Headspace Health – Privacy Policies & Notices
Our Privacy Commitment to You
First, a note about Headspace Health’s commitment to your privacy.
Headspace Health deeply values its role as a trusted provider of meditation, mindfulness and mental health offerings through the Headspace and Ginger apps. Headspace provides meditation and mindfulness content for stress, sleep, focus, and movement, and Ginger provides on-demand mental health support through coaching, therapy, psychiatry, and self-care resources. Ginger is a licensed medical provider in the United States. For information about Ginger services outside of the United States, please contact us at firstname.lastname@example.org. Central to that role is our promise to safeguard the privacy of your personal information. Here are a few things we want you to know:
- We only collect the personal information we need in order to provide you with Headspace Health’s services and products. We do not collect more information than we need. The personal information that we ask you to provide us, or give you the option to provide us, is intended to help us direct you to and deliver meditation, mindfulness, and mental health-related services, as applicable, that adhere to our standards of high quality and exceptional member service.
- We do not use your personal information for purposes unrelated to the reasons for which it was collected, or that would not conform to your reasonable expectations. We know it is important to you that you be aware of all the reasons that your information is collected, used and shared by Headspace Health. Our responsibility to safeguard your privacy is of the utmost importance to us.
- We do not retain personal information for longer than is necessary. We understand the importance of minimizing the personal information that we may maintain. We will only retain your data for the period of time necessary to fulfill the purposes for which it was collected, including delivering requested products and services, protecting the interests of our users and other stakeholders, and as otherwise consistent with our legal obligations or your reasonable expectations.
- We do not sell your personal information to others. We will not sell your personal information to third parties, except to the extent that our sharing of personal information to facilitate targeted digital advertising may be considered “selling” or “sharing” your personal information under certain state laws.
- We offer you ways to control your personal information and express your preferences. We provide you with a variety of ways to exercise control over your personal information, including providing you with options regarding what personal information you provide to us, exercising your account and communications preferences, and updating your user profile. You may have other rights depending on your location and applicable law.
- Headspace Terms and Conditions regarding your use of the Headspace Website and Apps
- Ginger Terms of Service regarding your use of the Ginger Website, Services, and App
Please also note that residents of certain jurisdictions may have certain unique rights with respect to our collection, use, and sharing of personal information, including residents of California, the European Union, and the United Kingdom. Please refer to Sections 10 and 11 for information about these jurisdiction-specific rights.
Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information.
Linkable Table of Contents
- Collection of personal information
We may collect your personal information when you interact with us through the Headspace Health Platform, share your information with us, or by other means. We may also automatically collect information regarding your use of our Platform.
- Use of personal information
We may use your personal information for various purposes connected with your interest in the Headspace Health Platform, and our Products and Services, and to allow us to maintain and improve them.
- Sharing of personal information
We may share your personal information with certain third parties, such as with our service providers, as directed by you, and to provide you with opportunities that we believe may be of interest to you.
- Your rights and choices
You may have certain rights and choices regarding our collection, use, and disclosure of your personal information.
- Data security
The security of your personal information is of utmost importance to us and we maintain appropriate safeguards to protect it.
- Cookies and tracking technologies
When you visit the Headspace Health Platform, we may collect certain information from you automatically through cookies and other tracking technologies.
- Children’s privacy
Our Platform is intended for individuals at least 18 years old or older, except in limited circumstances that will be clearly described to you.
- International data transfers
Our Platform is operated exclusively in the United States.
- Likes to other websites
Our Platform may contain links to other websites that are not operated by us and that are subject to third party privacy policies and other terms.
- California Privacy Notice
We provide additional disclosures and rights to California residents.
- European and UK Privacy Notice
We provide additional disclosures and rights to individuals located in Europe and the United Kingdom.
- Contact us
You may contact us for comments or questions in various ways.
- Collection of personal information
- Information you provide to us
Headspace Health may collect the following categories of personal information about you that you choose to provide to us when you use the Headspace Health Platform or otherwise interact with or receive our Products and Services:
- 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 Platform via a social media platform.
- 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 a 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.
- Surveys, health, and medical information. We may present you with surveys or other information forms on our Platform order 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, such as your current mental, emotional, and physical status, wellness goals, current life events, and other health-related information.
- Profile and demographic information. Through your account on our Platform, including the Headspace and Ginger Apps, you may have to 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 Health does not directly process payment card information, but does rely on 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 Health.
- Communication information. When you send or respond to emails, messages, or other communications from Headspace Health, 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 Platform, we may collect the content of those communications.
- Information from others
In certain circumstances, we may collect personal information from others. This may include the following:
- If you receive access to Headspace Health through your employer, health plan, or other Headspace Health Partner, we collect your name and email address and demographic information that such Partner submits to us to facilitate your enrollment in our programs.
- 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 who wish to enroll their adolescent dependents ages 13-17 in our Ginger for Teens offering. We will use this data to enroll the teen.
- 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
If you would like us to delete personal information that may have been provided to us by others as described above, you can do so by opting out as described in the invitation or other communication that we may have sent to you, or by contacting us at email@example.com.
