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Privacy Notice for California Residents

October 22, 2021

Under the California Consumer Privacy Act (“CCPA”), California residents are afforded certain rights about the Personal Information (as such term is defined under the CCPA) that businesses collect about them. Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the CCPA. To the extent of any conflict between this CCPA Notice and the rest of our Privacy Policy, this CCPA Notice shall control only with respect to Consumers and their personal information.

Scope

For purposes of this Privacy Notice for California residents, "Personal Information" has the definition given in the CCPA.  However, this Statement does not apply to:

  • Information excluded from the scope of the CCPA, such as clinical trial data, or information that is instead protected and governed by the California Confidentiality of Medical Information Act or the privacy, security, and breach notification rules issued by the US Department of Health and Human Services established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) (“HIPAA”) and the Health Information Technology for Economic and Clinical Health (“HITECH”) Act (Public Law 111-5).
  • Personal Information we collect from individuals acting in their capacities as representatives of organizations solely in the context of conducting due diligence regarding or providing or receiving a product or service to or from, such organizations.

If certain types of information are exempt from CCPA, and therefore this policy, other Talkspace privacy policies may apply such as our main privacy policy, HIPAA Notice of Privacy Practices or European/UK Residents Privacy Rights statement.   

How We Collect and Share California Residents’ Information

In the chart below, we have described the categories of Personal Information that we have collected and shared over the past twelve (12) months, the purposes for such collection and the types of entities with which we have shared such information.

Categories of Information
Sources of Information
Uses of Information
Sharing of Information

Identifiers, including your name, email address, DeviceID, and Internet Protocol (IP) address.

Directly from you or your devices, for example from forms you complete and submit prior to becoming a subscriber or when seeking commercial information about our business.

We collect such information to communicate with you, including for marketing purposes; to operate the Website and the App.

We share this information with certain service providers who help us process and use the information subject to written agreements.

We do not Sell this information.

Characteristics of protected classifications under California or federal law, such as gender identity, sexual orientation, gender expression, and age.

We collect this information directly from you, for example in survey responses you provide prior to becoming a subscriber.

We collect such information for communication and marketing purposes, and to operate the Website and the App.

(If you subscribe to our Services, survey data will also be used in connection with providing Services, as described in the section entitled Personal Data We Process & How We Use It.)

We share this information with certain service providers who use the information as described in the section entitled Personal Data We Process & How We Use It.

Internet or other electronic network activity information, such as IP addresses and cookies.

We collect this information automatically from your computer or device.

We collect such information to provide, and improve the Website or the App. For more information, see the section entitled Personal Data We Process & How We Use It.

We share this information with certain service providers who use the information as described in the section entitled Personal Data We Process & How We Use It.

Professional and employment related information—including such as your job title, company, or investor type.

We collect this information directly from you.

We collect such information if you are representing a business engaging with Talkspace on behalf of your employer or that business.

We share this information with certain service providers who use the information as described in the section entitled Personal Data We Process & How We Use It.

Inferences derived from information you provide, such as your responses to surveys.

Inferences about your interests are derived from your responses to surveys completed prior to becoming a subscriber.

We collect such information to tailor communications to your interests, and for marketing purposes, and to operate the Website and the App.

(If you subscribe to our Services, survey data will also be used in connection with providing Services, as described in the section entitled Personal Data We Process & How We Use It.)

We share this information with certain advertising networks to evaluate the success of our marketing campaigns, to conduct marketing activities, including tailoring advertising.  For more information see the section entitled Personal Data We Process & How We Use It.

Your Rights and Choices

Consumers have the following rights under the CCPA: 

  • Right to Know. You have the right to request that we disclose to you the Personal Information that we maintain about you, which we will provide to you upon receipt of a verifiable request (see further info below on how to submit such requests, in Exercising Your Rights). 
  • Right to Delete. You have the right to request that we delete any of your Personal Information that we have collected from you.
  • Right to Opt-Out of the Sale of Personal Information. We do not Sell your Personal Information. 
  • Right to Nondiscrimination. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under the CCPA. We will not discriminate against you for exercising any of your CCPA rights.  

Exercising Your Rights. To initiate access or deletion requests, you can contact us at [email protected]. As stated above, we do not Sell your Personal Information.

  • Only you, or someone that you authorize to act on your behalf, may make a request related to your Personal Information. An authorized agent may make a request on your behalf by providing written permission signed by you. 
  • We will need to confirm your identity or the identity of your authorized agent, before processing your request by asking you to log into your existing account (if you are a registered user) or by asking you for additional information, such as a government issued ID, to confirm your identity against information we have already collected. 
  • Please note that you may only make a request for access twice within a 12-month period.