Witmer Health Technologies Private Limited (“Witmer Health Technologies”, “Mind-n”, “We”, “Us”, or “Our”) operates the website www.mindn.ai and all associated domains) and the Mind-n mobile, web-based application and online applications (“Mind-n App” or “App/s” or “Mobile Software/s”), as well as the Mind-n Gym phygital services including mind-n gym facilities, integrated digital tools, wearables, and in-person sessions. The wellness models, the productivity models, assisted tech audio video AR and VR services, well-being assessments, exercises and activities, guided Tai Chi services, and analytics dashboard services and web-based application services, along with phygital gym-based training, biometric monitoring, and hybrid physical-digital interactions, are collectively referred to as the “service(s)”.
This web page informs you of our policies regarding the collection, use, storage and disclosure of personal information when you use our service. We use your data to provide and improve the service. We will not use or share your wellness data with anyone except as described in this Privacy Policy. We align our wellness data protection practices to the key principles prescribed by DPDP, GDPR, HIPAA, CCPA, and other Data Protection Laws. We will be making use of the data generated by the user in the productivity modules to generate valuable insights for the user and the organisation they work for.
This Policy applies to all visitors, data subjects, and others who access the Service (“User(s)” or “You/r”). By using our Apps, phygital gym services, and other offerings, you agree to the collection and use of information in accordance with this privacy policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service.
We may amend this privacy notice from time to time to keep it up to date. We will notify you via in-app notifications, gym session reminders, and on our policy webpage when we make any changes to the Privacy Policy. Please regularly check these pages for the latest version of this notice.
Initial Effective Date: June 30, 2022 (IST)
Latest Revised Date: December 31, 2025 (IST)
Version: 1.2
If in a crisis or emergency, please call the relevant emergency number in your country.
The Services are not to be used by anybody under 18 years of age.
Limit sharing your personal and sensitive data when using the Services. We only require the minimal data required to provide our services. Read this privacy policy to understand how we process your data.
The Mind-n Services provide a workforce productivity and wellness upskilling solution. It is assisted tech and includes text-based, audio-video based, gaming, VR/AR guided training services, as well as phygital gym experiences combining physical exercises, biometric tracking, and digital feedback. It will apply mental wellness principles and evidence-based coaching and mentoring models to help you improve your resilience, behavioural health, and psychological safety by helping you work towards your mental well-being goals. It will also help individuals and organizations improve their productivity by recommending and assisting usage of specific productivity tools and techniques. The underlying principle of the Mind-n Services is that you have the knowledge and capacity to make desired changes in your life and your career.
Mind-n Services do not intend to nor replace face-to-face psychotherapy. They are meant to empower and support you, not to treat any illness or a health condition.
The intended use for providing evidence-based tools and techniques is to manage your mental wellness and improve your productivity in a self-help and self-monitoring context.
The Services are not intended to provide a diagnosis, prognosis, treatment, or cure of a condition or disease.
The Services will not offer medical or clinical advice and only suggest that you seek medical help.
Your data is stored in databases maintained by us and third parties located in countries other than your country of residence. Some of them may have data protection laws that may be less stringent than those in your country.
The Services and their offerings are primarily in the English language.
Witmer Health Technologies is a private limited company having its registered offices in India (Witmer Health Technologies Pvt. Ltd.). mind-n/mind-n gym is a product of Witmer Health Technologies. When we decide the purposes of our services and personal data processing, mind-n will be the Controller. For all services and data processing done at the direction of and on behalf of a Controller or a Processor, mind-n would either be a Processor or a Sub-Processor.
The mind-n Services cannot and will not offer medical or clinical advice.
Upon your use of the Platform, we collect the following personal data:
Name, Date Of birth, contact number, personal email id, alternative email id and corporate email id. The name and contact number are encrypted. For mind-n Gym users, we may also collect phygital data such as gym visit logs, biometric readings (e.g., heart rate from wearables), and session participation details.
We only use your personal data for the purposes for which we collect it and in order to provide enhanced services to you with better experience. We will use it for another reason, only if compatible with the original purpose. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. We may process your personal data without your knowledge and consent, where it . We take express consent from you for such usage of your data/personal information.
