Headspace

Headspace is an English-American online healthcare company, specializing in meditation.

This page is not published. While you can access it via its direct link, it is not yet displayed on the website.

Transparency

Does the policy require users to be notified in case of a data breach? No

0/7

Decided May 18, 2020 (revision history). This question accounts for 8% of the final score.

Note that all companies operating in the EU are subject to Art. 33 of the GDPR, which requires companies to notify their data protection authority of a data breach within 72 hours of discovering it.

Possible Options

No0/7
Yes, eventually5/7
Yes, within 72 hours7/7
N/A (the service collects so little personal data that notification would not be possible)7/7

Note

The service is not required by its policy to alert users in case of a breach

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Will affected users be notified when the policy is meaningfully changed? Yes

5/5

Decided May 18, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Yes5/5
N/A (no personal data—or contact information—collected)5/5

Citation

We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Is the policy's history made available? Only the date it was last modified

3/5

Decided May 18, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Only the date it was last modified3/5
Yes, with revisions or a change-log5/5

Citation

Last update: 05/08/2020

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Does the policy outline the service's general security practices? Somewhat

1/3

Decided May 18, 2020 (revision history). This question accounts for 4% of the final score.

The policy provides only a very vague overview of its security practices.

Possible Options

No0/3
Somewhat1/3
Yes2/3
Yes, including audits2.5/3
N/A (no personal data collected)3/3
Yes, including independent audits3/3

Citation

The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at [email protected] Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law.

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Collection

Is it clear why the service collects the personal data that it does? Yes

10/10

Decided May 18, 2020 (revision history). This question accounts for 12% of the final score.

This question deals with transparency. Even if the service uses data for reasons that aren't ideal for privacy, provided they list all of those uses, the service can still receive full credit for this question. However, if they are not explicit about their uses (by employing language like "such as"), a lower score is assigned.

Possible Options

No0/10
Somewhat4/10
Mostly7/10
Yes10/10
No personal data is collected10/10

Citation

We use information held about you in the following ways:

  • To provide you with the Products.
  • To answer your questions or requests for information or handle your complaints.
  • To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
  • To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law.
  • To carry out our obligations arising from any agreements entered into between you and us.
  • To allow you to participate in interactive features of the Products, when you choose to do so.
  • To notify you about updates or changes to Product features and content.
  • To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
  • To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website. To inform your Community about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above.
  • To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law.
  • To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • To manage your payments and orders.
  • If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out to such communications.
  • If you choose to become a primary account holder of a Headspace Family plan, we may cross reference the address you’ve provided with that of any subsidiary account holder seeking to join your Headspace Family plan in order to verify the validity of the subsidiary account holder.
  • If you choose to become a subsidiary account holder of a Headspace Family plan, we may cross reference the address you’ve provided with that of any primary account holder administering your Headspace Family plan in order to verify the validity of your subsidiary account

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Does the policy list the personal data it collects? Yes, generally

7/10

Decided May 18, 2020 (revision history). This question accounts for 12% of the final score.

All general categories of collected personal data are listed, though not all types of personal data are explicitly mentioned (for example, the list might use a phrase like 'such as' when listing types of personal data).

Possible Options

No0/10
Only summarily3/10
Yes, generally7/10
Yes, exhaustively10/10
N/A (no personal information is collected)10/10

Citation

We may collect and process the following data about you: • Personal data including, for example, your name, e-mail address, password, and in certain instances, telephone number, data about your usage of the Products and data collected by tracking technologies as further described in section 4 below that may identify you as an individual or allow online contact with you as an individual.

• For individuals who participate in a Headspace Family plan, we may collect additional personal data, for example, home address in order to verify family member status.

• If, as a primary account holder of a Headspace Family plan, you choose to invite additional family members to become subsidiary account holders, we will ask you for their name and email address. We will use this data to invite him or her to join the Products. We store this data for the sole purpose of sending invitations and confirming family member status. If your subsidiary account holder(s) would like us to delete their data, they can do so by contacting the primary account holder of their family plan to be removed.

• Headspace does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps, and our payment processor collects Payment Card data with respect to purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.

• For individuals using the Products in connection with a Community client account as described in section 6, business data such as your company name, and company email address to the extent that you or your Community provides such data.

• Facebook profile information, such as name, email address, and Facebook ID, if you choose to log in to the Products through Facebook.

• Device information such as operating system version, device type, and system performance data.

• Data collected via tracking technologies, as fully described in section 4.

• If you choose to invite a “Buddy” to use the Products using our Buddy system, we will ask you for their name and email address. We will use this data to invite him or her to join the Products. We store this data for the sole purpose of sending invitations and tracking the success of our Buddy program. If your Buddy would like us to delete his or her data, they can do so by opting-out as described in each invitation or by contacting us at [email protected]

• If you choose to have your account verified to confirm your status as a student, we may allow a third party platform to access the specific personal data you provide in order to perform the verification. All the information you need to fill in the open text fields during account registration is mandatory. Any failure to complete that information or any response Headspace considers abnormal may result in Headspace refusing (or being unable) to process your request. You agree that the personal data you provide about yourself or subsidiary account holders or “Buddies” to Headspace will be current, accurate, complete and unequivocal.

