Modern Health

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.