1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you:
- Personal information including, for example, your name, e-mail address, telephone, credit or debit card or other payment information, information about your usage of the Products and information collected by tracking technologies as further described below that may identify you as an individual or allow online or offline contact with you as an individual.
- For individuals using the Products in connection with a Community client account as described in section 6, business information such as your company name, and company email address.
- Facebook profile information, such as name, email address, and Facebook ID, if you choose to log in to the Products through Facebook.
- Device Information such as operating system version, device type, and system performance information.
- Information collected via tracking technologies, as fully described in section 4
- If you choose to invite a “Buddy” to use the Products using our Buddy system, we will ask you for their name and email address. We will use this information to invite him or her to join the Products. We store this information for the sole purpose of sending invitations and tracking the success of our Buddy program. If your Buddy would like us to delete his or her information, they can do so by opting-out as described in each invitation or by contacting us at email@example.com.
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. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org. Except as described under the “Disclosure of Your Information” section below, we do not provide your personal information to any third party without your specific consent.
3. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive email newsletters or promotional materials from us we will use the information you give us to provide the communications you have requested.
If you inform us that you wish to cancel email newsletters or promotional materials by selecting unsubscribe at the bottom of such communication or by emailing us at email@example.com, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level.
4. TRACKING TECHNOLOGIES
Headspace 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 information several times during one task, 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 measuring how many people are using services.
We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
We partner with third parties, such as Facebook, to manage our advertising of the Products on other sites or platforms. Our third party partners may use technologies such as cookies to gather information about your activities within the Products to deliver such advertising to you, such as retargeting ads. We currently do not respond to do-not-track signals. For more information about interest-based ads, including how to opt-out of having your web-browsing information 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.
We use third party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third party platforms.
The Products use Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visit www.google.com/analytics.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the Products, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.
As true of most websites, we gather certain information and automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us through the Products is stored on our secure servers located in the US and UK. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on Headspace’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
6. CORPORATE AND OTHER COMMUNITY SHARING
While Headspace is a consumer products company, there is increasing interest by large consumer communities (corporations, universities, hospitals, etc.) (“Communities”) to introduce the Products to their employees and members. If you have registered to use the Products through a code or other registration credential furnished by a Community (a “Community Subscription”), the Community will have access to your name and the date you registered to use the Products and will have access to your usage information on an aggregated basis with all other members of the Community that are using the Products. While we do not otherwise share your personal information with your Community, when you register to use the Products you will have the opportunity to opt-in to agree to share additional personal information as well as usage information with your Community, and in this case, your Community will have access to this information. For example, many employers are offering incentive programs based on employee participation in health & wellness programs and desire to better understand how each of their employees is using the Products.
7. SINGLE SIGN-ON
You can log into our Products using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you to the option to post information about your activities on our Products or to your profile page to share with others within your network.
8. ACCESS TO AND DELETION OF PERSONAL INFORMATION
You may access your personal information at any time via an online account, or by emailing firstname.lastname@example.org.
To request the deletion of your personal data that we have on file please email us at email@example.com.
We will respond to your request in a reasonable timeframe.
9. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
- To provide you with information, products or services related to Headspace that you request from us or which we feel may interest you, unless you have requested that we not provide this information.
- To provide you with customer service communications.
- To carry out our obligations arising from any agreements entered into between you and us.
- To allow you to participate in interactive features of the Products, when you choose to do so.
- To notify you about changes to the Products.
- To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
- To inform your Community about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above.
- To serve our advertisements to you through third party platforms, such as Facebook.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through the Products and of the fulfillment of your Product orders.
- Details of your visits to and interactions with the Products including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you.
We do not disclose information about identifiable individuals to companies that host advertisements on our behalf, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
10. 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. It is the responsibility of any third party that you authorize to receive data to protect that information in accordance with applicable laws, and use it only to provide the services or information you have requested.
- In some circumstances, we may disclose the personal information that you have provided to Headspace to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, or bundled pricing options.
- If Headspace’s service providers (like hosting, market analytics, and payment service providers) require this information to provide services to Headspace. Headspace requires each of its service providers to agree to maintain the confidentiality of your personal information disclosed.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- If Headspace or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
- 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, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- With your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.
- With third parties, such as Facebook, in order to serve Headspace advertisements on such third party platforms.
11. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.
12. SOCIAL MEDIA WIDGETS
Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
Apple iOS users may opt-in to allow the Products to provide data regarding the amount of minutes meditated to the Apple iOS “Health” application for display. This data will not be shared with third parties or used for marketing purposes.
14. USE OF HEADSPACE BY MINORS
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person's account and otherwise subject to these Terms.
15. INFORMATION POSTED ON FORUMS
Headspace users may have the ability to post content to one or more Headspace forums. All such users may request and obtain removal of such posted content by contacting Headspace at firstname.lastname@example.org and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Headspace forum(s).
Headspace’s physical address is 2415 Michigan Avenue, Santa Monica, CA 90404.