- Information we automatically collect
Our Platform, including the Websites, may collect information from you automatically as your use our Platform, including individual Websites and Apps This information 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 Apps you are visiting; and
- Usage data, such as geolocation data, browsing history, time spent on the Platform, pages visited, links clicked, language preferences, performance of features, patterns of use, and the pages that led or referred you to our Platform including individual Websites and Apps. For example, we use Google Analytics on our Websites to help us analyze your use of our Websites and diagnose technical issues.
- Aggregated, anonymous, and de-identified data
- Use of personal information
We may use your personal information in the following ways:
- To provide our Products and Services, including the delivery of content and facilitation of interactive features;
- To communicate with you regarding the Headspace Health Platform, Products and Services;
- To notify you about updates or changes to the Headspace Health Platform, Products and Services;
- To provide customer service, answer your questions or requests for information, or handle your complaints;
- To facilitate payment transactions, manage your orders, and account for applicable sales taxes;
- To inform businesses, government entities, hospitals, universities and other organizations and groups that wish to make our Products and Services available to their members, employees and their families, patients, customers, residents or others (collectively, our “Partners”) about your registration and, in limited cases, use of the Products and Services;
- To effectuate our performance on any agreements that we may have with you;
- To maintain and improve the quality of the Headspace Health Platform, Products and Services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising;
- 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 serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law;
- To protect ourselves, you and others; preventing 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; respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defense against legal claims.
Please note that we may also use your personal information to cross-reference or convert various types of accounts that you may be associated with on our Platform. For example, we may cross reference the account information you provide to ensure your access to both Headspace and Ginger using the same credentials.
- Sharing of personal information
We may also disclose your personal information with the following categories of third parties:
- Our service providers. 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 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 Partners. In limited cases, we may provide certain personal information to our Partners, which may include your employer, in order to provide the Headspace Health Platform, Products and Services as a benefit of your employment.
- 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 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.
- 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 or apply our agreements with you; or to protect the rights, property, or safety of Headspace Health, 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
- Your Rights and Choices
- Privacy rights, choices, and preferences. If you have an account on our Platform, please visit your account for any privacy rights, choices, or preference options that may be offered. In your Headspace Health user profile, you are able to make additions or edits to any of your personal, payment, or membership information, and you may request to delete your account. You may also submit a request to firstname.lastname@example.org. For more information about your available privacy rights in certain jurisdictions for both accountholders and non-accountholders, please review our California Privacy Notice and European and UK Privacy Notice in the sections below.
- Data security
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.
- Cookies and tracking technologies
The Headspace Health Platform uses Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Platform and the volumes of usage of the Products and Services. This is done to ensure that the Platform and its associated Products and Services 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 do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Other tracking on our Platform. Our Platform, including our Websites, may utilize tracking technologies to collect and record your activities and movements across our Websites throughout your browsing session, including to track button clicks, mouse movements, scrolling, resizing, touches, keystrokes, data entered, device information and orientation, browser visual elements, and screen size (“Session Data”), for purposes of our own internal analytics and improving our products, services, and user experience. Such tracking may include recorded sessions, which we may play back for these purposes.
Our Platform also utilizes live chat and/or chat bot technology, which visitors 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 Health for our business purposes, including by our customer service and other personnel and service providers.
We may share Session Data and chat bot correspondence data with our third-party analytics or service providers, which may change from time-to-time, for these purposes, who will use the data solely on the behalf of, and for the benefit of, Headspace Health.
- Children’s privacy
Our Platform is intended for individuals at least 18 years of age, or the age of majority in your province, territory or country. Individuals ages 13 of 18, or the applicable age of majority, may utilize the Headspace Health Platform only with the consent and involvement of a parent or legal guardian. This provision is not applicable to registrations made under select subscriptions or special offerings, including business to business sales and enterprise partnerships, where specified in applicable contracts.
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@example.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.
- International data transfers
The Headspace Health Platform is operated exclusively in the United States. To the extent Headspace Health offers Products and Services to individuals located in the European Union or United Kingdom, or to the extent the Headspace Health Platform is intentionally available to such individuals, please review our European and UK Privacy Notice below for more information about disclosures and privacy rights associated with that activity.
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 have implemented other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal information to the U.S., consistent with applicable law.
For personal information collected from individuals located in the European Union, Switzerland and the United Kingdom, you have the ability to opt out of whether such personal information 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 Health at firstname.lastname@example.org in order to make such choices.
Headspace Health is mindful of its responsibility and potential liability for onward transfers of personal information to third parties where Headspace Health deems such transfers necessary and those transfers are subject to Privacy Shield.
- Links to other websites
- California Privacy Notice
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, correct, limit, and opt-out of the sales of certain personal information we collect about them, as well as to opt-out of the sharing of certain personal information for purposes of cross-context behavioral advertising (called “sharing” under California law). California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by emailing us using the information provided in the Your Privacy Rights section below.
For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified; or information that has been aggregated. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
- Personal information we collect
Headspace Health may collect, or has collected, the following categories of personal information from California residents within the last twelve (12) months:
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.
Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including:
- Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account;
- Precise geolocation;
- Racial and/or ethnic origin, religious or philosophical beliefs, or union membership;
- Personal information concerning health; and
- Personal information concerning sex life or sexual orientation.
