1. Introduction
Minda Mental Health ("we", "us", or "our") is a mental wellness companion application operated by Cem G. ("the developer"). This Privacy Policy explains in detail what data we collect, how we collect it, how we use it, who we share it with, and what protections are in place.
Minda uses third-party AI services to generate supportive conversations. This policy explicitly describes what user data is sent to these services, who processes it, and how it is protected.
2. What Data We Collect
2.1 Account Information
When you create an account, we collect:
- Email address — used for authentication and account recovery
- Display name — optional, shown in the app interface
- Preferred language — one of 10 supported languages
- Trusted contact name and phone number — optional, for emergency use
How collected: User enters manually during registration or profile editing.
2.2 Chat Messages (Text)
When you use the chat feature, we collect:
- Chat messages you send — the text you type or dictate
- AI-generated responses — the text Minda replies with
- Conversation history — stored to provide context for future conversations
- AI memory summaries — condensed notes about your patterns and preferences, updated every 10 messages
How collected: User types or dictates messages in the chat interface.
How used: Your messages are sent to OpenRouter (AI service) for processing. Both your messages and AI responses are stored in our database to maintain conversation continuity.
2.3 Voice and Audio Data
When you use the voice assistant feature, we collect:
- Voice recordings — temporary audio captured from your microphone
- Transcribed text — the text version of your speech, stored in chat history
- AI-generated speech — text-to-speech audio generated for voice responses
How collected: User taps the microphone button in the app. The device microphone records audio with user permission.
How used: Voice recordings are sent to ElevenLabs Scribe for speech-to-text conversion. The audio is processed and not permanently stored by ElevenLabs. The transcribed text is then sent to OpenRouter for AI processing. AI responses may be converted back to speech using ElevenLabs text-to-speech.
2.4 Image Data
When you upload an image in the chat, we collect:
- Uploaded images — photos selected from your device gallery or taken with the camera
- Image file name — the original file name of the uploaded image
How collected: User selects an image via the paperclip button in the chat interface.
How used: Images are converted to base64 format and sent to OpenRouter along with your message. The AI vision model (meta-llama/llama-3.2-11b-vision-instruct) processes the image to generate a response. Images are not permanently stored by OpenRouter.
2.5 Mood Data
When you use mood tracking, we collect:
- Mood scores — numerical mood ratings (1-5)
- Optional mood notes — text you add to a mood entry
- Timestamps — when each mood entry was recorded
How collected: User taps a mood rating in the Mood screen. Notes are optional.
How used: Mood data is stored in our database. It is not sent to any third-party AI service. It is used solely for mood tracking and pattern visualization within the app.
2.6 Thought Records
When you create thought records, we collect:
- Situation description — what happened
- Thought — what you thought
- Emotion — what you felt and its intensity
- Body response — optional physical sensations
How collected: User manually fills in the thought record form.
How used: Your thought record entries (situation, thought, emotion) are sent to OpenRouter (AI service) to identify cognitive distortions and generate a balanced reframe suggestion. The AI-generated distortion label and reframe are stored in our database alongside your original entry.
2.7 Automatically Collected Data
- Device type and OS version — for compatibility
- App version — for support and updates
- Language preference — for localization
- Timestamps — when interactions occur
- Usage statistics — messages sent, features used (aggregated, anonymized)
How collected: Automatically collected when the app runs.
2.8 Summary Table
| Data Type | Sent to OpenRouter? | Sent to ElevenLabs? | Stored on our servers? |
|---|---|---|---|
| Chat messages (text) | Yes | No | Yes |
| AI responses | Generated by | No | Yes |
| Voice recordings | No (transcribed text only) | Yes (for transcription) | No (transcribed text only) |
| Uploaded images | Yes (base64) | No | No (processed in transit) |
| Mood entries | No | No | Yes |
| Thought records | Yes — for CBT reframe analysis | No | Yes |
| Account info | No | No | Yes |
| Trusted contact | No | No | Yes |
3. Third-Party AI Services — Detailed Disclosure
Minda uses third-party AI services to provide its core functionality. Below is a detailed explanation of what data is shared, with whom, and how it is protected.
3.1 OpenRouter (AI Text & Vision Processing)
What data is sent: Your chat messages (text), AI conversation history for context, and uploaded images (in base64 format).
Who processes it: OpenRouter Inc., which routes requests to AI models including GLM-5.2 (for text chat) and meta-llama/llama-3.2-11b-vision-instruct (for image analysis).
How it is used: OpenRouter processes your messages to generate supportive AI responses. The messages and responses are transmitted over HTTPS encrypted connections.
Retention: OpenRouter may temporarily log requests for abuse prevention but does not permanently store your conversation data or use it to train their models. See OpenRouter's Privacy Policy.
Protection equivalence: OpenRouter provides data protection that is equivalent to or greater than our own, including HTTPS encryption, access controls, and compliance with applicable data protection regulations.
3.2 ElevenLabs (Voice Processing)
What data is sent: Your voice recordings (audio) for speech-to-text conversion, and AI-generated text responses for text-to-speech synthesis.
Who processes it: ElevenLabs Inc., using their Scribe API (speech-to-text) and text-to-speech API.
How it is used: ElevenLabs converts your voice recordings to text (speech-to-text) and converts AI text responses to natural-sounding speech (text-to-speech). Audio is processed in transit and not permanently stored by ElevenLabs.
Retention: ElevenLabs processes audio in real-time and does not permanently store your voice recordings. The transcribed text is returned to our server and stored in your chat history. See ElevenLabs' Privacy Policy.
