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HEADSPACE PRIVACY POLICY

PRIVACY
Privacy Policy
Notice of Privacy Practices
Cookie Policy




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Effective: January 1st, 2024

If you are visually impaired, have another disability, or seek support in other
languages, you may access this Privacy Policy by emailing us at
help@headspace.com.

As part of our company values, especially putting members first, we at Headspace
are committed to protecting and respecting your privacy in connection with your
use of our content and products via our websites, including www.headspace.com
(“Websites”), our applications, including the Headspace mobile app (“Apps”), or
other delivery methods (Websites, Apps, and other delivery methods are
collectively referred to as our “Products”). Headspace may deliver coaching
services, psychotherapy services (i.e. therapy), and psychiatry services
(collectively the “Services”) using the Products or via other delivery methods,
as applicable. Headspace provides the Services through its affiliated medical
providers and partners, including Ginger.io of California Medical P.C. (“Ginger
Medical”) or third party medical providers (Ginger Medical and these third party
medical providers will be collectively referred to as our “Care Providers”).
Throughout this Privacy Policy, we will collectively refer to all of our
Products and Services as our “Platform.” This Privacy Policy covers the
“personal information,” meaning information about an identified or identifiable
individual that is collected through our Product or Services.

Depending on how you interact with us, the following may also apply to you:

 * Our Services are delivered by our Care Providers. For those Care Providers in
   the US, they are classified as covered entities under the Health Insurance
   Portability and Accountability Act (HIPAA). Headspace is subject to HIPAA as
   our Care Providers’ business associate. Our Care Providers may provide you an
   additional privacy notice during enrollment which we encourage you to review.
   For example, if you receive Services from Ginger Medical, you can access
   their Notice of Privacy Practices here. If you are outside the US and use our
   international Care Providers, you may still receive an additional privacy
   notice from them as relevant to the applicable law in your area.
 * Some components or features of our Platform may include additional privacy
   notices, such as an optional feature that uses your personal information in a
   unique way. Similarly, you may have been given access to our Product or
   Services in a manner that includes additional terms or privacy notices such
   as from your employer. The language of those terms and privacy notices
   supplement this Privacy Policy unless there is a conflict, in which case
   those additional terms and privacy notices will apply.
 * You may follow links contained in our Platform or provided to you by other
   users to third-party websites or products not operated by us. This Privacy
   Policy does not apply to third-party websites or products. We strongly
   suggest you review their privacy policies to understand how your personal
   information is used and stored by those third parties.
 * Similar to the above point, you may use single sign-on (SSO) features to
   access our Platform, such as through your social media accounts or through
   your employer. That use may be subject to your SSO provider’s terms and
   privacy policies, and we encourage you to review them prior to using those
   features.
 * This privacy policy does not apply to Headspace employees or applicants to
   Headspace. Applicants can learn about how we use their personal information
   by reading our Applicant Privacy Notice here, and employees will be provided
   further details as part of onboarding.

Please read the following carefully to understand our practices regarding your
personal information. We also encourage you to review our end-user terms and
conditions here.


TABLE OF CONTENTS

This Privacy Policy is provided in a layered format. We provided summaries for
each section, but we encourage you to read each section in detail.