Headspace Health will not retain any information we collect about you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (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).
- Uses of personal information
The sensitive personal information that we collect as described in Section 10(a) above may be used for any of the following purposes:
CATEGORY OF SENSITIVE INFORMATION USED
To provide our Products and Services, including the delivery of content and facilitation of interactive features
Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account; Precise geolocation; Racial and/or ethnic origin, religious or philosophical beliefs, or union membership; Personal information concerning health; and Personal information concerning sex life or sexual orientation
To communicate with you regarding the Headspace Health Platform, Products and Services
To facilitate payment transactions, manage your orders, and account for applicable sales taxes
Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account
To maintain and improve the quality of the Headspace Health Platform, Products and Services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising
Racial and/or ethnic origin, religious or philosophical beliefs, or union membership; Personal information concerning health; and Personal information concerning sex life or sexual orientation; precise geolocation.
- 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 when registering for the Headspace Products and Services, surveys that you take, or as automatically collected when using our Platform.
- From our business partners and others, including those that may promote and/or offer products and services that may be of interest to you.
We may supplement the personal information collected from the categories of sources described above with personal information we obtain from other sources.
- Disclosure of personal information
This includes disclosure of your personal information to service providers 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 each categories of personal information listed in Section 10(a), including the listed sensitive personal information, for a business purpose.
Headspace Health does not “sell” personal information to third parties for monetary or other valuable consideration as that term is defined by the CCPA as amended by the CPRA.
The CCPA requires us to identify the categories of personal information that we have “sold” or “shared” under the CCPA in the preceding twelve (12) months.
In the last twelve (12) months, we have disclosed (or “shared”) the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:
- Internet or other electronic network activity information
- Your privacy rights
The CCPA provides California residents with specific privacy rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
If you are a California resident, you have the right to make the following requests under applicable California law in relation to your personal information, 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 your personal information, though it does “share” your personal information with third parties for cross-context behavioral advertising as disclosed elsewhere in this section.
- Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
- 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 Products and 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.
How to submit a request. To submit a request of any of the rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at email@example.com
- Calling us at 855-432-3822
Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer 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.
Requests by authorized agents. You may designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If you should use an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests for disclosure and deletion, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to firstname.lastname@example.org.
Household data. We collect household data in connection with our family plans. If we receive a Request to Delete, Know, or Correct submitted by all members of a household, we will individually respond to each request consistent with California law. If we receive a Request to Opt-Out or Limit submitted by all members of a household, we will process the request based on the information we have about your household and the individuals associated with it, and reserve the right to ask for further information if we determine it is needed to fully process your request. We will not be able to comply with any such request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
Responses. We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. Headspace Health reserves the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
These rights are subject to various exclusions and exceptions under California law and other applicable laws. In addition, if we are unable to verify your identity to a degree of certainty as required by the CCPA through any reasonable method, we will state that we are unable to verify in a written response to you along with a reason as to why there is no reasonable method by which we can verify your identity.
Direct marketing by third parties. Headspace Health 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 email@example.com.
We will continue to update our business practices as direct regulatory guidance becomes available.
- Notice of Right To Opt-Out
As detailed in Section 10(d) above, Headspace Health does not “sell” personal information to third parties for monetary or other valuable consideration as that term is defined by the CCPA as amended by the CPRA. However, Headspace Health does “share” personal information with third parties for purposes of cross-context behavioral advertising, as that term is defined by the CCPA.
- European and UK Privacy Notice
European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, to access, to rectification, to erasure, to restrict processing, to data portability, and to object with respect to collected personal data. For the purposes of this European and UK Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.
- Basis for processing your personal data
Headspace Health relies on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.
Legitimate business interests. We may collect, process, and maintain personal data 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 data 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:
- Provide you with requested Headspace Health Products and Services.
- Provide 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.
- Maintain and improve the quality of the Headspace Health Platform and the Products and Services that we offer through our Platform, including to customize our sites and products 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 data with our trusted service providers that provide services on our behalf.
- Protect you and others and 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.
- 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 data 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.
- Comply 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.
- Your privacy rights
In certain circumstances, individuals located within the EEA and UK may have the following data protection rights regarding their personal data:
- Right to access. You may have the right to request confirmation of whether Headspace Health processes personal data relating to you, and if so, to request a copy of that personal data.
- Right to rectification. You may have the right to request that Headspace Health correct or update your personal data that is inaccurate, incomplete or outdated.
- Right to deletion. You may have the right to request that Headspace Health erase your personal data in certain circumstances provided by law.
- Right to restrict processing. You may have the right to request that Headspace Health restrict the use of your personal data in certain circumstances.
- Right to object to processing. You may have the right to object to Headspace Health’s processing of your personal data, under certain conditions.
- Right to data portability. You may have the right to request that Headspace Health export the data that we have collected to you or another company, under certain conditions.
Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please submit a written request to firstname.lastname@example.org. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
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 European Economic Area, you can view the contact information for your data protection authority here. If you are in the United Kingdom, please visit this page.
- Retention of personal data
We will retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained. 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).
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