MindsWellMindsWell

Privacy Policy

Effective Date: January 1, 2025 | Last Updated: September 17, 2026

1. Introduction and Scope

Mindswell Innovations LLP ("Mindswell", "We", "Us", or "Our") is deeply committed to protecting the privacy and confidentiality of its Users, particularly given the sensitive nature of mental health information. This Privacy Policy explains how we collect, use, store, share, and protect your Personal Information and Sensitive Personal Information when you access or use the Platform.

This Privacy Policy is published in compliance with, inter alia:

By using the Platform, you acknowledge that you have received and read this Privacy Policy. Where applicable law requires consent for the processing of Personal Information, Mindswell will seek consent through a clear affirmative action for specified purposes. For mental-health or health information and other Sensitive Personal Information, Mindswell will seek specific consent at or before the point of collection, separate from general acceptance of these Terms where appropriate. If you decline or withdraw consent where withdrawal is permitted by law, certain features or Services may no longer be available; withdrawal will not affect processing already lawfully undertaken or retention required by law.

2. Information We Collect

2.1 Information Provided by You

When you register or use the Platform, we may collect:

(a) Patient Information

(b) Practitioner Information

2.2 Information Collected Automatically

When you use the Platform, we automatically collect:

2.3 Information from Third Parties

We may receive information about you from:

3. Sensitive Personal Information — Special Protections

Given the nature of our Platform, we collect and process Sensitive Personal Information ('SPI'), including:

We collect and process SPI only for the specific purposes stated in this Privacy Policy and, where consent is required by applicable law, with explicit and specific consent obtained at or before collection. Consent for mental-health and health information will be sought through a clear affirmative step and will not rely solely on general use of the Platform. SPI is subject to heightened security measures as described in Section 7. You may withdraw consent where permitted by applicable law; however, doing so may limit your ability to use certain features of the Platform.

Mental health records and session-related information are treated with the highest level of confidentiality. We will not disclose such information to any third party except: (a) with your explicit consent; (b) as required by law or court order; (c) in a genuine medical emergency where disclosure is necessary to prevent serious harm; or (d) to the Practitioner involved in your care.

4. How We Use Your Information

We use the information we collect for the following purposes:

5. Disclosure and Sharing of Information

5.1 Sharing with Practitioners

Information shared by a Patient (including health information) may be shared with the Practitioner the Patient is consulting. Practitioners are bound by professional confidentiality obligations and by the terms of their agreement with Mindswell.

5.2 Service Providers

We share information with trusted third-party service providers who assist in operating the Platform, including payment processors, cloud hosting providers, communication infrastructure providers, and analytics tools. These providers are contractually required to maintain confidentiality and security of your data and may not use it for any purpose other than providing services to Mindswell.

5.3 Legal Disclosure

We may disclose your information where required by law, regulation, court order, or governmental authority. We may also disclose information where we believe in good faith that disclosure is necessary to: (a) protect the rights, property, or safety of Mindswell, its Users, or the public; (b) prevent or investigate possible wrongdoing; or (c) respond to legal process.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your information may be transferred to the successor entity. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.

5.5 No Sale of Data

Mindswell does not sell, rent, or trade your Personal Information or Sensitive Personal Information to third parties for their marketing purposes.

6. Data Retention

We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected and as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, we will securely delete or anonymize your data. Practitioner records may be retained for longer periods to the extent required by medical regulatory requirements.

7. Data Security

We implement robust technical and organizational security measures to protect your Personal Information against unauthorized access, loss, destruction, alteration, or disclosure. Our measures include:

Notwithstanding the above, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. In the event of a data breach affecting your rights, we will notify you in accordance with applicable law.

8. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform. Types of cookies we use include:

You may control cookie preferences through your browser settings. Disabling certain cookies may affect your ability to use some features of the Platform. For more details, please refer to our Cookie Policy available on the Platform.

9. Your Data Protection Rights

Subject to applicable law, you have the following rights in relation to your Personal Information:

To exercise any of these rights, please contact us at privacy@Mindswell.com. We will respond to verifiable requests within 30 days as required by applicable law.

10. Children's Privacy

The Platform is not directed at individuals under the age of 18. We do not knowingly collect Personal Information from minors. If a parent or guardian believes that a minor has provided Personal Information to the Platform without their consent, they should contact us immediately at privacy@Mindswell.com, and we will take steps to delete such information promptly.

11. Grievance Officer

In accordance with the Information Technology Act, 2000 and the rules thereunder, and the Consumer Protection (E-Commerce) Rules, 2020 as applicable, we have appointed a Grievance Officer to address privacy concerns and consumer complaints. To the extent required under the Digital Personal Data Protection Act, 2023 and applicable rules, Mindswell will also make available the business contact information of the person responsible for answering questions regarding the processing of Personal Data and will appoint a Data Protection Officer if required to do so as a Significant Data Fiduciary. If you have any questions, complaints, or concerns about this Privacy Policy, our data practices, or consumer-facing Platform services, please contact:

Grievance Officer — Mindswell

Name: Chit Rokad

Company: Mindswell Innovations LLP

Email: admin@mindswell.in

Phone: +919979095901

Address: 8, Parivar Society, Prem Chand Nagar road, Satellite, Ahmedabad, Gujarat - 380015

Office Hours: Monday to Friday, 10:00 AM to 6:00 PM IST

We will acknowledge your complaint within 48 hours and endeavor to resolve it within 30 days of receipt.

12. Amendments to this Privacy Policy

Mindswell reserves the right to update or modify this Privacy Policy at any time. We will notify you of material changes by posting the updated Policy on the Platform with a revised 'Last Updated' date, and, where appropriate, by email or in-app notification. Your continued use of the Platform after any such changes constitutes your acceptance of the revised Privacy Policy.

13. Cross-Border Data Transfers

Your information may be transferred to and processed in countries outside India where our service providers operate. When we transfer information outside India, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws, including contractual protections such as standard contractual clauses or equivalent mechanisms.

This document was prepared for Mindswell Innovations LLP. It is intended as a starting point and should be reviewed and finalized by qualified legal counsel familiar with all applicable laws before publication. © 2025 Mindswell Innovations LLP. All rights reserved.

MINDSWELL

PRACTITIONER ACKNOWLEDGEMENT & ACCEPTANCE

For Psychologists Providing Services Through the Mindswell Platform

Document

Mindswell Terms of Use & Privacy Policy

Document Version

Effective January 1, 2025 | Last Updated September 17, 2026

Company

Mindswell Innovations LLP

Acknowledgement

I, the undersigned psychologist/practitioner, confirm that I have received and had the opportunity to review the Mindswell Terms of Use & Privacy Policy set out in the preceding pages. I acknowledge that the document forms part of the terms governing my use of, and provision of professional services through, the Mindswell platform.

• I have read and understood the provisions applicable to Practitioners and agree to comply with them while using the Mindswell platform.

• I will provide services only within the scope of my qualifications, competence, registrations, memberships, and applicable professional requirements.

• I will maintain professional and ethical standards, patient/client confidentiality, appropriate records, and the privacy and security of information entrusted to me.

• I will promptly inform Mindswell of any material change to my professional qualifications, registration or membership status, or other information relevant to my eligibility to provide services.

• I understand that this signed page is retained as a record of my receipt and acceptance of the Terms of Use & Privacy Policy and does not replace any separate Practitioner Agreement entered into with Mindswell Innovations LLP.

Practitioner Details & Signature

Full Legal Name

Professional Title

Psychologist

Email / Mobile

Signature

Date & Place

Please sign and return this page to Mindswell for record-keeping.

Questions about this document? Email admin@mindswell.in.