1. Collection of personal information We may collect your personal information
through our Platform, or when you otherwise share your information with us. Our
collection may require your input or can be automatically collected while you
engage with us. 2. Use of personal information We primarily use your personal
information for our Products and Websites to function and to deliver you the
Services. We also may use your personal information for other purposes like
communicating to you about your interest in our Platform, processing payments,
complying with legal obligations, or to develop new features or improvements. 3.
Sharing of personal information We may share your personal information with
certain third-party service providers to help make our Platform function. We may
also share personal information as directed by you, to provide you with
opportunities we think may interest you, or as legally required, such as to
comply with a court order. 4. Data security and retention The security of your
personal information is of utmost importance to us. We retain your personal
information for as long as necessary, and we maintain appropriate safeguards to
protect it. 5. Your privacy rights We want you to have choice in how your
personal information is used. We provide you rights to request actions regarding
your personal information including deletion, no matter where you reside.
Further rights may be provided for your specific jurisdiction, which are
outlined in Section 10. 6. Children's Privacy Our Platform is generally intended
for adults, except in limited circumstances depending on your offering. 7.
Cookies When you visit our Websites, we may collect certain information from you
automatically through cookies and other tracking technologies. You can decide
what cookies are deployed using the cookies settings on our Websites. 8. Changes
We may change this Privacy Policy to reflect new services, changes in our data
practices, or to comply with relevant laws. 9. Contact us You may contact us for
comments, questions, or to exercise your privacy rights in various ways
including emailing help@headspace.com 10. Supplemental notices This section
provides additional information specific to certain jurisdictions. Please note,
that our Platform is operated in the United States where your personal
information will be primarily processed and stored.


1. COLLECTION OF PERSONAL INFORMATION

We may collect or process the following personal information about you from what
you provide us directly, we receive from others, and personal information we may
automatically collect when you interact with our Platform.

(a) Information you provide to us

 * 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 Products via a social media account.
 * 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
   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.
 * Health information. We will collect the information you provide about your
   health and wellness as you use our Products or engage with the Services. You
   may provide this information through the Products, such as through survey
   responses about your current mental or physical health status, setting your
   health or wellness goals, or in other inputs that relate to your health or
   wellbeing. You may also provide this type of information through the
   Services, such as talking with your coach or therapist about your current
   health needs or during treatment. We understand that this information is very
   sensitive so we handle it with care, including treating this health
   information as protected health information under HIPAA where applicable.
 * Profile and demographic information. Through your account in our Product, you
   may have the 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 does not directly process payment card
   information, and instead relies upon 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.
 * Survey information. We may present you with surveys for Product
   functionality, to provide you the Services, 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, your use of the Platform, or feedback on future
   improvements.
 * Communication information. When you send or respond to emails, messages,
   chats, or other communications from Headspace, 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 Products, we may collect the content of those
   communications.
 * Support information. When you submit a support request or otherwise engage
   with our support team, we collect the information you provide as part of that
   interaction. We also utilize live chat and/or chatbot technology, which allow
   you 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 for our business purposes, including by our
   customer service and other personnel and service providers.

(b) Information from others

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

 * If you receive access to Headspace through your employer, health plan, or
   another party that sponsors your access (your “Benefit Sponsor”), we collect
   your name and email address and other information that your Benefit Sponsor
   submits to us to facilitate your enrollment in our Products and Services.
 * 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 for operating
   accounts for their dependants aged 13-17 where supported.
 * 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.

(c) Information we automatically collect

Our Products and Websites may collect information from you automatically during
your use which 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 Products you are
   visiting.
 * Usage data, such as time spent on the Products and Websites including pages
   visited, links clicked, approximate location, language preferences,
   performance of features, patterns of use, and the pages that led or referred
   you to our Products and Websites.

(d) Aggregated, anonymous, and de-identified data We may create or collect
aggregated, anonymous, or de-identified data from personal information by
removing, masking, or otherwise altering data components that make the data
personally identifiable, or potentially personally identifiable to you
(“De-Identified Data”). De-Identified Data is not personal information and not
subject to this Privacy Policy.


2. USE OF PERSONAL INFORMATION

We may use your personal information in the following ways:

 * To provide our Platform, including the delivery of content and interactive
   features;
 * To communicate with you regarding our Platform including updates or changes;
 * To provide you support, answer your questions or requests for information, or
   handle your complaints;
 * To process payment, manage your orders, and account for applicable sales
   taxes;
 * To inform your Benefit Sponsor, if you have one, about your registration and
   other information as described in Section 3 below;
 * To fulfill our obligations under any agreements that we may have with you;
 * To maintain and improve the quality of our Platform, including to perform
   research and development, understand user trends, and, in a limited way,
   understand the effectiveness of our marketing and advertising such as
   recording a sales conversion;
 * 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 personalize the advertisements you receive about our Platform through
   third-party platforms, on other websites and apps;
 * To protect ourselves, you and others such as by taking actions to prevent
   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 including meeting regulatory compliance
   obligations, responding to subpoenas, court orders or other legal processes;
   and
 * to establish or exercise our legal rights or defense against legal claims.


