or sexual orientation.

The specific types of personal information we collect are further detailed in
Section 1 of this Privacy Policy. Personal information does not include
information excluded from the CCPA’s scope.

Headspace Health will not retain any information we collect about you for longer
than is reasonably necessary for the disclosed purpose of using such
information. Our determination of precise retention periods will be based on (i)
the length of time we have an ongoing relationship with you; (ii) whether there
is a legal obligation to which we are subject; and (iii) whether retention is
advisable in light of our legal position (such as in regard to applicable
statutes of limitations, litigation or regulatory investigations). 

 2. Uses of personal information

Headspace Health may collect, use, or disclose personal information about
California residents for purposes listed in Section 2 of our Privacy Policy.

The sensitive personal information that we collect as described in Section 10(a)
above may be used for any of the following purposes:

‍

PURPOSE

CATEGORY OF SENSITIVE INFORMATION USED

To provide our Products and Services, including the delivery of content and
facilitation of interactive features

Account log-in, financial account, debit card, or credit card number combined
with any required security or access codes, passwords, or other credentials
allowing access to an account; Precise geolocation; Racial and/or ethnic origin,
religious or philosophical beliefs, or union membership; Personal information
concerning health; and Personal information concerning sex life or sexual
orientation

To communicate with you regarding the Headspace Health Platform, Products and
Services

Precise geolocation.

To facilitate payment transactions, manage your orders, and account for
applicable sales taxes

Account log-in, financial account, debit card, or credit card number combined
with any required security or access codes, passwords, or other credentials
allowing access to an account

To maintain and improve the quality of the Headspace Health Platform, Products
and Services, including to perform research and development, understanding our
user trends, and understand the effectiveness of our marketing and advertising

Racial and/or ethnic origin, religious or philosophical beliefs, or union
membership; Personal information concerning health; and Personal information
concerning sex life or sexual orientation; precise geolocation.

 3. Sources of personal information 

We obtain the categories of personal information listed above from the following
categories of sources:

 * From you, including, for example, from forms you complete when registering
   for the Headspace Products and Services, surveys that you take, or as
   automatically collected when using our Platform.
 * Through our service providers, which are third party companies who help us
   provide Products and Services to you consistent with the purposes disclosed
   in this Privacy Policy.
 * Directly from Partners for select subscriptions that are verified as
   described in the Headspace Privacy Policy.
 * From our business partners and others, including those that may promote
   and/or offer products and services that may be of interest to you.

We may supplement the personal information collected from the categories of
sources described above with personal information we obtain from other sources.

 4. Disclosure of personal information 

We may disclose your personal information to the categories of service providers
and third parties identified in Section 3 of this Privacy Policy, and in ways
that are described in that section.

This includes disclosure of your personal information to service providers for a
business purpose. When we disclose personal information for a business purpose,
we enter a contract that describes the purpose and requires the recipient to
both keep that personal information confidential and not to use it for any
purpose except performing the contract. In the preceding twelve (12) months, we
have disclosed each categories of personal information listed in Section 10(a),
including the listed sensitive personal information, for a business purpose.  

Headspace Health does not “sell” personal information to third parties for
monetary or other valuable consideration as that term is defined by the CCPA as
amended by the CPRA. 

However, we do “share” personal information for purposes of cross-context
behavioral advertising, as that term is defined by the CCPA. Specifically, as
with many online companies, Headspace Health partners with third parties, such
as Facebook and Google, to manage our marketing of Headspace Health on other
platforms, where such advertising is based on your past visits to our Platform.
These third party partners may use technologies, such as Cookies, to gather
information about your activities on the Platform to deliver such advertising to
you when you visit their platforms. For instance, if you visit
www.headspace.com, a cookie may be attached to your browser in the form of the
Facebook Pixel that allows Headspace Health to deliver advertising to you on the
Facebook platform.  Please also review our disclosures in Section 6 of our
Privacy Policy (“Cookies and other tracking technologies”).  