| Personal Data / Data Types | Source | Processing Purpose | Lawful Basis |
|---|---|---|---|
| Android or Apple identifier (app-device identifier) | Collected from your device | To recognise you as a new or existing user. To create a random user identifier for all transmissions. Perform one-way hash before sharing data for analytic purposes. To associate users to their provided data to provide uninterrupted App and services. To migrate your data to a new device. To process subscription-related requests. To administer your account. To process for addressing your data rights. To comply with applicable law or regulation. | To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Access or referral code | Provided by the user | To send deep links to directly access the App. To register you as a business user. To authorise access to business-agreed services. To provide customised App and services for referred and business users. To aggregate data at business or cohort or user level for analytics purposes. To administer your account. To process your data rights. | To perform our contract with you and with your business. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Name, DOB, Personal email id, alternative email id, corporate email id | Provided by the user | To personalise content on the App and services. To administer your account. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Device data (Operating system, OS version, device make and model, time-zone) | Collected from your device | To detect and prevent fraudulent use of or abuse of the service. To resolve issues. To improve App experience and use. To provide service-related information. To remind users of upcoming sessions and events. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| User input data (free text messages,questionnaires/assessment and scores, wellness data, voluntary data) (Questionnaires are a proven way to track progress of your mental well-being and productivity. You have the option to not respond to these assessments based on your choice) (Wellness data includes voluntarily provided special category health data. You have the option to not share any sensitive physical or mental health-related data.) |
Voluntarily provided by the user. | To apply our AI algorithms to wellness data to derive new data to indicate wellness state. To apply our AI algorithms to productivity activity data and to derive new insights to indicate productivity state. To detect context and ensure continuity in wellness coaching and mentoring. To detect medical or emergency terms to ensure safe conversations. To provide the right tool, technique, and content. To provide and process the wellness programs and send program use reports back to your business. To improve product and service quality and customer experience. To anonymise reports. To anonymise research and analytics data. To share app use reports back to your business. |
To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Additional Condition for any Special Category data: Reasons of substantial public interest. For safeguarding of individuals at risk. |
| Inadvertent submitted personal identifiers (names, location, contacts, email identifiers) | Voluntarily provided by the user | To take reasonable steps to detect and anonymise personal data. | To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Event Data (text button events, app screen events, tool events) | Events created during use of App | To share anonymised event data with 3rd party providers for analytics purposes. To obscure the event data to not reveal sensitive information. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Communication Information (name, email identifier, email messages, subscription receipts, feedback messages) | Voluntarily provided by the user | To respond to your inquiries, requests and feedback. To troubleshoot your issues. To provide and improve customer support services. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Other personal information (age-range) | Voluntarily provided by the user | To provide age-appropriate content, tools and techniques. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) |
| Network Data (Internet protocol address) | Collected from user device by Mind-n’s Content Delivery Networks (CDN) | To store in the CDN database and network logs. To enable access to all images, media, and tools provided within the App during use. To enable secured access to both the app and website. | To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) (IP address is not linked to the app user identifier and not stored in the App database) |
To provide you with our services, we use third-party service providers to help store and process your data. We assess the service provider’s security and privacy practices. We strictly require that they comply with confidentiality and non-disclosure obligations and applicable laws and regulations including relevant Data Protection Laws. We also require that they access your data only to the extent necessary to perform tasks on our behalf. We use the following third-party service providers.
To provide the service, we collect, transfer, and store your data in secure servers provided by our authorised cloud service providers. You can find more on their security practices in the security policy. We maintain a Data Processing Agreement (DPA) with Standard Contractual Clauses (SCCs) and Business Associate Agreement with our cloud service providers.
We use Mind-n authorised third-party service providers to provide our services. List of our service providers include:
| Service Providers | Purpose |
|---|---|
| Cloudflare | We use Cloudflare for its CDN and DDoS protection. Cloudflare helps us to efficiently secure and provide our Services for you. Cloudflare has access to your IP address to provide the services. Mind-n does not store or process your IP address beyond the CDN. Hence your conversations remain secure and private. Cloudflare may process your browser and operating system related information for logging and abuse prevention purposes. You can read Cloudflare’s terms of service, privacy policy and GDPR Compliance to know more about how they handle your data. We have a signed DPA with SCCs with Cloudflare. |
| Wasabi | Wasabi works with our applications running on AWS and offers direct, high-speed connectivity which helps us avoid internet latency, traffic bottlenecks and security risks and help our users by providing fast and predictable performance. More information around this can be read here https://docs.wasabi.com/docs/pdfs-of-documents |
| AWS | AWS is a Cloud Computing platform, which helps us build our applications over the cloud. It offers various services like a combination of infrastructure and software services, along with computing power, scalability, reliability, and secure database storage. You can read up here https://aws.amazon.com/compliance/data-privacy-faq/ |
| Freshdesk | Freshdesk helps us get everything we need to quickly resolve customer issues and also allows us to engage with customers in real-time. You can read up here https://support.freshdesk.com/en/support/solutions/articles/50000000206-freshworks-privacy-update |
You may need an access code or link provided by us or your organisation to use the mind-n/mind-n gym Services. Your organisation may also get access to service usage data for their analytic and research purposes based on the consent given by you to your institution and to us. We may collect your country, division, and in some cases your city information to provide aggregated analytics. We do not share your messages with your organisation. Any inadvertent identifiers get removed prior to the aggregated analysis.