Protection equivalence: ElevenLabs provides data protection that is equivalent to or greater than our own, including encryption, access controls, and GDPR compliance.
3.3 Apple StoreKit (In-App Purchases)
What data is sent: Purchase receipts for verification. No personal message data is shared with Apple.
Who processes it: Apple Inc., via the StoreKit 2 framework.
How it is used: Apple verifies subscription purchases and manages billing. See Apple's Privacy Policy.
4. How We Use Your Data
| Use | Data involved | Sent to third party? | |
|---|---|---|---|
| Generate AI chat responses | Chat messages, conversation history, images | Yes — OpenRouter | |
| Voice assistant (STT) | Voice recordings | Yes — ElevenLabs | |
| Voice assistant (TTS) | AI response text | Yes — ElevenLabs | |
| Image analysis | Uploaded images | Yes — OpenRouter (vision model) | |
| Mood tracking | Mood scores, notes | No — stored locally on our servers | |
| Thought records (CBT analysis) | Situation, thought, emotion | Yes — OpenRouter | Yes — OpenRouter (for CBT reframe) |
| Personalization (AI memory) | Summarized conversation patterns | Yes — OpenRouter (for generation) | |
| Crisis resources | Language preference (for hotline numbers) | No | |
| Subscription management | Purchase receipts | Yes — Apple StoreKit | |
| Account management | Email, display name | No |
5. Data Storage and Security
5.1 Storage Location
Your data is stored on our secure servers located in the European Union (Amsterdam region).
5.2 Security Measures
- Encryption in transit: All data is transmitted via HTTPS/TLS 1.3
- Password hashing: User passwords are hashed using bcrypt (never stored in plain text)
- Authentication: JWT tokens stored in device Keychain/Secure Storage
- Database security: Restricted access, authenticated connections, regular updates
- Rate limiting: Authentication endpoints are rate-limited to prevent abuse
- PIN protection: App can be locked with a PIN stored in flutter_secure_storage
- SSL certificate: Valid Let's Encrypt certificate for minda-app.com
5.3 Data Retention
Your data is retained for as long as your account is active. Specifically:
- Chat history: Retained until account deletion
- AI memory: Updated every 10 messages, retained until account deletion
- Voice recordings: Not permanently stored (processed in transit only)
- Images: Not permanently stored (processed in transit only)
- Mood entries: Retained until account deletion
- Thought records: Retained until account deletion (including AI-generated reframe)
- Account info: Retained until account deletion
6. Your Rights (GDPR)
If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (GDPR):
- Right of Access: Request a copy of your personal data
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure ("Right to be Forgotten"): Delete your account and all data at any time from the Profile screen
- Right to Data Portability: Request your data in a structured, machine-readable format
- Right to Object: Object to the processing of your personal data
- Right to Withdraw Consent: Withdraw consent for AI data sharing at any time by deleting your account
To exercise any of these rights, contact us at cemfb@live.nl.
7. Account Deletion
You can delete your account and all associated data at any time from the Profile screen in the app. Account deletion is permanent and irreversible. When you delete your account:
- All chat history is permanently deleted from our servers
- All AI memory summaries are permanently deleted
- All mood entries and thought records are permanently deleted
- Your email address, display name, and profile information are permanently deleted
- Your trusted contact information is permanently deleted
- Active subscriptions are not automatically cancelled — you must cancel via Apple Account settings
Account deletion takes effect immediately and cannot be undone.
8. Subscription Management
Minda offers auto-renewable subscriptions managed through Apple's StoreKit 2:
- Monthly: €6.99/month
- Yearly: €45/year (save 40%)
Subscriptions auto-renew unless cancelled at least 24 hours before the end of the current billing period. You can manage and cancel subscriptions in your Apple Account settings (Settings → Apple ID → Subscriptions). Cancelling a subscription does not trigger account deletion — you retain access until the end of the current billing period.
9. Data Sharing Summary
We do not sell, rent, or trade your personal data. We only share data in the following circumstances:
| Recipient | Data shared | Purpose | Equal protection? |
|---|---|---|---|
| OpenRouter | Chat messages, images, conversation history | AI response generation | Yes — HTTPS, GDPR-compliant |
| ElevenLabs | Voice recordings (temporary), AI text for TTS | Voice processing | Yes — HTTPS, GDPR-compliant |
| Apple (StoreKit) | Purchase receipts only | Subscription verification | Yes — Apple's privacy standards |
We confirm that all third-party services we share data with (OpenRouter, ElevenLabs, Apple) provide data protection that is equal to or greater than our own, including HTTPS encryption, access controls, and compliance with applicable data protection regulations including the GDPR.
10. Children's Privacy
Minda is not intended for children under 17. We do not knowingly collect personal data from children under 17. If you believe we have collected data from a child under 17, please contact us immediately.
11. International Users
If you access Minda from outside the European Union, your information may be transferred to, stored, and processed in the EU. By using Minda, you consent to this transfer. Your data may also be processed by our third-party service providers (OpenRouter, ElevenLabs) which may be located outside the EU, but all transfers are conducted in compliance with GDPR Article 44-50 (transfers of personal data to third countries).
12. Crisis and Emergency Situations
In crisis situations, Minda provides emergency hotline numbers based on your language preference. Minda does not store or transmit crisis-related data beyond normal chat history. If you are in immediate danger, please contact your local emergency services directly (112 in the EU, 911 in the US).
13. Medical Disclaimer
Minda is not a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of a qualified healthcare provider with any questions regarding a medical condition.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the app and updating the "Last updated" date.
15. Contact Us
If you have questions about this Privacy Policy or how your data is handled, please contact:
Email: cemfb@live.nl