Headspace Health Privacy Policy

April 04, 2022

Headspace, Inc., Headspace Meditation Limited, and Ginger.io, Inc. (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 website, www.headspacehealth.com (the “Website”) and other products, services and features thereof, including but not limited to our mobile applications and administrative tools related to our Headspace Health mental health offerings, including Headspace, Headspace for Work, and Ginger (the Website, and such other products, services and features are collectively referred to herein as the “Headspace Health Product(s)”, or “Product(s)”, 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 set forth the basis on which any personal information we collect from you, or that you provide to us, in connection with your information requests related to the Headspace Health Products will be processed by us. 

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

1. INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

  • Personal information including, for example, your first name, last name, work e-mail address, job title, company name, telephone number, and any additional information you may provide to us in connection with communications regarding the Headspace Health Product(s).
  • Data collected via tracking technologies, as fully described in section 5.

2. CONFIDENTIALITY AND SECURITY

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

3. WHITEPAPERS OR OTHER ELECTRONIC COMMUNICATIONS

If you sign up to receive materials from us via email we will use the information you give us to provide the communications you have requested. If you inform us that you wish to cancel receiving materials by emailing us at help@headspacehealth.com, we will remove you from our mailing list.

If you provide your phone number to us directly or through a third-party for the specific purpose of getting in touch with a member of our team to bring any of the Headspace Health Product(s) to your organization, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply.

4. WHERE WE STORE YOUR PERSONAL INFORMATION

All personal information you provide to us is stored with our sales and marketing vendors. For additional information regarding where data collected via tracking technologies is stored, please refer to section 5. 

5. TRACKING TECHNOLOGIES

Headspace Health and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Headspace Health Product(s).

We additionally use browser local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.

We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads. We do not respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.

We use third party trackers to let us know when users have visited the Headspace Health Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Headspace Health Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Headspace Health Products and the volumes of usage of the Headspace Health Products. This is done to ensure that the Headspace Health Products 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 Headspace Health Cookie Policy.

6. ACCESS TO AND DELETION OF PERSONAL INFORMATION

Upon request, Headspace Health will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email help@headspacehealth.com.

You may access your personal information or modify it at any time by emailing help@headspacehealth.com.

To request the deletion of your personal data from our sales and marketing vendor systems, please email us at help@headspacehealth.com. We will respond to your request in a timely fashion as dictated by applicable law.

7. USES MADE OF THE INFORMATION

We use information you provide and as described above in the following ways:

  • To provide you with information related to the Headspace Health Products. 
  • To contact you in order to discuss the Headspace Health Products.
  • To notify you about updates or changes to Product features and content.
  • To answer your questions or requests for information or handle your complaints.
  • 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.

 

8. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also disclose your personal information to third parties as follows:

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 you have requested from such party, or fulfill a request for information from such party. 

If Headspace Health’s service providers require this information to provide services to Headspace Health. Headspace Health requires each of its service providers to agree to maintain the confidentiality and security of your personal information.

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 proceedings, 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.

 

9. CONTACT AND EEA REGISTERED AGENT

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

Our registered agent within the European Economic Area is Headspace France SAS, which can be contacted at 102 Ave des Champs Elysees, 75008 Paris 8.

Our registered agent within the United Kingdom is Tricor, which can be contacted at Tricor Suite, 4th Floor, 50 Mark Lane, London, EC3R 7QR.

Headspace Health’s principal office address is 2415 Michigan Avenue, Santa Monica, CA 90404.

10. TRANSMISSION TO OTHER COUNTRIES

The subsidiaries, service providers or other third parties listed above to whom Headspace Health may disclose your personal data may be domiciled abroad, and in particular outside the European Union, Switzerland, 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 data, 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 data to the U.S., consistent with applicable law.

For personal data collected from individuals located in the European Union, Switzerland and the United Kingdom, you have the ability to opt-out of whether such personal data 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@headspacehealth.com in order to make such choices.

General disputes arising from your use of our Websites, Apps, Products, and other 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 or in this Section 21 regarding Privacy Shield, you may reach us using the contact information at the end of this 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 data to third parties where Headspace Health deems such transfers necessary and those transfers are subject to Privacy Shield.

CCPA ADDENDUM

Effective Date: January 1, 2020 Last Reviewed On: June 30, 2021

This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.

 

1. INFORMATION WE MAY COLLECT FROM YOU

Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:

 

CATEGORY EXAMPLES COLLECTED

Identifiers First and last name, email address, Internet Protocol address, online identifiers. Yes

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). First and last name. Yes

Internet or other similar network activity. Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms. Yes

The specific types of personal information we collect are described more fully in section 1 of the Privacy Policy. Personal information does not include: (1) deidentified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope.

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

Directly from you. For example, from forms you complete when registering for the Products. Indirectly from you. For example, from observing your actions on our Products.

Directly from Partners associated with your Community, if you have a Community Subscription that is authenticated through the Community’s use of eligibility files as described in section 6 of the Privacy Policy.

 

2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for the purposes described in section 9 of the Privacy Policy.

 

3. SHARING PERSONAL INFORMATION

We may disclose your personal information to third parties 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 the following categories of personal information for a business purpose:

  • Category 1: Identifiers
  • Category 2: Personal Information
  • Category 3: Internet activity

Specific examples of such sharing activities can be found in sections 6 and 11 of the Privacy Policy.

We do not sell your personal information to third parties.  We do share a limited set of data that is gathered when you visit our Websites, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements, as further detailed in Section 4 of our Privacy Policy. To the extent this online advertising activity is interpreted as included in California’s broad definition of “data sale”, you may use the opt-out tools described below in Section 5 of this CCPA Notice.

 

In the last twelve (12) months, we’ve disclosed the following categories of personal information to advertising partners as described above:

  • Category 1: Identifiers
  • Category 2: Personal Information
  • Category 3: Internet activity

4. YOUR RIGHTS AND CHOICES

Access to Specific Information and Data Portability Rights

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

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The categories of personal information we share with third parties.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.

We may deny your deletion request if certain CCPA exemption apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 
  • Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Emailing us at help@headspacehealth.com
  • Calling as at 855-432-3822

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We also provide an easy-to-view snapshot of your personal information that we have processed via the “My Data” tab in the Products.

Response Timing and Format

Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Notice of Right To Opt-Out

Like most companies, we partner 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 Products. These third party partners may use technologies, such as cookies, to gather information about your activities on the Products 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.

Accordingly, while we do not sell your personal information, if you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites for purposes of targeted digital advertising, as described in this CCPA Notice and our Privacy Policy, you can opt-out by visiting the Headspace Cookie Policy and clicking “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.

We do NOT use cookies so that third parties can serve ads to you about their own products or services.

We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.

6. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

7. Changes to our CCPA Addendum

We reserve the right to amend this CCPA Addendum at our discretion and at any time. When we make changes to this CCPA Addendum, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.

 

8. Contact Information

If you have any questions or comments about this CCPA Addendum, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

  • Email: help@headspacehealth.com
  • Phone: 855-432-3822
  • Postal Address: Headspace Health, Inc., Attn: Legal-CCPA; 2415 Michigan Avenue, Santa Monica, CA 90404