If the Services are integrated with your organisation’s IT systems (into the future), your organisation may additionally share your assessment scores with us, and likewise, we may share aggregated user data with them. Such assessment scores may be processed by us for providing services to your organisation. Your assessment responses will never be processed for diagnostic purposes.
We process your data for purposes such as enhanced services, targeted experience of using the Services, direct marketing purposes, etc.. We will always weigh your rights and freedom before we process any such requests for purposes of legitimate interest.
Mind-n shares your conversation data only with your explicit consent provided either to us or your organisation.
In the future, if we are involved in any merger, acquisition, sale of assets, business reorganisation, or bankruptcy, we may transfer or otherwise share some or all of our assets which may include your data. We will take reasonable steps to inform you about this using the following modes.
Public notice on our website and/or Inform your organisation and/or where applicable, send in-app notification and/or Changes to this privacy policy and in-app notice.
You can always email us at help@mindn.ai to exercise your data protection rights.
However, in such an event of sale or transfer, we shall reasonably ensure that your data with us is stored and used by the transferee in a manner that is consistent with this Privacy Policy and applicable Data Protection Laws. Any such third party to whom we transfer shall have the right to continue to use the data that you provide us immediately prior to such transfer or sale. On completion of the sale or transfer, the Privacy Policy of the third party shall apply with respect to your data.
For your privacy and security, you are advised to set your own App PIN to protect unauthorised access to your conversation messages. Your mobile device screen password is your PIN. To extend your device password, use the “Set Lock” feature under the App settings. You can also remove your PIN using the “Remove Lock” option under settings. The PIN that you use is personal to you, and you are responsible for maintaining the confidentiality and security of your PIN. Please keep your PIN safe and do not share it with anyone. The PIN you set remains in your device and is not collected, transferred, and stored in our servers. For Mind-n Gym, similar security measures apply to any digital access codes for gym equipment or sessions.
We take your consent to perform the following processing.
| Data | Purpose | Lawful Basis |
|---|---|---|
| Website Cookies, web-based AI Coach widget, or web beacon Data (browser type, browser language, operating system, language settings, web page views and the link clicks) | To understand website visits and engagement analytics. Use of AWS operational cookies. To share anonymised event data with third-party providers for analytics purposes. | Your consent to our cookie policy. (We do not sell your provided data to any third party) |
| Mind-n Website Contact Form (Name, Email ID, inadvertent identifiers in messages) | To respond and provide support for your inquiries. | Your consent during form submission |
| App usage data and reports ( questionnaires data, wellness data) | To process and share app usage and analytics data with your institution or research partner. | Your consent with us and/or with your organisation (Agreements are signed with respective organisations) |
| In-app push notifications | To notify you of reminders you have set. To remind you about upcoming sessions and events. | Opt-in and Opt-out in App settings or mobile device settings. |
| Promotion event data (email ID) | To process the survey. To send programme-related information. To enrol and onboard you to the programme. To correspond on programme matters. | Your consent given within the Mind-n App and forms. |
There may be occasions where you wish to contact us to seek support or make enquiries. Your communication data is securely stored with access to only authorized users. We will only use your data to investigate the issue or request asked. Your email will be retained within our system for a maximum of 10 years since last correspondence. We will not spam you or contact you for any direct marketing. We will not share or sell your personal data with any third party.
Your issues or complaints or requests about the Services are taken very seriously. You will need to send an email request to help@mindn.ai. We will respond to your complaints within three business days. Some of your complaints may take longer to resolve. We will continuously provide you with an update until your complaints are satisfactorily resolved.
We do not promote third party offers as a part of the Services experience. Your survey submission will never be linked to your Mind-n account. You can opt out at any time from the programme by sending us an email to help@mindn.ai. We will respond to your request within three business days. Your submissions will never be shared with a third party.
The Mind-n Services may carry a link to the organisation’s EAP for payment.
We do not collect, retain, or store your personal and card information. Your card processing is handled by third-party payment agencies. We do not collect any personal data from the play stores post-purchase or from any of our third-party payment gateway providers. Please read their terms and privacy policy before making a payment. The payment confirmation and subscription details are received and processed by us. This is to support you with your subscription-based requests.
