1. Collection of personal information

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For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through the Headspace Health Platform will be apparent by the context of the page and/or the circumstances in which the personal information is being collected. This may include collection and processing of personal information including, but not limited to, the following categories of information.

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1.  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.

2. 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

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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 help@headspace.com.

3. 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.
• Cookies and web-beacons  We may use cookies and other tracking technologies such as pixels, web beacons, embedded scripts, and tags (“Cookies”). We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. 

Please review our Cookies and tracking technologies section below, as well as our Cookie Policy  for more information about our use of these technologies.

4. Aggregated, anonymous, and de-identified data

We may create aggregated, anonymous, or de-identified data from personal information by removing data components that make the data personally identifiable to you, or potentially personally identifiable to you, or through obfuscation or other means. Once information is aggregated, anonymized, or de-identified such information is no longer personal information, and use of the data is not subject to this Privacy Policy.

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2. Use of personal information

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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.