3. SHARING OF PERSONAL INFORMATION

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

 * Our service providers. In some circumstances 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, based on
   our instructions and are contractually obligated to maintain the
   confidentiality and security of your personal information, and to not
   disclose or use your personal information for any other purpose inconsistent
   with this Privacy Policy and applicable law.
 * Your integrations. You may connect your account through supported
   integrations with third parties and we will share your personal information
   with those third parties. If you do connect an integration, that third
   party’s terms and privacy policy may apply to the personal information shared
   as a result and we encourage you to review those before setting up the
   integration. For example, if you are on iOS, you may connect our Products to
   Apple’s Health Kit. If you do, iOS Privacy Policy and Terms of Use apply, and
   can be reviewed at www.apple.com/legal/privacy.
 * Community Activity. If you engage with other Platform users using our
   community features, we will share some information about you such as your
   name associated with your comment on a forum or other information you choose
   to share with other users.
 * Your Benefit Sponsor. In limited cases, we may provide certain personal
   information to your Benefit Sponsor, including your name, email address, your
   registration date, and the date on which you last used our Platform.
   Generally, we restrict this sharing to not include specific details of your
   in-app activity or any details about your use of Services, like therapy. This
   restriction may not apply where sharing some of your activity is necessary
   for your treatment, payment, or healthcare operations such as if your Benefit
   Sponsor is your other healthcare provider, health insurance provider, or
   health plan.
 * 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, bundled subscription offer, 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.
 * Third party advertising platforms. We work with third party platforms who
   provide us with analytics and advertising services. This includes helping us
   understand how users interact with our Platform serving advertisements on our
   behalf to those who may be interested, and measuring the performance of those
   advertisements.
 * 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 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. 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.
 * Affiliates and business transfer. We may share your personal information with
   any member of our business group, which includes our subsidiaries and our
   affiliates including Ginger Medical and its medical professional corporation
   affiliates for any of the purposes described in this Privacy Policy. If
   Headspace, including any of our 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 or becomes subject to a different privacy policy.


4. DATA SECURITY AND RETENTION

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.

No security can be fully guaranteed, though. If you have an account with us and
you suspect unauthorized use of your account or its credentials, you should
contact us immediately using the contact information in Section 9 below or
contact our security team directly at security@headspace.com.

We will keep your personal information for as long as needed to perform our
obligations to you, or for as long as legally permitted. 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). For example, we keep your account information, like
your name, email address, and password, for as long as your account exists so
that you may access it.


5. YOUR PRIVACY RIGHTS

We believe that you should have control of your personal information. To that
end we provide the following rights to make requests regarding your personal
information. You may make these requests by contacting help@headspace.com or in
some cases using features within the Platform:

 * Access. You have the right to know what personal information we collect about
   you and how we use it. This Privacy Policy serves to inform you about that
   collection and use. If we have personal information about you, you may also
   request a copy of that information.
 * Correction. You have the right to request the correction of your inaccurate
   personal information.
 * Portability. You may request an export of your personal information in a
   structured and machine readable format such as a .csv or .pdf. Where
   feasible, we can send that export to a third party you identify.
 * Deletion. You have the right to request, under certain circumstances, the
   deletion of your personal information that we collect.
 * Restriction. You have the right to request that Headspace restrict the use of
   your personal information in certain circumstances. Please note that in some
   cases we may not be able to place a restriction due to the use being
   necessary for Product functionality or delivery of the Services.
 * No retaliation or discrimination. You have the right not to receive
   discriminatory or retaliatory treatment for making a request.