The CCPA requires us to identify the categories of personal information that we
have “sold” or “shared” under the CCPA in the preceding twelve (12) months.  

In the last twelve (12) months, we have disclosed (or “shared”) the following
categories of personal information to advertising partners for cross-context
behavioral advertising purposes:  

 * Identifiers
 * Internet or other electronic network activity information

 5. Your privacy rights 

The CCPA provides California residents with specific privacy rights regarding
their personal information. This section describes your CCPA rights and explains
how to exercise those rights.

If you are a California resident, you have the right to make the following
requests under applicable California law in relation to your personal
information, subject to certain exceptions:  

 * Right to Know.  You have the right to, up to twice in a 12-month period,
   request what personal information we collect, use, disclose, and/or sell, and
   to whom, as applicable. You may request either a report disclosing the
   general categories of the personal information we collect, or a report
   disclosing the specific pieces of personal information we collect.
 * Right to Delete.  You have the right to request, under certain circumstances,
   the deletion of your personal information that we collect.
 * Right to Opt-Out of Sale or Sharing.  You have the right to opt-out of the
   “sale” or “sharing” of your personal information, as those terms are defined
   under California law. Please note that Headspace Health does not currently
   sell your personal information, though it does “share” your personal
   information with third parties for cross-context behavioral advertising as
   disclosed elsewhere in this section.   
 * Right to Non-Discrimination.  You have the right not to receive
   discriminatory treatment for the exercise of the privacy rights described
   above.  
 * Right to Limit Use and Disclosure.  You have the right to limit the use or
   disclosure of your sensitive personal information to only the uses necessary
   for us to provide our Products and Services to you, or for certain other
   authorized purposes. We will not use or disclose your sensitive personal
   information after you have exercised your right unless you subsequently
   provide consent for the use of your sensitive personal information for
   additional purposes.
 * Right to Correct.  You have the right to request the correction of your
   inaccurate personal information.

How to submit a request. To submit a request of any of the rights described
above, please submit a verifiable consumer request to us by either:

 * Emailing us at help@headspace.com
 * Calling us at 855-432-3822

Any request you submit to us is subject to an identification and residency
verification process (“Verifiable Consumer Request”) as permitted by the CCPA. 
We will not fulfill your request unless you have provided sufficient information
that enables us to reasonably verify that you are the consumer about whom we
collected the personal information on.  In order to verify you, you must provide
us with your first and last name and email address.  

Requests by authorized agents.  You may designate an authorized agent, in
writing or through a power of attorney, to request to exercise the above rights
on your behalf. If you should use an authorized agent to exercise your various
rights under the CCPA, we may require that you provide your authorized agent
with written permission to exercise your various rights and to verify your own
identity with us. If your authorized agent does not submit proof that they have
been authorized by you to submit verified requests for disclosure and deletion,
we reserve the right to deny such a request that we have received and will
explain to your authorized agent why we have denied such request. The authorized
agent may submit a request to exercise these rights by emailing the letter of
authorization or power of attorney to help@headspace.com.

Household data.  We collect household data in connection with our family plans.
If we receive a Request to Delete, Know, or Correct submitted by all members of
a household, we will individually respond to each request consistent with
California law. If we receive a Request to Opt-Out or Limit submitted by all
members of a household, we will process the request based on the information we
have about your household and the individuals associated with it, and reserve
the right to ask for further information if we determine it is needed to fully
process your request. We will not be able to comply with any such request by a
member of a household under the age of 13, as we do not collect personal
information from any person under the age of 13.

Responses.  We will respond to your request within forty-five (45) days after
receipt of a Verifiable Consumer Request for a period covering twelve (12)
months and for no more than twice in a twelve-month period.  Headspace Health
reserves the right to extend the response time by an additional forty-five (45)
days when reasonably necessary and provided consumer notification of the
extension is made within the first forty-five (45) days.

