LifeStance Privacy Notice for Employees and Job Applicants

Last modified: February 2025

This notice (“Notice”), in conjunction with the LifeStance Privacy Policy, describes how LifeStance Health, Inc., and its subsidiaries, affiliates and related companies (collectively, “LifeStance” or “Company”) handle and protect data to which LifeStance is provided access in connection with the employee recruiting process and employment.

For residents of the state of California, please review the specific CCPA and privacy information available at: https://careers.lifestance.com/california-employees-applicants-privacy/.

The CCPA requires a business that collects personal information from California residents to disclose at or before the point of collection, the categories of personal information to be collected, the purposes for which that information is to be collected or used, whether that information is sold or shared for cross- context behavioral purposes, and the length of time a business intends to retain that information. If sensitive personal information is to be collected, CCPA requires a business to disclose the purposes for which it is collected or used and whether such information is sold or shared. If you are a job applicant or independent contractor, additional information about your rights under the CCPA can be found within the Company’s Privacy Policy.

If you decline to submit or make available your information for a job application, it may affect your ability to apply for or receive an offer of employment. This Notice does not form part of any contract of employment offered to candidates hired by LifeStance.

Personal Information
Sensitive Applicant Data
Collected Applicant Data
Collection of Applicant Data
Business Purposes and Processing of Applicant Data
Employee Data
Data Retention
Sharing with Third Parties
Children’s Personal Information
Automated Decisions
Direct Marketing
Applicant Rights
How to Contact Us
- Request to Disclose, Restrict, or Delete Applicant Data

Personal Information

The CCPA defines personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with an individual. Personal information, as referred to herein this Notice as Applicant Data, is identifiable information that an individual makes available to LifeStance either directly or indirectly in connection with the recruiting process. Applicant Data may include a variety of information, such as job application status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by a job applicant (e.g., a cover letter), expertise or project work publicly shared, driver’s license number as required for certain positions, references, and criminal history, where permitted by law.

Personal information under the CCPA, however, does not include:

Deidentified or aggregated personal information.
Publicly available information from federal, state or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public, or from widely distributed media, or made available by a person to whom the individual has disclosed the information without restricting the information to a specific audience. Personal information also does not include lawfully obtained, truthful information that is a matter of public concern.

The CCPA further excludes certain types of information from its definition of personal information:

Medical or health information covered by the Health Insurance and Portability and Accountability Act of 1966 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) and certain types of clinical trial or biomedical research study data.
Personal information covered by certain specific privacy laws such as the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or California Financial Information Privacy Act (“FIPA”) and the Driver’s Privacy Protection Act of 1994.

Employee and Applicant Texting:

LifeStance does not share, sell, or disclose an Employee or Applicant’s (referred herein this section as individual) personal information or mobile opt-in data to third parties without their explicit consent, except where required by law.

Opting In and Consent to Receive Text Messages: An applicant providing their cell phone number is expressly opting in and consenting to receive text messages from LifeStance and its text message providers.
Use of Text Messages: An individual providing their cell phone number to LifeStance is thereby consenting to the collection and use of their personal information specifically for texting and for uses which include, but not limited to activities such as scheduling interviews, interview reminders, interview confirmation, answering questions regarding job, onboarding scheduling and for employees such as shift/schedule change, emergency notifications/protocols, training reminders, payroll updates and information. An individual has the right to opt out of receiving text messages at any time.
Opt Out Right: To opt-out of all future text message communications, the individual can reply “STOP” to any text message received.

Sensitive Applicant Data

Sensitive Applicant Data is Applicant Data that may concern special categories of personal data in certain legislations, such as race or ethnic origin, health information, criminal history, disability, military service, etc. If LifeStance intends to collect Sensitive Applicant Data from third parties, it will provide notice and the opportunity to consent from the Applicant. If an Applicant has a disability and would like LifeStance to consider an accommodation, they may provide that information during the recruiting process.

