Privacy Policy 

Effective date: March 6, 2023

Last updated: May 14, 2025

We at MindRight know you care about how your personal information is used and shared, and we take your privacy seriously.  Please read the following to learn more about our Privacy Policy.  By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, and sharing your information in the following ways. 

Remember that your use of MindRight’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy.  Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.  

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including Sensitive Personal Information(“Personal Information”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage.  Sensitive Personal Information includes Personal Information that reveals a consumer’s (A) social security, driver’s license, state identification card, or passport number, (B) 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 an account, (C)  precise geolocation, (D) racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership, (E) mail, email, and text messages content unless MindRight is the intended recipient of the communication, (F) Personal Information collected and analyzed concerning a consumer’s health, (G) Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.

We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below. 

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register or use the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at hello@mindright.io.

 

Will MindRight ever change this Privacy Policy?

 We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on www.mindright.io, by sending you an email or text, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them.  If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.  Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

 What Personal Information does MindRight Collect?

 Categories of Personal Information

 The categories of Personal Information we may collect and have collected in the past 12 months are:

 (A) Identifiers such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

(B) Personal Information including information that identifies, relates to, describes, or is capable of being associated with, you or a particular individual, including, but not limited to, name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, or medical information.

(C) Characteristics of protected classifications under California or federal law, including, but not limited to race, gender, age, sexual orientation, military or veteran status, national origin, physical or mental disability.

(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

(E) Biometric information, such as sleep, health, or exercise data

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.

(G) Geolocation data. For example, our server automatically tracks your geolocation.

(H) Audio, electronic, visual, thermal, olfactory, or similar information. This may include certain types of communications that you send to our coaches.

(I) Professional or employment-related information, such as job title or employer.

(J) Education information, which is not publicly available personally identifiable information.

(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

(L) Sensitive Personal Information, including but not limited to, a consumer’s racial or ethnic origin, sexual orientation, immigration status, religious or philosophical beliefs, or union membership.

Where Does MindRight Collect My Personal Information From And Why?

 

Information You Provide to Us:

We receive and store any information you knowingly provide to us.  For example, if you indicate interest on our website, we may collect Personal Information such as your name, email address, and organization.  If you opt into the Services via text, we may collect Personal Information such as your name, phone number, email address, and age.  We may also collect information that you provide to us in an enrollment survey or in a wellness and/or depression screening.  Further, if you text our coaches, we may collect the text message history between you and our coaches, as well as aggregate data about those conversations, like your overall emotions expressed, topics of conversation, and strategies we’ve used to support you.

We may communicate with you if you’ve provided us the means to do so.  For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses or email you about your use of the Services.  If you do not want to receive communications from us, please indicate your preference by clicking “unsubscribe” on our newsletters, replying “STOP” to our text messages, or by emailing us at hello@mindright.io. If you use our text messaging services, please see our Terms of Use for further information about ceasing communications.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people.  You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.  

Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices.  Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this De-Identified Information to customize content for you that we think you might like, based on your usage patterns.  De-Identified Information means information that cannot reasonably be linked to an identified or identifiable individual or household. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.   

 

Information Collected From Other Websites and Do Not Track Policy

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services.  Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.  Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.  When you turn on the Do Not Track function in your browser, we stop collecting the information from your browser that allows us to tailor advertisements and other content specifically to you that is based on your visits to our advertising partners’ websites.  Specifically, we stop collecting information from the unique browser cookie that links your browser to visits to third party sites.  Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.  Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser.

 

Does MindRight Sell or Share my Personal Information?

No, MindRight does not Sell or Share Personal Information. Additionally, MindRight does not have actual knowledge that it Sells or Shares the Personal Information of consumers under sixteen (16) years of age.

Selling means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your Personal Information to a third party in exchange for money or other compensation.

However, Selling does not include:

·                Disclosures or interactions with third parties as directed by you.

·               Transfers to processors that process Personal Information on our behalf.

·               Disclosures necessary for providing MindRight’s services that you request.

·               Transfers to affiliates our affiliates.

·               Disclosures of Personal Information made publicly available by you.

·               Transfers as part of a merger, acquisition, or similar transaction, provided Personal Information is used consistently with the original terms.

Sharing means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s Personal Information to a third party for Cross-Context Behavioral Advertising, even if no money is exchanged. Cross-Context Behavioral Advertising means the targeting of advertising to you based on your Personal Information obtained from your activity across businesses, distinctly branded internet websites, applications, or services, other than such activity on MindRight’s platforms.

However, Sharing does not include:

·               Disclosures or interactions with third parties as directed by you.