• If you chose to have your account verified to confirm your status as a US-based healthcare provider, we may collect your National Provider Identifier (“NPI”) in connection with your email address in order to perform the verification.

Note

It's important to note the frequent use of "may" and "such as"

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Does the service collect personal data from third parties? No

10/10

Decided May 18, 2020 (revision history). This question accounts for 12% of the final score.

This includes the use of data brokers and independent verification authorities (such as background check providers).

Possible Options

Yes0/10
Only for critical data7/10
No10/10

Note

The service doesn't collect data from third-parties.

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Does the service allow the user to control whether personal data is used or collected for non-critical purposes? On an opt-out basis, for all non-critical data/uses

3/5

Decided May 18, 2020 (revision history). This question accounts for 6% of the final score.

Some services allow users to opt-out or opt-in to of non-critical collection or use of personal data, such as collecting data for personalized advertisements.

Possible Options

No0/5
On an opt-out basis, but only for some non-critical data/uses1.5/5
On an opt-out basis, for all non-critical data/uses3/5
N/A (no data used for non-critical purposes)5/5
On an opt-in basis5/5

Citation

If your Buddy would like us to delete his or her data, they can do so by opting-out as described in each invitation or by contacting us at [email protected] [...] For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. [...] If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out to such communications. [...] Apple iOS users may opt-in to allow the Products to provide data regarding the amount of minutes meditated to the Apple iOS “Health” application for display. This data will not be shared with third parties or used for marketing purposes. [...] For personal data covered by Privacy Shield, you have the ability to opt-out of whether such personal data is disclosed to a third-party (apart from service providers) or is to be used for a purpose that is materially different for the purpose for which it was originally collected or subsequently authorized. You can contact Headspace at [email protected] in order to make such choices.

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Handling

Does the policy allow personally-targeted or behavioral marketing? Yes, but you can opt-out

3.5/10

Decided May 18, 2020 (revision history). This question accounts for 12% of the final score.

Possible Options

Yes0/10
Yes, but you can opt-out3.5/10
Yes, but you must opt-in7/10
No10/10

Citation

Like most companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Headspace on other platforms, where such advertising is based on your past visits to our Products. These third party partners may use technologies, such as cookies, to gather information about your activities on the Products to deliver such advertising to you when you visit their platforms. For instance, if you visit www.headspace.com, a cookie may be attached to your browser in the form of the Facebook Pixel that allows Headspace to deliver advertising to you on the Facebook platform.

You can opt-out of the above-referenced cookie-based retargeting by visiting the Headspace Cookie Policy and clicking “opt-out of marketing / analytics cookies” at the bottom of the page. Doing so will erase all current marketing cookies and disable the placement of future marketing cookies.

We do NOT use cookies so that third parties can serve ads to you about their own products or services.

We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.

Note

The Headspace cookie policy is at https://www.headspace.com/cookie-policy

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Does the service allow third-party access to private personal data? Yes, not all parties specified

0/10

Decided May 18, 2020 (revision history). This question accounts for 12% of the final score.

The policy allows sharing personal data with third-parties (not just critical service providers), and does not explicitly list the third-parties.

This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).

Note that whether the policy allows sharing aggregated user data does not affect this question.

If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).

If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).

Possible Options

Yes, not all parties specified0/10
Yes, all parties specified (including non-critical service providers such as advertisers)3/10
Yes, not all parties specified (but only to critical service providers)7/10
Yes, all parties specified (only to critical service providers)8/10
No10/10

Citation

We use information held about you in the following ways: [...] - 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 for such uses under applicable law. - To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.

Note

There is a partial inclusion of what services are used, but the term "such as" is used. NoScript detected the following trackers as well: Google Tag Manager, Optimizely, Branch, and "cdn-akami.mookie1.com"

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Does the service allow you to permanently delete your personal data? Yes, by contacting someone

3/5

Decided May 18, 2020 (revision history). This question accounts for 6% of the final score.

Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.

Possible Options

No0/5
Yes, by contacting someone3/5
Yes, using an automated mechanism5/5
N/A (no personal information collected)5/5

Citation

The retention periods applied by Headspace comply with applicable legislation in effect on the date hereof, namely:

For data relating to your account: such data will not be retained beyond your request that your account be deleted.

For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Headspace.

For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw consent or applicable law requires that such data is no longer used.

When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.

When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months.

Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

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When does the policy allow law enforcement access to personal data? Only when required by a court order or subpoena

4/5

Decided May 18, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

Always0/5
Not specified0/5
When reasonably requested3/5
Only when required by a court order or subpoena4/5
N/A (no personal data to share)5/5
Never (special legal jurisdiction)5/5

Citation

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Headspace, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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Warnings

Headspace has no warnings published on PrivacySpy. PrivacySpy publishes warnings when it learns a service has announced a data breach or is found misusing user data. If you believe a warning should be published for Headspace, submit one here.


Highlighted Policy Snapshot ALPHA

No highlighted policy snapshot has been created for this privacy policy. To view the policy at its original location, click here.

5.8/10

How we calculate ratings →


Version Added

May 18, 2020

Ratings Updated

May 18, 2020

Warnings

0

Maintained by

doamatto

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