Modern Health

Warning: *privacy not included with this product

Modern Health

Review date: May 2, 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 number of privacy concerns. We hope to see improvements. We will update this post when we do.

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. For example, they recently changed their privacy policy to say they "utilize tracking technologies on our marketing website" and they “do not engage in any third party tracking on [their] platform or target ads toward any of [their] platform members.” We worry they can use information learned about users of their service for advertising purposes, and if that's not true, then we hope they clarify their privacy policy to alleviate our concerns. For example, open questions we still have include: what's a "marketing website"? Do they engage with third party tracking off-their platform

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. The company also says they can collect information about you from third parties. And they may combine or enhance information they get from you when you use Modern Health's services with information they get from third parties. So far, that's a lot of information gathered on you.

They also 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 and with whom they are sharing your data. Finally, Modern Health doesn’t specifically state in their privacy policy that they don’t sell user data, which is something we like to see stated clearly. That's not a good thing to be unclear on. The privacy policy only confirms that they have not sold California consumers’ data, but it doesn't guarantee anything about the future or people in other locations.

So yes, even the mental health app Mozilla offers employees raises a host of 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.

What's the worst that could happen? Well, Modern Health shares data with employers. Modern Health has assured Mozilla that it only shares high-level, aggregated data with employers and does not share any user level data. We hope they will commit to that publicly in their privacy policy, because it currently says “[w]e only share information with your employer that is permitted by law.” We would like to see more public details here so we (or any consumer reading this) doesn't have to make assumptions on what is permitted by law

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.

Modern Health may engage third party service providers who utilize tracking technologies on their marketing website to serve you advertisements that you may be interested in. Some of these advertisements may be personalized to you, meaning that the advertisements are intended to be relevant to you based on what Modern Health, or the third party service providers, know about you.

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.

If you are accessing the service through an employer (such as single sign-on), they may collect information about your login activity, including whether and when you access Modern Health Services.

In the last twelve (12) months, Modern Health does not have knowledge that they sold any Personal Information of California Consumers, nor actual knowledge that they sold the Personal Information of California Consumers under the age of sixteen (16) years old.

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).

Modern Health states that it 'may refuse or deny a request [to access or delete your data] in accordance with applicable privacy laws . . . depending on the circumstances and where you are located. The privacy notice says that under certain circumstances, local privacy laws may give you rights with respect to your Personal Information.

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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