Collected Applicant Data

The chart below identifies categories or examples of personal information and sensitive personal information covered by the CCPA some of which we collect:

Category	Examples Only	Collected	Purpose
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	YES	The Company collects personal identifiers to onboard personnel; enroll and administer benefits; enter into contracts; use for general human resource purposes; and limited information for a professional bio.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Some personal information included in this category overlap with other categories.	YES	The Company collects this information to process job applications; onboard personnel; enroll and administer benefits; enter into contracts; use for general human resource; and limited information for professional bio. The Company collects pay information – such as pay rate, payroll deduction information banking information for direct deposit, and credit card information for expense reimbursement – to pay its Personnel and comply with applicable laws.
Protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES	The Company collects equality and diversity information, such as minority, veteran and disability status, through voluntary self-disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws. The Company collects health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers’ Compensation insurance programs; and comply with applicable laws. The Company also collects information necessary for benefits enrollment and administration purposes.
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	If you are a contractor, we may collect commercial information from or about you in connection with obtaining services from you.
Biometric information	Physiological, behavioral, and biological characteristics, including DNA, that is or intended to be used either alone or in combination with other identifying data to establish individual identity, and includes other identifying information, such as, imagery of the iris or retina, fingerprint, face, hand, palm, vein patterns and voice recordings from which an identifier template or a voice print can be extracted, also includes, keystroke or gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	YES	Fingerprints if required by laws and for background check purposes; fingerprints or other biometric information for secure access purposes. Sleep, health or exercise data in connection with employee wellness programs. The Company collects this information to ensure that Personnel properly log-in to Company equipment and ensure that authorized Personnel have access to secured locations in the Company
Internet or other similar network activity	Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.	YES	The Company collects this information to protect Company, customer, and Personnel property, equipment and confidential information; monitor Personnel performance; and enforce the Company’s electronic communications acceptable use policies.
Geolocation data	Physical location or movements.	YES	The Company collects geolocation data for general human resource purposes.
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	YES	The Company may collect audio and visual information of Personnel through photographs used for identification purposes and to promote the Company. The Company collects audio and video recordings of training sessions.
Professional or employment related information	Current or past job history or performance evaluations.	YES	The Company collects professional and employment-related information to manage its relationship with Personnel.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES	The Company collects education information in connection with the job promotion process; to evaluate Employees for promotions; and to feature Employees in marketing materials and on the Company’s website.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	YES	The Company may collect inferences drawn from other personal information to manage our relationship with Personnel
Emergency Contact Information	Profile that will include the name and contact information and relationship to Employee.	YES	The Company collects this information to contact the Employee’s designated emergency contact persons in the event of an emergency.
Beneficiary Information	Profile will include the name and contact information, relationship to the Employee, birth date, Social Security Number, information necessary to process, benefits claims.	YES	The Company collects this information to enroll and administer benefits programs for beneficiaries of Employees.
Sensitive Personal Information	Personal information that reveals a person’s: social security, driver’s license, state identification card or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to the account; precise geolocation, race or ethnic origin, religious or philosophical beliefs, union membership, contents of a person’s mail, email and text messages unless the business is the intended recipient; genetic data; processing biometric information for the purpose of uniquely identifying a person; information collected and analyzed concerning a person’s health, sex life or sexual orientation. Note: Sensitive personal information does not include information that is “publicly available” as defined in 1798.140(v)(1)(L).	YES

Collection of Applicant Data

In addition to collecting Applicant Data directly from job applicants and employees, LifeStance may collect Applicant Data from third parties, for example, from recruiters, in connection with a background or employment check or an employment reference (subject to consent where required by law) or, to the extent permitted by law, from a recruiting or other website where information has been provided about work experience or interests. Where legally required, LifeStance may ask for additional information or references. In these circumstances, additional instructions will be provided during the application process.

Business Purposes and Processing of Applicant Data

Processing refers to any action performed on Applicant Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting. LifeStance processes Applicant Data for legitimate human resources and business management purposes.

