Modern Health

Warning: *privacy not included with this product

Modern Health

Review date: Aug. 1, 2022

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Mozilla says

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People voted: Not creepy

Mozilla recently decided to offer the mental health app Modern Health to employees as part of our wellbeing program. With the growing mental health crisis around the world, many companies are adding access to mental health apps to their wellbeing programs too. It can be challenging to find companies capable of meeting high privacy standards, and so we decided it was important we include a review of the mental health app we offer to share what it is like to navigate these privacy concerns.

First, a little about Modern Health. The app offers a full spectrum of mental health services, including 1:1 sessions with care professionals, guided meditations, group sessions, digital programs, well-being assessments and more. Offered through your employer, access to the app is free. One of the features Modern Health offers the over 250 companies that use their service is access to "aggregated and de-identified" data through an "Insights Hub". How does Modern Health look from a privacy perspective? Well, even the mental health app Mozilla uses raises a few privacy concerns for us. We hope to see improvements. We will update this post when we do.

Update: Modern Health updated their privacy policy on June 30, 2022. We've included a note on these updates below.

What could happen if something goes wrong?

Modern Health's privacy notice raised flags for us because they say they can collect a large amount of personal information and combine or enhance this information with more information they collect on you from third parties for things such as providing more personalized services. Modern Health says they can collect a fair amount of personal information, including name, mailing address, e-mail address, telephone number, date of birth, IP address, location information, social media information, video recordings and photographs, and information about your dependents.

And remember, they might also collect information about you from your employer. Their privacy policy reads, “…we may receive Personal Information about you from our customers (who may be your employer) to enable us to validate your eligibility to use the Service. This information may include your name, work email address, postal code, date of birth, gender, race/ethnicity, employee ID number or code (if applicable), employment start and end dates, department, title, job code (if applicable), office location, performance information, health claims data, or survey information about your work satisfaction and related topics.” So far, that's a lot of information gathered on you.

Modern Health did make a clarification in the update they made to their privacy policy on June 30, 2022 regarding how they do interest-based targeted advertising. Their privacy policy reads, “We do not target any advertisements toward individual consumers or members of our platform. We may engage third party service providers who utilize tracking technologies on our corporate website (www.modernhealth.com) to serve advertisements that may be of interest to potential employer-buyers of our Services. Some of these advertisements may be personalized, meaning that the advertisements are intended to be relevant to potential employer-buyers based on what we, or the third party service providers, know about them…” So, they do use personal information for targeted advertising, but they say they don't target “individual consumers or members.” All this is still a bit confusing. Hopefully this mean if you use Modern Health as a wellness service, nothing you do on the platform or website will be used to target you with ads anywhere else on the internet.

Finally, Modern Health does say they can share your personal information with a number of third parties, including business affiliates and your employer. It is unclear from their privacy policy who the business affiliates are.

So yes, even the mental health app Mozilla offers employees raises some privacy concerns for us. And overall, employer-provided access to mental health apps raises a number of privacy concerns employees should consider before using these apps. We recommend reaching out to your company's HR or wellness department to learn what access to data your company has for such apps and what policies they have in place to keep any data collected private, secure, and anonymous.

One final thing, one of the co-founders of Modern Health, who has since left the company, raised her own concerns and offered solutions about the problems she sees with mental health apps broadly and patient safety in this space.

Tips to protect yourself

  • Ensure you have a strong password
  • Do not allow third-party tools access to your medical data
  • Do not give permission to combine your data with other third-party data, or to use it for research
mobile Privacy warning Security A.I.

Can it snoop on me? information

Camera

Device: N/A

App: Yes

Microphone

Device: N/A

App: Yes

Tracks location

Device: N/A

App: Yes

What can be used to sign up?

What data does the company collect?

How does the company use this data?

Update: Modern Health updated their policy around May 1, 2022 to say they utilize tracking for advertising on their marketing website and not on their platform. This is a good step forward even if we still have questions about their collection and use of the data for targeted advertising purposes.

Update: Modern Health updated their privacy policy again June 30, 2022. In this update to their privacy policy they clarify that they “do not sell, disclose, and/or share your Personal Information to other businesses or third parties for monetary or valuable consideration.” Modern Health also clarified how they do targeted advertising.