Upon receiving your request, we may ask for additional information from you in
order to verify the request or confirm how you would like to proceed. We
endeavor to respond to a verifiable request without undue delay. If we require
an extended amount of time, we will inform you using the email associated with
your account or the email you used to make the request.

We do not charge a fee to process your verifiable request unless it is
excessive, repetitive, or clearly unfounded. If we determine that your request
requires a fee, we will tell you why and provide you with a cost estimate before
completing your request.

Your rights are not absolute, and exceptions may apply. These exceptions can
arise from different factors including our legal obligations, the rights of
others, your or another’s safety, and our ability to bring or defend against
legal claims. Additionally, we will not fulfill your request if you do not
provide sufficient information to verify your identity or to verify that a third
party making the request is authorized to act as your representative.

Some US jurisdictions provide residents with certain rights with respect to
their personal information as defined under applicable law. These rights are
subject to the specific laws of that jurisdiction and that certain other rights
might apply. Please review our Supplemental Notices, including our Privacy
Notice for EU and UK, our Privacy Notice for California, and our Privacy Notice
for Virginia, Connecticut, Colorado, Utah, and Nevada for more information on
rights and terms specific to your location or place of residence.


6. CHILDREN’S PRIVACY

At Headspace, we are committed to protecting and respecting children’s privacy.
Our Platform is generally intended for individuals at least 18 years old and we
do not intentionally collect personal information from individuals under 18
years old. There are limited exceptions:

 * If you are in the US and participate in our Headspace for Teens offering or
   through certain Benefit Sponsors’ offerings, you may register an account as
   long as you are at least 13 years old.
 * If you are a US user 13 to 17 years old who may have joined as noted above,
   you may enroll in the Services with verifiable parent or guardian consent.
 * If you are a parent under our employee assistance program (EAP), you may
   refer your child of at least 6 years old to our Care Providers for in-person
   care but cannot create an account for them.

You also may notice some content in our Products that appears geared towards
children. This content is only meant for you to share with your child under your
supervision, and does not require or allow your child to create an account.

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


7. COOKIES

When you visit our Websites, we may collect information from you automatically
through cookies including cookies provided by third parties. We use cookies and
the information they collect for a variety of purposes including functionality,
analyzing performance, security, personalizing Website content, and advertising.
We will get your consent in order to use such trackers or provide you with the
opportunity to opt-out of cookies, to the extent required by applicable law. You
may use an opt-out preference signal, such as the Global Privacy Control (GPC),
to opt-out of the sale/sharing of your personal information. For more
information on the types of cookies we use and your choices regarding them,
please review our Cookie Policy.


8. CHANGES

This Privacy Policy is effective as of the date posted at the top. We may update
this Privacy Policy from time to time to reflect Platform changes, make
corrections, improve clarity, reflect changes in our privacy practices, or as
required by applicable laws. When we may make a significant change, such as on
how we use your personal information or your rights, we will notify you within
the Platform or through another channel such as the email you supplied during
account registration, in addition to posting the revised version on our Website.
We encourage you to periodically check this Privacy Policy to stay informed
about how we handle your personal information.


9. CONTACT US

We want to hear from you if you have questions, concerns, or requests regarding
this Privacy Policy. You can reach us by emailing help@headspace.com or calling
855.432.3822.


10. SUPPLEMENTAL NOTICES

Depending on your jurisdiction, you have additional rights that apply to you
under your jurisdiction's privacy laws. We provide the supplemental information
in this section in our efforts to comply with those additional privacy laws and
inform you about your rights. If you do not see your jurisdiction below please
do not interpret that to mean that we do not respect your privacy and we
encourage you to still contact us using the contact details above with your
questions or concerns. Please note that Headspace is a US based company and your
personal information will be stored within the US.



