Scope and Overview
Headspace Health is committed to protecting the privacy and security of your personal information. Headspace Health includes Headspace, Inc., Ginger.io, Inc. and its subsidiaries and affiliates (collectively referred to as "Headspace," "we," or "us"). This Privacy Notice supplements the privacy policy available at https://www.headspacehealth.com/privacy-policy to specifically covers how we collect, process, and store the personal information about you during the application process and if you enroll as a student at the Ginger Training Institute Behavioral Health Coach Training Program (the “Program”). This Privacy Notice applies to you only if you are a prospective, enrolled, and past student of the Program. If you are instead looking for information on our website or our other products, please refer to the privacy policy linked above.
This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, and when we may disclose your personal information to third parties. This Privacy Notice also describes your rights regarding the personal information that we hold about you including how you can access, correct, and request erasure of your personal information.
We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law or with your consent. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
Collection of Personal Information
For the purposes of this Privacy Notice, personal information means any information about an identifiable individual collected in connection with you being a prospective, enrolled, or past student of the Program along with your application. Headspace may collect personal information directly from you, as prospective or enrolled student, or may receive personal information from third parties, subject to your consent where required by law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process personal information, including, but not limited to, the following categories, which we require in connection with our recruiting activities:
| Category | Examples | Collected |
|---|---|---|
Category A: Identifiers | First and last name, email, telephone number, mailing address, password and account credentials | Yes |
Category B: Personal | First and last name, mailing address, telephone number, signature. | Yes |
Category H: Sensory | Recordings of classes, customer service voicemails, photographs | Yes |
We do not actively collect sensitive personal information (ex: social security number, health information, precise geolocation) and we ask that you refrain from entering any during your application or providing any during class. We do not collect or process sensitive personal information for the purposes of inferring characteristics about consumers.
Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories and we may not collect all of the information in a particular category. Additionally, while we may not actively collect a particular category, we may still inadvertently collect information you decide to provide us such as during classes or in your student application.
Sources of personal information
We obtain the categories of personal information listed above from the following categories of sources:
- From you, including, for example, from forms you complete a student or scholarship application form, surveys that you take, information you provide as part of class activities, or as automatically collected when using software tools as part of your classes such when you take an exam.
- Through our service providers, which are third party companies who help us provide our teaching services to you or services related to that purpose such as our payment processor.
We may supplement the personal information collected from the categories of sources described above with personal information we obtain from other sources.
Use of Personal Information
We only process your personal information where applicable law permits or requires it in connection with carrying out our student processes, 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 information for the following legitimate business purposes:
- Identifying and evaluating prospective students, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
- Identifying and evaluating your application for a scholarship, including….
- Communicating with you about the application process and your application and managing your student enrollment:
- Keeping student records related to our training processes, for only as long as appropriate under the circumstances.
- To comply with our requirements as an approved training program under the National Board of Health and Wellness Coaching (NBHWC).
- Billing and payment purposes regarding your tuition and other fees.
- Conducting internal audits.
- Analyzing and improving our application selection and training processes, 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 information for the purposes we collected it for or for compatible purposes. If we need to process your personal information for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.
We may also process your personal information 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 selection or evaluation decisions based solely on automated data processing without your prior consent.
Data Sharing
We will only disclose your personal information 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 Program. We may use third-party service providers for various purposes, including, but not limited to, content delivery, class interactions, payment processing, and data storage or hosting. These third-party service providers may be located outside of the US. We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us.
We may also disclose your personal information 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 student 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 information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information 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 information 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.
Data Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information 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 information 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. Under some circumstances we may anonymize or de-identify your personal information 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.
Your Rights
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes or if there is an error. Additionally, you have the following rights subject to certain exceptions:
Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, and to whom, as applicable. You may request either a report disclosing the general categories of the personal information we collect, or a report disclosing the specific pieces of personal information we collect.
Right to Delete. You have the right to request, under certain circumstances, the deletion of your personal information that we collect.
Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the “sale” or “sharing” of your personal information, as those terms are defined under California law. Please note that Headspace Health does not currently sell or share your personal information in the scope of this Privacy Notice.
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 our Program’s services to you, or for certain other authorized purposes. 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.
Right to Correct. You have the right to request the correction of your 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.
To submit a request for any of the rights described above, please submit a verifiable consumer request to us by either emailing us at EMAIL@headspace.com.
Any request you submit to us is subject to a verification process as permitted or required by applicable law. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal information on. In order to verify you, you must provide us with your first and last name and email address. If your request is through an authorized agent we will require proof that the agent has in fact your authorization to submit requests on your behalf.
Children’s Privacy
Our Program is only intended for individuals who are at least 18 years old. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us at EMAIL@headspace.com. If we become aware that we have collected personal information from children under age 13 without parental consent, we will take steps to remove that information from our servers.
Links to Other Websites
Our Program may contain links to other websites that are not operated by us. We are not responsible for the content or privacy policy policies of websites we do not own or control, and this Privacy Notice does not apply to third-party websites. We strongly suggest you review the privacy policies for third-party websites to understand how your personal information is used and stored by those websites.
Changes to This Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date of the last update is listed at the top of this Privacy Notice. You are responsible for periodically visiting this link to Privacy Notice to check for any changes. If the link changes or we make material changes to how we will use your personal information, we will notify you using your email on record or by other means.
Contact Us
If you have any questions about our processing of your personal information or would like to make an access or other request, please contact us at: EMAIL@headspace.com.