During use of our voice chatbot, you may get an opportunity to talk with the chatbot apart from typing. For Android phone users, you will need to give permission to activate your device microphone to speak to the chatbot. On microphone activation, the Google Android provided Speech Software Development Kit (SDK)/API within your device gets initiated. The Android SDK/API converts your speech to text and displays the text in your chat. The converted text data is securely transferred to our servers. We do not access nor collect nor store your voice data on our servers. Please do not share your personal or sensitive information at any time during use of this service. The lawful basis for processing of your transcribed text is governed by this agreement. The processing of your voice for the purpose of converting to text is performed by Android SDK/API which is governed by Google’s Terms and Condition and Privacy Policy. You can read Google’s Privacy Policy https://policies.google.com/privacy?hl=en-US[1] . We do not access, receive, or collect any identifiers and information that are collected by Google. If you accidentally submitted any personal information, please write to us for any rectification at the contact provided here. The same Android SDK/API plays back the chatbot’s response to you.
We use minimal and only the required data for research purposes including aggregated data for any publications. This data is completely anonymised using one-way hash functions prior to use. This helps us to improve our product and services and contribute to user-centred mental wellbeing best practices globally.
You can always write to us at help@mindn.ai to restrict processing and opt-out of your data for research purposes.
Your use of third-party weblinks
The Services may carry links to third-party websites and resources. When you click on those links, you may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. We encourage you to read the Privacy Policy and Terms of Use of every external link you visit.
We do not combine and process your personal data with any other third-party available data. Your data, messages, or usage are not used for direct marketing, nor are they sold to advertisers. We will always take your consent before using your name for social proof purposes.
We will update this Privacy Policy and inform you if we perform any additional processing.
The security of your data is important to us. We have implemented adequate technical and organisational safeguards to protect your data. Some of the steps undertaken include:
Security by Design
We use TLS and SSL encryption during transfer and AES-256 protocol at rest.
Random identifiers are used for all data transactions between Mind-n and our servers.
Our systems are secured with role-based access, strong passwords, and two-step verification.
We enable endpoint security in all staff systems, including gym facility devices.
We review and maintain data processing agreements with our service providers.
We have a strict hiring and background verification process in place.
Regular awareness and training are provided to our staff.
Annual third-party compliance audits and data protection certifications.
We perform regular penetration tests of our Apps, Infrastructure, and gym digital systems.
We conduct regular checks to ensure compliance with our policies. [3]
No method of electronic transmission or method of data storage is perfect or impenetrable. While we try our best to implement controls to protect your personal data, we cannot guarantee its absolute security. To ensure your data is secure, we require your cooperation as well. Please do not copy and share your engagement data with unknown people. For Mind-n Gym, ensure physical devices (e.g., wearables) are secured against unauthorized access.
Any identifiers shared in your conversation get hashed within 24 hours within our system.
We may retain your data even after your subscription ends if it is reasonably necessary. This could be in the following situations:
Where not specified, we retain your data for a maximum of 10 years from the end of subscription and as per our information retention policies.
You can also, at any point of time, clear all your conversation data by asking to “reset my data” by sending an email to help@mindn.ai.
You have certain rights under the Data Protection Laws in relation to your personal data. To exercise any of your rights, you will need to send an email request to help@mindn.ai. Please note that we may need to verify you before responding to any requests. After verifying you and examining your request, we will respond to you on the action taken within one calendar month from verification. We may at times be unable to address your request, if we are unable to correctly identify you.
Your individual rights requests may be limited, where:
denial of access is required or authorised by law;
grant of access would have a negative impact on other’s privacy;
they are required to protect our rights and properties;
the request is unjustified or excessive.
If your personal data is inaccurate or incomplete, you can write to us to correct or complete it. If we share your personal data with third parties, we will inform them about the correction where possible.
Right to object
When you use the service, you have the option to reset your data by using the “Reset my data” feature in the App settings. Reset my data deletes all your submitted data including your identifiers, past conversations, reminders, assessment responses, gym session data, and enabled settings. Post reset, you will not be able to recover your past data and you will be considered as a new user of the Services. Hence, this feature is to be used at your discretion. If you are a paid subscriber, your transactional data and messages will be deleted on reset. However, your active subscription, purchased through third parties like Google Play, iTunes, etc., will continue to exist post reset of data.
You can also write to us to delete or remove your personal data, such as when you withdraw your consent.
In the event of a breach of your personal data, we will notify you within 72 hours or as required by Data Protection Laws.