(a) Privacy Notice for EU and the UK



Data Transfers. This section is for individuals in the European Union (EU), the
United Kingdom (UK), and Switzerland. Headspace operates as a data controller
under the General Data Protection Regulation (GDPR) for the majority of the
personal information detailed in section 1 and as a data processor for the
limited personal information we may receive from your Benefit Sponsor.

Headspace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Headspace has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance on the
EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK
Extension to the EU-U.S. DPF. Headspace has certified to the U.S. Department of
Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any
conflict between the terms in this privacy policy and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more
about the Data Privacy Framework (DPF) program, and to view our certification,
please visit https://www.dataprivacyframework.gov/.

The following entities are included under Headspace’s DPF certification and
adhere to the EU-U.S. DPF Principles, its UK Extension, and the Swiss-U.S. DPF
Principles:



 * Headspace, Inc.
 * Ginger.io, Inc.
 * Ginger.io of California Medical P.C.

If you have any questions or concerns regarding our personal information
collection, use, and sharing practices as described in this Privacy Policy you
may reach us using emailing help@headspace.com. We will investigate the matter
and resolve any issues, if we can. In the event that we are unable to resolve
your issues, you may be able to invoke binding arbitration, under certain
conditions and as permitted by the EU-U.S. DPF, its UK Extension, or the
Swiss-U.S. DPF, by contacting our U.S.-based third party dispute resolution
provider (free of charge) at https://go.adr.org/eu-us_dpf_annexi.html. Headspace
is subject to the investigatory and enforcement powers of the U.S. Federal Trade
Commission (FTC).

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 the applicable EU-U.S. DPF, its UK
Extension, or the Swiss-U.S. DPF.

Legal basis. Headspace relies on one or more legal bases to process your
personal information under applicable law, including:

 * (i) with your consent, which you may withdraw at any time;
 * (ii) when the processing is necessary to perform our contractual obligations
   to you, like under our Terms;
 * (iii) when necessary to pursue our legitimate interests as further detailed
   below;
 * (iv) when necessary for our compliance with our legal obligations such as a
   request or order from courts, law enforcement or other government
   authorities.

Legitimate business interests. We may collect, process, and maintain personal
information 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 information 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:

 * Providing you with our Platform, including functionality of features or
   Websites you interact with or so that we can provide you the Services.
 * Providing 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.
 * Maintaining and improving the quality of the Products and Services that we
   offer, including to customize our features 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
   information with our trusted service providers that provide services on our
   behalf.
 * Protecting you and others, as well as, 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.
 * To 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 information 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.
 * Complying 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.

Privacy rights. Individuals in the EU and UK have privacy rights under the GDPR
and the UK equivalent. We will work to respond to your verified request within a
month’s time unless we request an extension. Section 5 above generally covers
these privacy rights but EU and UK residents also have the following:

 * Right to object to processing - You may have the right to request that
   Headspace Health restrict the use of your personal data in certain
   circumstances.
 * Right not to be subject to automated decision making - You have the right not
   to be subject to a decision based solely on automated processing. Please know
   that we do not currently make decisions about you in this manner.
 * Right to lodge a complaint - 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 EU, you can view the contact
   information for your data protection authority here. If you are in the UK,
   please visit this page. We ask that you contact us first to see if we can
   resolve your issue.

Exceptions may still apply as described in Section 5.


Representatives: Individuals and the data protection supervisory authorities in
the EU/EEA and individuals and the data protection supervisory authority (“ICO”)
in the UK may also contact our data protection representatives according to
Article 27 GDPR:

EU: DP-Dock GmbH, Attn.: Headspace, Inc., Ballindamm 39, 20095 Hamburg, Germany

UK: DP Data Protection Services UK Ltd., Attn.: Headspace, Inc., 16 Great Queen
Street, Covent Garden, London, WC2B 5AH, United Kingdom

www.dp-dock.com

headspace@gdpr-rep.com

Our data protection officer can be reached at privacy@headspace.com.