Their privacy policy now reads, “We do not target any advertisements toward individual consumers or members of our platform. We may engage third party service providers who utilize tracking technologies on our corporate website (www.modernhealth.com) to serve advertisements that may be of interest to potential employer-buyers of our Services. Some of these advertisements may be personalized, meaning that the advertisements are intended to be relevant to potential employer-buyers based on what we, or the third party service providers, know about them, such as employment at or agency for a company that might be interested in offering Modern Health as a benefit to its employees.”

Finally, Modern Health clarified in their privacy policy data sharing with employers by saying, “We do not share any Personal Information with employers unless necessary to prevent imminent harm (e.g., crisis management) or as required by law. We only share anonymized and aggregated information with employers.”

“If you are accessing the service through an employer (such as single sign-on), your employer may collect information about your login activity, including whether and when you access Modern Health Services. Modern Health does not control the information collection practices of employers or other benefit providers, and you should consult their internal policies and procedures for more information about their information collection practices.”

Modern Health's privacy policy reads, “…we may receive Personal Information about you from our customers (who may be your employer) to enable us to validate your eligibility to use the Service. This information may include your name, work email address, postal code, date of birth, gender, race/ethnicity, employee ID number or code (if applicable), employment start and end dates, department, title, job code (if applicable), office location, performance information, health claims data, or survey information about your work satisfaction and related topics.”

Modern Health says they do some targeted interest-based advertising, “We do not target any advertisements toward individual consumers or members of our platform. We may engage third party service providers who utilize tracking technologies on our corporate website (www.modernhealth.com) to serve advertisements that may be of interest to potential employer-buyers of our Services. Some of these advertisements may be personalized, meaning that the advertisements are intended to be relevant to potential employer-buyers based on what we, or the third party service providers, know about them, such as employment at or agency for a company that might be interested in offering Modern Health as a benefit to its employees.”

When permitted by law, Modern Health may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties. “We may combine information that is obtained from your use of the Services with information obtained from such third parties in order to provide you with more personalized Services.”

How can you control your data?

Information that Modern Health collects will be retained in a personally identifiable form for as long as necessary for the purposes described in the Policy, after which it will be deleted or maintained in a non-personally identifiable form. Modern Health may retain information in order to comply with their legal obligations (such as tax, accounting or health privacy purposes).

Update to Modern Health's privacy policy on June 30, 2022.

Modern Health's privacy policy states, “…you may request access to or deletion of your Personal Information by contacting us. We will handle any request in accordance with applicable law. Note that privacy rights may not be absolute. We may refuse or deny a request in accordance with applicable privacy laws.” Unfortunately, this statement is not clear to us that they will grant all users requests for data deletion, regardless of where they live earning them a privacy ding from us.

What is the company’s known track record of protecting users’ data?

Average

No known privacy or security incidents discovered in the last 3 years.

Child Privacy Information

"Online components of our Services are not directed to children under the age of thirteen (13), and we do not knowingly collect Personal Information via online Services from children under the age of 13. Some Services can be provided to those under thirteen but this is handled outside of our online Services (e.g., by phone) and therefore electronic information for children under the age of 13 is not available. If you think that we have collected Personal Information via an online Service from a child under the age of 13, please contact us. The Service is not intended to be accessed by minors under the age of eighteen (18) except as authorized by their parents or legal guardian, and we do not knowingly collect any Personal Information directly from such minors and children without such authorization. If we discover that an individual under 18 has provided us with Personal Information, we will delete the Personal Information to the extent required by the Children’s Online Privacy Protection Act."

Can this product be used offline?

No

User-friendly privacy information?

No

Links to privacy information

Does this product meet our Minimum Security Standards? information

Yes

Encryption

Yes

Modern Health applies PGP encryption to verify that any data exchanged is encrypted between the sender and receiver

Strong password

Yes

Security updates

Yes

Manages vulnerabilities

Yes

Modern Health has a disclosure policy, security vulnerabilities can be reported to [email protected]

Privacy policy

Yes

Does the product use AI? information

Can’t Determine

Is this AI untrustworthy?

Can’t Determine

What kind of decisions does the AI make about you or for you?

Is the company transparent about how the AI works?

Can’t Determine

Does the user have control over the AI features?

Can’t Determine


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