These rights are subject to various exclusions and exceptions under California
law and other applicable laws. In addition, if we are unable to verify your
identity to a degree of certainty as required by the CCPA through any reasonable
method, we will state that we are unable to verify in a written response to you
along with a reason as to why there is no reasonable method by which we can
verify your identity. 

Direct marketing by third parties.  Headspace Health does not disclose personal
information to third parties for their own direct marketing purposes. However,
California residents additionally have the right to request information
regarding such practices under California’s “Shine the Light” law. If you are a
California resident and would like to inquire further, please email
help@headspace.com.

We will continue to update our business practices as direct regulatory guidance
becomes available.  

 6. Notice of Right To Opt-Out

As detailed in Section 10(d) above, Headspace Health does not “sell” personal
information to third parties for monetary or other valuable consideration as
that term is defined by the CCPA as amended by the CPRA. However, Headspace
Health does “share” personal information with third parties for purposes of
cross-context behavioral advertising, as that term is defined by the CCPA.

If you wish to opt-out of the “sharing” of the limited data that is gathered
when you visit our Platform for purposes of cross-context behavioral
advertising, please visit the Cookie Policy and click “opt-out of marketing /
analytics cookies” at the bottom of the page. Doing so will erase all current
marketing cookies and disable the placement of future marketing cookies.

 * 
   

 11. European and UK Privacy Notice

 

This European and UK Privacy Notice applies to any individuals located within
the European Economic Area (EEA) or the United Kingdom (UK) from whom we may
have collected personal data from any source, whether online or offline,
including through your use of our Websites. We provide this European Privacy
Notice to comply with applicable privacy laws, including the General Data
Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and
guidance from the European Union and/or its member states.  Any capitalized term
used and not otherwise defined below has the meaning assigned to it in our
Privacy Policy. 

European law provides individuals located in Europe with rights to receive
certain disclosures regarding the collection, use, and sharing of personal data,
as well as rights to be informed, to access, to rectification, to erasure, to
restrict processing, to data portability, and to object with respect to
collected personal data.  For the purposes of this European and UK Privacy
Notice, “personal data” means any information relating to an identified or
identifiable natural person.

 1. Basis for processing your personal data

Headspace Health relies on one or more legal bases to process your personal data
under applicable law.  We may process personal data (i) as necessary to perform
our contractual obligations to you; (ii) as necessary to pursue our legitimate
interests as further detailed below; (iii) as necessary for our compliance with
our legal obligations such as a request or order from courts, law enforcement or
other government authorities; and/or (iv) with your consent, including to send
you marketing email messages and other information that may be of interest to
you, which you may withdraw at any time.

Legitimate business interests.  We may collect, process, and maintain personal
data to pursue the legitimate business interests outlined below.  To determine
these legitimate interests, we balance our legitimate interests against the
legitimate interests and rights of you and others, and only process personal
data in accordance with those interests where they are not overridden by your
data-protection interests or fundamental rights and freedoms.

Our legitimate interests generally include:

 * Provide you with requested Headspace Health Products and Services.
 * Provide you with customer service and support, including to send you messages
   and provide user support, and to facilitate other communications that you
   request or are required to render our Products and Services to you. This may
   include providing you with information about new products and other
   opportunities we offer that we believe may be of interest to you based upon
   your interactions with us, and to personalize, measure, and improve such
   offers.
 * Maintain and improve the quality of the Headspace Health Platform and the
   Products and Services that we offer through our Platform, including to
   customize our sites and products to better fit your needs as a user, develop
   new sites and products, to perform internal analytics for new and existing
   products (such as our user accounts and related features) and to conduct
   research and development. This also includes sharing personal data with our
   trusted service providers that provide services on our behalf.
 * Protect you and others and to create and maintain a trusted environment, such
   as to ensure compliance our agreements with you and other third parties, to
   ensure safe, secure, and reliable sites and products, and to detect and
   prevent wrongdoing and crime, assure compliance with our policies, and
   protect and defend our rights, interests, and property. 
 * Provide, personalize, measure and improve our marketing, including to send
   you promotional messages and other information that may be of interest to you
   with your consent. We may also use personal data to understand our user base
   and the effectiveness of our marketing.  This processing is done pursuant to
   our legitimate interest in undertaking marketing activities to offer products
   or services that may be of interest to you.
 * For risk management purposes, including compliance with our legal and
   regulatory obligations and for fraud detection, prevention and investigation,
   including “know your customer,” anti-money laundering, conflict and other
   necessary onboarding and ongoing client checks, due diligence and
   verification requirements, credit checks, credit risk analysis, compliance
   with sanctions procedures or rules, and tax reporting.
 * Comply with laws and regulations applicable to us, including any legal or
   regulatory guidance, codes, or opinions and to other legal process and law
   enforcement requirements, including any internal policy based on or
   reflecting legal or regulatory guidance, codes, or opinions. We may also
   respond to subpoenas, court orders, or legal process, and establish and
   exercise our legal rights or defenses against legal claims. 