Applicant Data may be removed or deleted, and outreach consent may be changed at any time as specified under How to Contact Us below. These include business purposes such as:

To evaluate your eligibility or suitability for any type of engagement or association with LifeStance, or your eligibility or suitability for employment, partnership or any continuation thereof, including but not limited to confirming employment, educational and military histories when applicable, check references and make background checks;
To calculate your salary and any withholding for state or federal taxes, social security payments or any benefits offered or required by LifeStance;
To make salary payments, other payments, direct deposits or necessary calculations;
To evaluate and permit your participation in any retirement plan offered by LifeStance in which you are eligible to participate under the terms of that plan and to administer your participation in and payments made to or from any plan;
To administer our personnel policies and to assess risk management issues;
To evaluate or administer any type of benefits offered by LifeStance for which you or a family member may be eligible, and to pay and or dispute claims;
For possible inclusion in any affirmative action programs including programs for veterans or individuals with disabilities;
To track the use of vacation, sick days, disability or leave policies;
To notify a person you designate in the event of an emergency;
To comply with any legal obligation imposed upon us by law;
To provide legal advice or services you may request that we agree to provide;
To defend or prosecute a lawsuit, administrative proceeding, or any type of legal, regulatory or administrative claim, challenge or dispute which may include responding to discovery requests involving your information;
To negotiate, conduct due diligence, document, settle or close a deal, transaction, contract or legal dispute, including the issuance of opinions to third parties in connection with above;
To communicate with you or a related third party such as our insurer, any benefits or claims administrator or your agent, broker or a claim administrator about the status, developments or the outcome or our legal analysis of any claim or dispute;
To comply with any legal demands or lawful orders issued in an administrative proceeding, by a tribunal or court of law such as subpoenas, warrants, or other legal process, or to comply with a regulatory obligation imposed by a governmental or regulatory agency or official, which could include meeting various compliance, screening, or recordkeeping requirements, anti-money laundering, financial and credit checks, fraud and crime prevention requirements, and which may require manual or automated checks of your personal information against various databases and lists;
To respond for requests for proposals (“RFPs”), to highlight your knowledge, background, experience for marketing purposes, for making pitches to payers, to respond to inquires or questionnaires, or in business development and marketing efforts to attract new business and/or to retain existing business;
For any other lawful purpose necessary to further the legitimate interests of LifeStance;
To comply with federal, state or local laws and regulations including but limited to tax, civil rights and ERISA.
To meet or fulfill the reasons you provided us the information, including to process offerings or requests, complete transactions, to make payments or refunds, to provide necessary information and to prevent transaction fraud;
To help maintain the safety, security, and integrity of our websites, products, services, applications, databases, networks, and other technical assets;
Debug, identify, rectify, or mitigate errors or vulnerabilities in our website, systems, applications, technologies, hardware, software, servers or equipment;
To evaluate, confirm compliance with, and enforce LifeStance’s Policies & Procedures;
To evaluate, confirm compliance with and enforce outside counsel guidelines issued;
To audit, improve, develop, modify or support our websites, products and services, to update and maintain contact, visitor or email lists and for other internal purposes;
To send invitations, announcements, and information about Company publications, programs, events, seminars, conferences, events, newsletters, publications, blogs social media feeds or to provide CLE or CE information.
To confirm an attorney’s licensure status, standing and admission to the bar of any state, jurisdiction, court of law or tribunal.
To respond to lawful requests for information through court orders, subpoenas, warrants and other legal process, obligations or governmental regulations;
To protect the operations of LifeStance, or the safety, security and privacy of LifeStance, our employees and staff, or third parties. This potentially includes sharing information with others for purposes of fraud protection, info security, and related matters;
To review, confirm and evaluate the identity of a person making a request concerning information in our possession.
To evaluate and resist malicious, deceptive, fraudulent or illegal actions directed at LifeStance or the information in our possession and to prosecute anyone responsible.
For any purpose related to any of the foregoing.

Applicant Data, based upon consent, may be also used to:

send communications regarding this or other employment opportunities;
retain and use Applicant Data to consider you for other positions;

Please note:

LifeStance does not and will not sell your personal information – Applicant Data.
LifeStance will not share your personal information with third parties for cross-context behavioral advertising purposes.
LifeStance will not use personal information – Applicant Data to make any automated decisions affecting the individual.

Employee Data

If a candidate is hired, Applicant Data may be used in connection with his/her employment consistent with LifeStance’s employment data protection policies. Employee data will be used for processing payroll and employee benefit plan and program administration including enrollment and claims handling; maintaining personnel records and record retention requirements; communicating with employees and/or employees’ emergency contacts and plan beneficiaries; complying with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws; preventing unauthorized access to or use of the LifeStance property, including the Company’s information systems, electronic devices, network, and data; ensuring employee productivity and adherence to LifeStance’s policies; and investigating complaints, grievances, and suspected violations of Company’s policy(ies). Employees who are treating providers consent and provide LifeStance the necessary information to have LifeStance create and post publish their professional bio/profile listing their name, professional licenses, specialties, photo on its website as a way for patients to see and select a provider that best meets their needs.