(b) Privacy Notice for California


We include this section for residents of California in order to comply with the
California Consumer Privacy Act of 2018, and its amendment, the California
Privacy Rights Act of 2020 (together, the “CCPA”). This section is intended to
comply with the CCPA by supplementing the information provided elsewhere in the
Privacy Policy.

Categories of personal information. The CCPA includes categories of personal
information that businesses like us are required to tell you what of them we
have collected from you. To comply with those requirements, we have provided the
table below disclosing the categories of personal information we have collected
through our Platform within the last twelve (12) months.

Headspace is not a data broker and does not sell your personal information to
third parties for payment. However, as with many online companies, Headspace
partners with third parties to manage our advertising on other platforms. For
that purpose, we may disclose limited personal information to third parties for
our cross-context behavioral and targeted advertising purposes and this activity
may fall under broader concepts of “selling” and/or “sharing” under the CCPA. We
have noted in the table below what categories we have “sold” and/or “shared” in
the last twelve (12) months. Please review the section below the table about
your privacy rights for more information on how to opt-out of this activity.



CATEGORY COLLECTED “SOLD” / “SHARED” A. Identifiers.
Name, alias, mailing address, unique personal identifier, online identifier, IP
address, email (personal and/or work), account name, telephone number, password,
account credentials, National Provider Identifier (NPI), driver’s license /
government ID number (if provided for identity verification), or other similar
identifiers Yes Yes
email, online identifier, personal unique identifier, IP address B. Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e)).
Name, signature, mailing address, telephone number, driver’s license /
government ID number (if provided for identity verification), payment card
number, employment, employment history, bank account information, medical
information, and health insurance information Yes Yes
email C. Protected classification characteristics under California or federal
law.
Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression, pregnancy
or childbirth and related medical conditions), sexual orientation, veteran or
military status Yes No D. Commercial information.
Payment history, balances, Products or Services purchased or considered Yes Yes
Products or Services purchased or considered E. Biometric information.
Sleep, health, or exercise data Yes No F. Internet or other similar network
activity.
Browsing history, search history, information on how you interact with our
website Yes Yes
Browsing history, information on how you interact with our website G.
Geolocation data.
Approximate location based on information like IP address Yes No H. Sensory
data.
Audio recordings, voicemails, photographs Yes No I. Professional or
employment-related information.
Employer, job title or role, work contact information Yes No J. Non-public
education information (per the Family Educational Rights and Privacy Act (20
U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Student identification number Yes No K. Inferences drawn from other personal
information.
Profile reflecting a person's preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes Yes No L. Sensitive personal information.
Password, health information, payment information, racial and/or ethnic origin,
information concerning your sexual orientation, and gender identity Yes No

Please note that because of the overlapping nature of certain categories
identified above, some of the personal information we collect may be reasonably
classified under multiple categories. Please also note that some of this
personal information, especially in regards to the Products and Services, may be
covered by federal laws like HIPAA.

Use of personal information. We may use your personal information in the
following ways:

 * To provide our Platform, including the delivery of content and interactive
   features;
 * To communicate with you regarding our Platform including updates or changes;
 * To provide you support, answer your questions or requests for information, or
   handle your complaints;
 * To process payment, manage your orders, and account for applicable sales
   taxes;
 * To inform your Benefit Sponsor, if you have one, about your registration and
   other information as described in Section 3 below;
 * To fulfill our obligations under any agreements that we may have with you;
 * To maintain and improve the quality of our Platform, including to perform
   research and development, understand user trends;
 * 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 personalize the advertisements you receive about our Platform through
   third-party platforms, on other websites and apps;
 * To protect ourselves, you and others such as by taking actions to prevent
   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 including meeting regulatory compliance
   obligations, responding to subpoenas, court orders or other legal processes;
   and
 * To establish or exercise our legal rights or defense against legal claims.

Use of sensitive personal information. We use sensitive personal information for
the same purposes listed above except for personalizing ads.