 2. Your privacy rights

In certain circumstances, individuals located within the EEA and UK may have the
following data protection rights regarding their personal data:

 * Right to access. You may have the right to request confirmation of whether
   Headspace Health processes personal data relating to you, and if so, to
   request a copy of that personal data.
 * Right to rectification. You may have the right to request that Headspace
   Health correct or update your personal data that is inaccurate, incomplete or
   outdated.
 * Right to deletion. You may have the right to request that Headspace Health
   erase your personal data in certain circumstances provided by law.
 * Right to restrict processing. You may have the right to request that
   Headspace Health restrict the use of your personal data in certain
   circumstances.
 * Right to object to processing. You may have the right to object to Headspace
   Health’s processing of your personal data, under certain conditions.
 * Right to data portability. You may have the right to request that Headspace
   Health export the data that we have collected to you or another company,
   under certain conditions.

Where the processing of your personal data is based on your previously provided
consent, you have the right to withdraw your consent at any time.  If you would
like to exercise any of these rights, please submit a written request to
help@headspace.com. We will respond to these requests in accordance with
applicable data protection laws. We may ask you to verify your identity in order
to help us respond efficiently to your request.

You may also have the right to lodge a complaint about our data collection and
processing actions with the appropriate supervisory authority.  If you are in
the European Economic Area, you can view the contact information for your data
protection authority here.  If you are in the United Kingdom, please visit this
page.

 3. Retention of personal data

We will retain personal data for as long as needed or permitted in light of the
purpose(s) for which it was obtained. The criteria used to determine our
retention periods include:  (i) the length of time we have an ongoing
relationship with you; (ii) whether there is a legal obligation to which we are
subject; and (iii) whether retention is advisable in light of our legal position
(such as in regard to applicable statutes of limitations, litigation or
regulatory investigations).

‍

 12. Changes to this Privacy Policy

‍

We may change this Privacy Policy from time to time to reflect new services or
changes in our data practices or relevant laws. The “effective date” legend at
the top of this Privacy Policy indicates when this Privacy Policy was last
revised. Any changes are effective when we post the revised Privacy Policy on
the Headspace Platform, including the Websites. We may take reasonable measures
to notify you via email and/or a prominent notice on our Platform prior to
certain changes becoming effective, and will update the effective date at the
top of this Privacy Policy. You are advised to review this Privacy Policy
periodically for any changes.

‍

 13. Contact Us

‍

Questions, comments and requests regarding this privacy policy are welcomed and
should be addressed to help@headspace.com. In the alternative, you may reach
Headspace Health customer support at 855-432-3822.

‍


‍

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© Headspace Health 2023
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Our Approach
The ScienceOur care modelOur Impact
Resources
All ResourcesEvents and WebinarsBlogCustomer StoriesWhite Papers and Research
Company
AboutContact UsGinger is now a part of HeadspaceHeadspace Training
InstituteCookies Settings
Support
FAQhelp@headspace.com


© Headspace Health 2023
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