Data Retention

The length of time we retain information depends on the nature of the information and the context in which it was received. We strive to retain information in accordance with our record retention schedule. To the extent permitted by applicable law, LifeStance may retain personal information obtained as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

We may share personal data received when necessary to administer background checks, our payroll, benefits or plans with vendors or other service providers with whom we contract to assist in the provision of those benefits or payments. This may require that we share your information with vendors like Workday, or others such as accountants, actuaries, insurers or third-party administrators or consultants used by an insurer, benefit provider, or vendors we retain to assist us when necessary to accomplish any of the purposes noted above. Additionally, LifeStance may be required to disclose certain Applicant Data to other third parties (1) as required by law; (2) to protect LifeStance’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of the applicant or another individual may be endangered as further described below.

Information from LifeStance’s equipment or your use of LifeStance’s network, systems or equipment may be shared with vendors, who provide data and cybersecurity to LifeStance. When necessary, information may be shared with court reporters, videographers, notaries, trial consultants, judges, courts, tribunals, arbitrators, lawyers and mediators involved in the resolution of a dispute. When relevant to our marketing and business development efforts, LifeStance may share Applicant Data with existing or potential patients, such as licensure/credentials.

We may also share your personal information with courts of law, law enforcement authorities, governmental officials or regulators, attorneys or other third parties when it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for purposes of an alternative dispute resolution process; to investigate or prosecute the violation of any law or regulation, to recover our applications, software, hardware, equipment or assets, to comply with a subpoena or court order, legal process, or other legal requirement or when we believe in good faith that such disclosure is necessary to comply with the law, to prevent physical harm or financial loss, to investigate, prevent or take action concerning illegal activities, suspected fraud, threats to LifeStance, any of its employees/workforce or our property; or as necessary in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity.

LifeStance uses third-party web analytics services in connection with the Online Channels, including HEAP Analytics, VWO, CloudFlare, Viemoe, Pardot, Smartsheet Analytics, some which may use cookies, cookieless and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels. LifeStance also uses various third-party platforms for enrollment, payment, engagement, call tracking and careers postings such as Avochado, Phreesia, Invoca, Birdeye, Google Maps, Boostie, and Delia. To learn more about these and other services and how to opt out, please select the Cookie link available at the bottom of the page.

Children’s Personal Information

The LifeStance Careers Website is designed for a general audience and are not directed to children as per applicable law. LifeStance does not knowingly collect or solicit personal information from children as per applicable law. If we become aware that we have collected personal information from a child under as per applicable law, LifeStance will promptly delete the information from our records. If you believe that a child may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Applicant and Employee Privacy Notice.

Automated Decisions

LifeStance generally does not make recruiting or hiring decisions based solely on automated decision-making. In the event that LifeStance relies solely on automated decision-making that could have a significant impact on you, LifeStance will provide you an opportunity to express your views and will provide any other safeguards required by law.

Direct Marketing

LifeStance will not use Applicant Data to offer any products or services for personal or family consumption (“direct marketing”) or provide Applicant Data to third parties for their direct marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with LifeStance.

Applicant Rights

To the extent provided by the law of your jurisdiction, you may have the right to:

Request that we update, correct, amend, erase, or restrict your personal information; or
exercise your right to data portability

Where provided by law, you may withdraw consent you previously provided to LifeStance or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate.

To request to exercise these rights, please contact us as indicated in the How to Contact Us section of this Notice.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. LifeStance strives to respond to complaints within thirty days of receipt, or less when required by applicable law.

How to Contact Us

Request to Disclose, Restrict, or Delete Employee and Applicant Data

To ask questions or comment about this privacy policy and our privacy practices, or if you would like us to update information, we have about you, or update preferences around the use of your data, please reach out to us using the contacts below:

Calling us at 1-800-308-0994
Written communication can be directed to LifeStance Health, Attn: Privacy Officer, 4800 N. Scottsdale Road, Scottsdale, AZ 85251
Email us at [email protected]