Last update: 06/30/2021
We may collect and process the following data about you:
We use information held about you in the following ways:
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at firstname.lastname@example.org. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. Headspace maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email 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. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Products.
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 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 Products.
We use 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 Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Products use Google Analytics code to gather statistical data. 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 data on how Google Analytics processes this data, 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 data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
As true of most websites, we gather certain data and automatically and store it in log files. This data 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.
All data you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment data 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 data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
Headspace is also offered through partnerships with organizations. Sometimes corporations, governments, hospitals, universities and other organizations and groups (“Partner(s)”) wish to make Headspace available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to Headspace and brands that promote wellness may wish to and do offer Headspace through their loyalty programs. When an entity provides access to Headspace to others, we call those “Communities.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Community Subscription”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Community's aggregated and anonymized general usage data (including aggregated and anonymized usage data with respect to your Community’s optional engagement with the My Progress feature).
You may be able to log-in to 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 data (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 data about your activities on our Products or to your profile page to share with others within your network.
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “My Data” tab in the Products.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Headspace will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Headspace may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to Headspace, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Headspace. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Headspace. Headspace may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Headspace account and following the instructions here.
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Headspace’s personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Headspace instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email firstname.lastname@example.org. You may access your personal data to modify or update at any time via an online account, or by emailing email@example.com. We will respond to your request in a reasonable timeframe in accordance with applicable law.
In accordance with GDPR, Headspace provides the following information regarding its Article 6 legal bases for personal data processing: The performance of the contract (the Headspace Terms & Conditions) between you and Headspace for the data processing relating to your use of Headspace’s Products (including your orders and payments);
Headspace’s legitimate interest, more specifically:
We may disclose your personal data with and among our subsidiaries, ultimate holding company, and any affiliates, which include Headspace Meditation Limited and Headspace Health Inc.
We may also disclose your personal data to third parties as follows:
The retention periods applied by Headspace comply with applicable legislation in effect on the date hereof, namely:
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing firstname.lastname@example.org.
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 data to these external websites.
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.
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 of a parent or legal guardian under such person's account.
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 email@example.com 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).
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’s principal office address is 2415 Michigan Avenue, Santa Monica, CA 90404.
The subsidiaries, service providers or other third parties listed above to whom Headspace 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 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 are working to implement 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 at firstname.lastname@example.org in order to make such choices.
Headspace is mindful of its responsibility and potential liability for onward transfers of personal data to third parties where Headspace deems such transfers necessary and those transfers are subject to Privacy Shield.
Effective Date: January 1, 2020 Last Reviewed On: June 30, 2021
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:
|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|
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.
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:
In the last twelve (12) months, we’ve disclosed the following categories of personal information to advertising partners as described above:
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:
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 email@example.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.
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.
Like most companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Headspace 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 to deliver advertising to you on the Facebook platform.
We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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.
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.