Privacy Policy
This Privacy Policy describes how MentCura Labs Private Limited ("MentCura", "we", "us", or "our") collects, uses, stores, and shares your personal data when you use the MentCura mobile application and related services (the "Service"). This Policy applies to all users including free users and MentCura Pro subscribers.
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority.
Application refers to MentCura, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to MentCura Labs Private Limited.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to Delhi, India.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application or the Website or both.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to MentCura, accessible from http://www.mentcura.com
MentCura App refers to MentCura User app, accessible from Google Play
MentCura ProConnect refers to MentCura Therapist App, accessible from Google Play
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- First name and last name
- Email address
- Phone number
- Device identifiers (such as device ID and user ID)
Subscription & Payment Data
When you purchase MentCura Pro, we collect:
- Transaction records: Date, subscription tier, and billing cycle of your purchase. We do not collect or store your credit/debit card number or bank details. All payment processing is handled by Apple App Store or Google Play Store on your behalf.
- Subscription status: Whether your account has an active Pro subscription, expiry date, and renewal history.
- Promotional code redemptions: Records of any coupon or promo codes applied to your account (e.g. for trial access).
Apple and Google's privacy policies govern their collection of financial information. We receive only a transaction confirmation and subscription status from these platforms.
AI Interaction Data
When you use AI-powered features (AI coach, guided conversations, personalised recommendations):
- Conversation content: The text you type to the AI coach is processed to generate responses. This content is treated as sensitive mental health data.
- Interaction metadata: Timestamps, session duration, and feature usage patterns.
- Model improvement: Anonymised and aggregated interaction data may be used to improve AI model quality. Individual conversations are never shared with third parties for advertising purposes.
Points & Activity Data
- Records of in-app activities completed (habits checked, challenges finished, sessions attended) for the purpose of awarding and tracking Points.
- Points balance, transaction history, and redemption records.
- Streak data and milestone achievements.
Community Notes Data
When you post Community Notes or engage with community features:
- Content you post: Text, reactions, and responses visible to other MentCura users.
- Interaction data: Likes, replies, and reports you make on others' content.
- Moderation records: If your content is reported or removed, a record is kept for safety and compliance purposes.
Important: Do not post personally identifiable information in Community Notes. Content shared in community features is visible to other MentCura users.
Special Categories of Personal Data
MentCura handles data that may reveal information about your mental and emotional health, including mood logs, journal entries, AI conversations, therapy notes, and wellness assessments ("Mental Health Data"). We treat this data with the highest level of protection:
- Mental Health Data is encrypted at rest using AES-256 encryption.
- Mental Health Data is never sold to third parties.
- Mental Health Data is never used for advertising targeting — by us or any third party.
- Mental Health Data is not shared with your employer, insurer, or any other institution without your explicit, informed consent except where required by law.
- AI conversations are processed to provide you with responses but are not reviewed by human staff except in cases where safety concerns are flagged or you provide explicit consent for quality review.
MentCura Pro subscription data (what tier you are on) is kept separate from your Mental Health Data and is not linked in any externally shared reports.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of this Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Process and manage your Pro subscription | Subscription & payment data | Contract performance |
| Provide AI coaching and personalised recommendations | AI interaction data, mood data | Contract performance / Legitimate interest |
| Award and track Points and rewards | Activity data, Points records | Contract performance |
| Display and moderate Community Notes | Community content | Contract performance |
| Detect and prevent abuse of Promo Codes | Promotional redemption records | Legitimate interest |
| Comply with Apple/Google App Store requirements | Transaction records | Legal obligation |
| Improve AI model accuracy (anonymised only) | Aggregated AI interaction data | Legitimate interest |
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Third-Party Services and Data Sharing
The following third parties process data on our behalf or receive data as part of providing the Service:
| Third Party | Purpose | Data Shared | Their Privacy Policy |
|---|---|---|---|
| Apple App Store | Subscription billing (iOS) | Transaction confirmation, subscription status | apple.com/legal/privacy |
| Google Play Store | Subscription billing (Android) | Transaction confirmation, subscription status | policies.google.com/privacy |
| Firebase / Google | Analytics, crash reporting, push notifications | Device ID, usage events, notification tokens | firebase.google.com/support/privacy |
| OpenAI | AI coach responses | Conversation content (anonymised where possible) | openai.com/privacy |
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
| Data Type | Retention Period | Reason |
|---|---|---|
| Subscription records | 7 years after account closure | Tax and legal compliance |
| Payment transaction IDs | 7 years | Financial record-keeping |
| Community Notes | Until deleted by user or removed by moderation | Service provision |
| Points history | Duration of account | Service provision |
| Promo code redemption records | 2 years | Fraud prevention |
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Your Rights and Data Deletion
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Rights of Pro Subscribers
In addition to general user rights, MentCura Pro subscribers have the right to:
- Access a record of all subscription transactions associated with your account.
- Export your mental health data in a portable format upon request (contact privacy@mentcura.com).
- Delete your account and all associated data, including Mental Health Data, AI conversation history, Community Notes, and Points records. Subscription transaction records required for legal compliance will be retained per the retention schedule above.
To exercise any of these rights, contact: privacy@mentcura.com
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Children's Privacy
MentCura is not intended for users under the age of 17. We do not knowingly collect personal data from children under 17. Mental health data, AI conversations, and community features carry particular sensitivity and are not appropriate for minors. If we become aware that a user under 17 has created an account, we will delete their account and all associated data promptly.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
Data Controller:
MentCura Labs Private Limited
5th Floor, Maharishi Kanad Bhawan, Near North Campus, University of Delhi - 110007
Privacy Enquiries:
Email: privacy@mentcura.com
For subscription/billing issues:
Contact Apple or Google Play support directly.