Effective Date: January 31, 2024

Scope and Overview

Headspace is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how Headspace, including Headspace, Inc., Ginger.io, Inc. Ginger.io of California Medical P.C., and their subsidiaries, affiliates, and related entities (collectively, "Headspace," "we," or "us") collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants only.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. Headspace may collect personal data directly from you, as a job applicant, or may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process personal data, including, but not limited to, the following categories, which we require in connection with our recruiting activities:

• Identifying information, such as your name, title, addresses, telephone numbers, personal email addresses, gender, date of birth, and signature.
• Demographic data, such as your race, ethnic origin, marital status, disability, and veteran or military status.
• National identifiers, such as your Social Security number, driver’s license/identification card number, passport and visa information, and immigration status and documentation.
• Professional background, such as your work history, training, professional memberships, proof of work eligibility, and other relevant experience including information contained in a resume, CV, cover letter, or job application.
• Educational background, such as education information including degrees awarded, transcripts, and other information provided in support of the job application.
• Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, and workplace illness and injury information.
• Application information, such as information collected during phone screenings and interviews, details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits, reference information and information received from background checks, where applicable, including information provided by third parties, and information related to previous applications to Headspace or previous employment history with Headspace.

The personal data listed in this notice is mandatory in connection with our recruiting activities. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Privacy Notice.

We will collect the majority of the personal data that we process directly from you. In limited circumstances third parties may provide your personal data to us, such as former employers, official bodies (such as regulators or criminal record bureaus), medical professionals, and/or other sources.

Use of Personal Data

We only process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, or with your consent if applicable law requires consent. We may process your personal data for the following legitimate business purposes:

• Identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
• Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application and managing your employment relationship with us, including for:
  • Onboarding processes;
  • Other human resources purposes.
• Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
• Creating and submitting reports as required by applicable laws or regulations.
• To comply with our legal, regulatory, or other corporate governance requirements.
• Conducting internal audits and workplace investigations.
• Analyzing and improving our application and recruitment process, including performing analytics and benchmarking.
• Exercise or defend the legal rights of Headspace and its employees, affiliates, customers, contractors, and agents.

We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation. We may also process your personal data for our own legitimate interests, including for the following purposes:

• To prevent fraud.
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

Collection and Use of Special Categories of Personal Data

We may collect and process the following special categories of personal data when you voluntarily provide them, or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits:

• Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
• Race or ethnic origin to comply with statutory obligations.
• Previous criminal charges or convictions where relevant for the position.

Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Data Sharing

We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

• To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
• As part of our regular reporting activities to other members of our group of companies.
• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
• To protect the rights and property of Headspace.
• During emergency situations or where necessary to protect the safety of persons.
• Where the personal data is publicly available.
• If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
• For additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Notice. If you are located in the EU/EEA, we have implemented the data transfer mechanism from Article 49(1)(b) of the General Data Protection Regulation (GDPR) to secure the transfer of your personal data to the United States and other jurisdictions.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy.

Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Headspace, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Headspace, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the recruitment process. By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party. If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at Talent@Headspace.com. Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or anonymized your personal data in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at Talent@Headspace.com.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time. We will provide the updated Privacy Notice on this website and we encourage you to periodically review it. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

Contact Us

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: Talent@Headspace.com.