Headspace, Inc. (“Headspace,” “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, www.headspace.com/work (the “Website ”) and other products, services and features thereof, including but not limited to our mobile applications and administrative tools related to our “Headspace for Work” business-to-business offering (the Website, and such other products, services and features are collectively referred to herein as the “Headspace for Work Product” or “Headspace for Work Products”, which may be updated from time-to-time at the sole discretion of Headspace).

This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal information we collect from you, or that you provide to us, in connection with the Headspace for Work Products will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at http://go.adr.org/privacyshield.html.

1. INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

• Personal information including, for example, your first name, last name, work e-mail address, job title, company name, telephone number, and any additional information you may provide to us in connection with communications regarding the Headspace for Work Product(s).

2. CONFIDENTIALITY AND SECURITY

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

3. WHITEPAPERS OR OTHER ELECTRONIC COMMUNICATIONS

If you sign up to receive materials from us via email we will use the information you give us to provide the communications you have requested. If you inform us that you wish to cancel receiving materials by emailing us at help@headspace.com, we will remove you from our mailing list.

If you provide your phone number to us directly or through a third-party for the specific purpose of getting in touch with a member of our team to bring Headspace for Work to your organization, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply.

4. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored with our sales and marketing vendors.

5. ACCESS TO AND DELETION OF PERSONAL INFORMATION

Upon request, Headspace will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email help@headspace.com.

You may access your personal information or modify it at any time by emailing help@headspace.com.

To request the deletion of your personal data from our sales and marketing vendor systems, please email us at help@headspace.com. We will respond to your request in a timely fashion as dictated by applicable law.

6. USES MADE OF THE INFORMATION

We use information you provide and as described above in the following ways:

• To provide you with information related to the Headspace for Work Products. • To contact you in order to discuss the Headspace for Work Products.

7. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also disclose your personal information to third parties as follows:

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 you have requested from such party, or fulfill a request for information from such party. If Headspace’s service providers require this information to provide services to Headspace. Headspace requires each of its service providers to agree to maintain the confidentiality and security of your personal information.

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 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 information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

8. CONTACT AND EEA REGISTERED AGENT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to help@headspace.com. In the alternative, you may reach Headspace customer support at 855-432-3822.

Our registered agent within the European Economic Area is Tricor, which can be contact at Tricor Suite, 4th Floor, 50 Mark Lane, London, EC3R 7QR.

This Privacy Policy is effective and was last updated on February 28th, 2020. Headspace’s physical address is 2417 Michigan Avenue, Santa Monica, CA 90404.

9. EU-U.S. and Swiss-U.S. Privacy Shield

We participate in and have certified our compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks. Headspace is committed to subjecting all personal data received from European Union (EU) member countries and the United Kingdom and/or Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov

Headspace is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Headspace complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

For personal data covered by Privacy Shield, you have the ability to opt-out of whether such personal information is disclosed to a third-party 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 help@headspace.com in order to make such choices. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Headspace is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Headspace may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.