If you have any concerns or grievances about this Privacy Policy, you will need to send an email request from your email ID to help@mindn.ai with Attn. to our Head-Compliance and designated Data Protection Officer (DPO). We will respond to you within 48 hours and help resolve your concerns or complaints. If you are not satisfied with our resolution, you have the right to complain to a Data Protection supervisory authority in your country or state of residence. We will fully cooperate with the supervisory authority.
There are certain disclosures required by the California Consumer Privacy Act (or “CCPA”). California residents can request a list of third parties with whom we share personal data for direct marketing purposes. Subject to certain exceptions, you can write to us to know about the personal information you shared. You can request to delete your personal information, to opt out of any “sales”, and to not be discriminated against. We will respond to your request within 45 calendar days of verification. We may at times be unable to address your request, if we are unable to correctly identify you. We may be unable to address your request due to any of the limitations and exceptions provided within CCPA.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not respond to DNT signals transmitted by web browsers.
How to contact for additional questions, comments or concerns?
For any product, services, or issues, please contact us at help@mindn.ai with your questions.
Our mail address for all communication is:
India Office:
Witmer Health Technologies Private Limited
No. B4, Green Court Apts, Srinidhi Layout, Vidyaranyapura
Bengaluru, 560038
Karnataka, India
The US Federal Trade Commission (FTC) publishes information for users on how to secure your personal data and devices. These can be found at the following public links.
How To Protect Your Privacy on Apps | FTC Consumer Information
Online Security | FTC Consumer Information
FTC – How to Keep Your Personal Information Secure
Mind-n strongly believes in security and safety of data in your mobile device. As a responsible Service provider, we like to share important device-based security information for your attention. These have been sourced from US FTC best practices and guidelines. Always refer back to the US FTC links provided above for more details and future security updates.
Always lock your mobile screen by setting a password. Use strong passwords and keep passwords private. Never leave your device unattended.
Always extend your mobile screen password to set an App PIN to keep your conversations with the App private.
Always keep your mobile operating system up to date.
Enable remote access of your devices to enable you to locate and control your devices remotely in the event your device gets stolen.
Install anti-virus software to protect against virus attacks and infections
Avoid phishing emails. Do not open files, click on links, or download programs from an unknown source.
Be wise about using Wi-Fi. Before you send personal and sensitive data over your laptop or mobile device on a public wireless network in a coffee shop, library, airport, hotel, or other public place, see if your data will be protected.
You are also responsible for helping to protect the security of your personal data. You are responsible for maintaining the security of any personal computing device or gym wearable on which you utilise the Services.
We may modify our Privacy Policy from time to time for various reasons including to improve our privacy practices, to ensure our users right to be informed, to reflect changes to our service, and to comply with relevant laws. If and when this policy is changed, we will post the new notice on our Website and the App and notify you through an in-app notification, gym communication, or as otherwise required by relevant law. It is your responsibility to check our Website and our App periodically for updates or changes to the policy. We encourage you to review changes carefully. If the changes to the Privacy Policy include changes to the collection, storing, or processing your personal information in a way that infringe into your privacy, we will notify you clearly about the same where required by the applicable laws and regulations. If you agree to the changes, then please continue to use our service. If you, however, do not agree to any of the changes and you no longer wish to use our service, you may choose to unsubscribe or uninstall our App. Continuing to use our Services after a notice of change has been communicated to you or published constitutes your acceptance of changes and consent to the modified Privacy Policy.
We have taken every effort to ensure that this Privacy Policy adheres with the applicable Data Protection Laws. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any data other than the data collected by Witmer Health Technologies while providing the services.
Anonymisation is the process of removing personal identifiers from data sets so that the person can no longer be identified.
Cookie is a small amount of data stored on your device (computer or mobile device).
Data or Information under this Privacy Policy means both personal and non-personal data or information.
Data Controller or Controller means the resource, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data Processor or Processor or Service Providers means the resource, public authority, agency, or other body which processes personal data on behalf of the data controller.
Data Protection Laws here means in accordance with the Indian Information Technology Act and Reasonable security practices and procedures and sensitive personal data or data rules, including but not limited to requirements of EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018 (UK GDPR) and applicable Legal and Statutory requirements.
Data Subject (or User/You) means any living individual who is using our service and is the subject of Personal Data
Encryption is the process of transforming data into unreadable text so that it is only legible to those possessing an encryption key.
Personal Data or Personal Information means data about a living person who can be identified from the data and/or other information either in our possession or likely to come into our possession.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific user without the use of additional information.
Non-Personal Data or Non-Personal Information means any data that is made anonymous and does not reveal user specific identity.
Sub-Processor/s is a data processor who is sub-contracted to do some of the personal data processing.
Special Category Data includes personal data revealing or concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sex-life, or a person’s sexual orientation.