Retention. We will keep your personal information for as long as needed to
perform our obligations to you, or for as long as legally permitted. 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). For example, we keep your
account information, like your name, email address, and password, for as long as
your account exists so that you may access it.

Your California privacy rights. The CCPA provides California residents with
rights to receive certain disclosures regarding the collection, use, and
disclosure of personal information and sensitive personal information. These
disclosures are provided in Sections 1-3 and the chart in Section 10(b) above.
If you are a California resident, you have the following rights under California
law in relation to your personal information, subject to certain exceptions. We
will respond to your verifiable request within 45 days.

 * Right to know and access. You have the right to know what personal
   information we collect, use, disclose, and sell and/or share, as those terms
   are defined under applicable law. You may ask us to provide you a portable
   copy of this information up to two times in a rolling twelve-month period.
 * Right to delete. You have the right to request under certain circumstances
   that we, as well as our service providers and contractors, delete the
   personal information that we collect about you.
 * Right to correct inaccurate personal information. You have the right to
   request the correction of inaccurate personal information.
 * Right to non-discrimination. You have the right not to receive discriminatory
   treatment for the exercise of the privacy rights described above.
 * Right to opt out of sale and/or sharing. You have the right to opt-out of the
   sale and/or sharing of your personal information by a business. Please see
   our Notice of Right to Opt-Out below for more information.
 * 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 goods or services to you. 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.
 * Sharing with third parties for their own direct marketing purposes. Headspace
   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.



Notice of right to Opt-Out.

As mentioned above, if you are a resident of California, Headspace “sells” and
“shares” personal information under the CCPA’s broader definition of “sale” or
“share.” California law provides you a right to opt-out of such “sales” and
“shares.”. You may exercise this right Your privacy choices and, if you are an
Apps user, by going to the My Data page here or within your mobile app settings.
The opt-out link is also available our Website’s pages by clicking on the Your
Privacy Choices link.





(c) Privacy Notice for Virginia, Connecticut, Colorado, Utah, and Nevada



We include this section for residents of other US states with privacy laws that
may impact them. These privacy laws include the Virginia Consumer Data Privacy
Act (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer
Privacy Act (“UCPA”), the Colorado Privacy Act (“CPA”), and the Nevada Privacy
Law (“NPL”). This section is intended to comply with these laws by supplementing
the information provided elsewhere in the Privacy Policy.



Collection of personal information. Headspace may collect the personal
information described in Section 1 and as categorized in the table within
Section 10(b) above. Please note that some of this personal information will be
considered sensitive under your state’s legal definition which can vary across
different states. The personal information we may collect depending on how you
use our Platform includes mental or physical health information, racial or
ethnic origin, and information about sexual orientation or gender identity.

Use of personal information. Headspace may collect, use, or disclose personal
information about US state residents for purposes listed in Section 2 of our
Privacy Policy. We use sensitive personal information for the same purposes
except for personalizing ads.

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.

Your privacy rights. We generally provide the privacy rights described in
Section 5 above to you regardless of your location. Your state may afford you
additional privacy rights as noted below. To exercise your right, see the
contact information in Section 9 or follow the instructions below for specific
state rights. We will respond to your verifiable request within the time limit
afforded under applicable law. Exceptions may still apply as described in
Section 5.

 * Residents of Colorado, Connecticut, Virginia, and Utah have the right to opt
   out of targeted advertising and sales. If you are a resident of these states,
   you may opt out by Your privacy choices and, if you are an Apps user, by
   going to the My Data page here or within your mobile app settings.
 * For users in Colorado, Connecticut and Virginia, you may opt out of profiling
   in furtherance of decisions that produce legal or similarly significant
   effects. While you may still make this request, Headspace does not currently
   use profiling in this manner.
 * Nevada provides its residents a limited right to opt out of the sale of
   personal information. Please know that we do not trigger this requirement
   because we do not sell your personal information for payment.

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