·               Alerting other third-parties that you have opted out of sharing your Personal Information.

·               Transfers as part of a merger, acquisition, or similar transaction, provided Personal Information is used consistently with the original terms.

 

What are my privacy rights?

Right to Delete  

You may request that MindRight delete the Personal Information we collected about you. If your request is accepted, MindRight will delete your Personal Information from our records, and we will notify any service providers, contractors, or other parties with whom we have shared or sold your Personal Information to do the same.

 We may retain confidential record of your deletion request to prevent the Personal Information from being sold or to comply with any applicable laws.

 Right to Correct

 

You may request that MindRight correct inaccurate Personal Information. We will use commercially reasonable methods to comply with your request.

 

Right to Know What Personal Information is Being Collected/Right to Access Personal Information

 

You may request that MindRight disclose (1) the categories of Personal Information we collect about you, (2) the sources form which we collect the Personal Information, (3) the business or commercial purpose for collecting, selling, or sharing Personal Information, (4) the categories of third parties to whom we disclose Personal Information and (5) the specific pieces of Personal Information we have collected about you.

 

Right to Limit Use of Sensitive Personal Information and Notice of Right to Limit

You may request that MindRight limit our use of your Sensitive Personal Information to what is necessary to perform our Services.

 If you want to limit our use of your Sensitive Personal Information you or your authorized agent can follow this link. We will comply with your request and notify any relevant third parties of your request within 15 business days from the date we receive your request.

 

Right to Non-Discrimination

 MindRight respects your right to privacy. We will not discriminate against you because you have exercised any of your rights under this Privacy Policy. Specifically, we will not deny you access to our Services, charge you different prices, or provide a different level of quality of Services if you exercise your privacy rights.

 How can I exercise these privacy rights?

 To exercise any of these rights you can send your request to hello@mindright.io.

 Upon receiving your request, we will need to verify your identity. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 An authorized agent, such as a parent, guardian, or conservator, may submit your request on your behalf, however, we will have to similarly verify the authorized agent’s authority to submit such request.

 We will respond to your request within 45 days, or we will notify you if we need to extend our review period for an additional 45 days.

 

Will MindRight Disclose Any of the Personal Information it Receives?

We may disclose your Personal Information with third parties as described in this section:

 

Information that’s been De-Identified.  We may disclose  De-Identified Information. . For example, if you text our coaches, we may disclose De-Identified Information, such as demographic data, topics of conversation, and emotion data with our partners.  We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience. 

 

Advertisers : We may deliver a file to you through the Services (known as a “web beacon”) from an ad network.  Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers.  Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites.  Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.  You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.

 

Affiliated Businesses: In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us).  You can recognize when an affiliated business is associated with such a transaction or service, and we will disclose your De-Identified Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

 

Information that’s identifiable. If a third party is paying for your use of our coaching services, we may share certain Personal Information with them.  For example, if your school offers to pay for you to text MindRight’s coaches, we may send the school reports with your demographic data, identification number, the results of your depression screening and assessments, and how often you are using the service.  The school may be able to identify you based on your identification number.  We may also disclose Personal Information with a third party, such as a crisis services or care provider, when you request or agree to such disclosure, or when you indicate a risk of harm to yourself or another person. However, if you do not use our coaching services, we will never disclose de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person. For both types of disclosures, MindRight only shares the following types of Personal Information: your usage, name, phone number, address, emergency contact information, age, and gender.

Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party. 

 

Protection of MindRight and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of MindRight, our employees, our users, or others.  

 

Is Personal Information about me secure?

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security.  Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. 

 

What Personal Information can I access?

If you use our text messaging services, you may text 886-886 to access, and, in some cases, edit or delete the following information you’ve provided to us:

·       name 

·       email address

·       location

·       age

·       phone number

·       chat logs.

The information you can view, update, and delete may change as the Services change.  If you have any questions about viewing or updating information we have on file about you, please contact us at hello@mindright.io.  If you use our text messaging services, please see our Terms of Use for further information about ceasing communications.

 What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

 

You may be able to add, update, or delete information as explained above.  When you update information, however, we may maintain a copy of the unrevised information in our records.  If you use our texting services, you may request deletion of your account by emailing support@mindright.io.  If you’ve submitted information on our website, you may request deletion of your account by emailing support@mindright.io. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.  

 

Finally, keep in mind that if you choose to turn on the Do Not Track function on your browser, we may continue to use all information we collected prior to your turning that function on, in the manner described in this Privacy Policy.

 

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to hello@mindright.io, and we will try to resolve your concerns.