Ginger

Ginger

Ginger.io, Inc.
Bluetooth

Data da avaliação: 25 de Abril de 2023

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A Mozilla investigou por 8 horas
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Opinião da Mozilla

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Votos das pessoas: Razoavelmente assustador

Ginger bills itself as an emotional support app. Offered mostly through employers, organizations, and health plans, this app lets users access text chat with coaches, video therapy and psychiatry sessions, and a library of self-care resources. So, whether you're feeling anxious about that big work meeting or the scary state of things in the world, depression, anxiety, or more, Ginger says it can offer it to you "all from the privacy of your smartphone." Which, not sure that makes us feel so good about things as we all know our smartphones are not all that private. Ginger does have some HIPAA compliance with the data they collect...which is good. But know that not all the personal information they collect on your is covered by HIPAA. And they do say they can disclose some of your data to the provider (ie. employer) or health plan you sign up through, so just be aware of that. Is Ginger bad for privacy? Well, it's hard to tell exactly, but you could potentially be sharing a lot of personal information is those chat-based coaching sessions that might not be covered by HIPAA, so do be careful.

O que pode acontecer se algo der errado?

At first glance, the Ginger app seems alright privacy-wise. According to their many privacy policies, they don’t sell your data, they don't share your data widely with third parties for advertising purposes, they practice good cybersecurity hygiene, and they say they’ll delete your personal information upon request. All this looks pretty good to us. Good work Ginger.

We do want to call out one thing about Ginger -- and many other mental health apps -- that raises a concern for us. And it's those text-based chats you have with "coaches." Many people expect their personal conversations through online therapy sites to be private, or to be covered by stricter privacy laws protecting health care data, like HIPAA in the United States. But conversations with unlicensed coaches are often not required to be covered by these stricter privacy laws. What does that mean? Pretty much it means, beware what you share in text-based chat communications with online mental health apps unless you have been 100% guaranteed they are covered by strict health privacy laws like HIPAA. Otherwise, they could be used for things like improving the app, advertising or marketing, or turned in to "anonymized" data to be used for many purposes.

Yes, we have overarching concerns about online chat transcripts with all mental health apps. But what is actually going on with Ginger? Much of what happens inside the Ginger app is text-based coaching that’s available 24/7. A promotional video describes those chats as providing “guidance through tough emotional challenges.” Another part of the website suggests your coach can help you through some pretty tough stuff, like if you’re struggling with depression.

But what you should know, before your thumbs set that tiny digital keypad ablaze, is that all of those DMs back and forth become “Care” or “Coaching Data” that’s stored by Ginger. And though the services are marketed together with Headspace as “Mental healthcare,” coaching isn’t therapy. That’s because the coaches aren’t required to be licensed therapists, but it also means that those conversations aren’t necessarily covered by stricter health privacy laws.

For example, according to Ginger's FAQ, multiple coaches can be assigned to help you at different times, depending on availability and other factors, forming a “care team.” And all those coaches can talk to each other about what you’ve been talking to them about, “so they’ll know what you’ve been working on with another coach and where you left off.”

Ginger also mentions that “[their] unique platform analyzes chat transcripts and other data points to help coaches provide effective support for each member in their care.” And in their International Coaching Privacy Statement they say they can use that Coaching Data to “evaluate the quality and progress of our coaching program, and optimize [their] coaching services.”

So between the paper trail, the inter-coach-conferring, the technological analysis, and the somewhat ambiguous description of evaluating how you’re progressing and optimizing the services, those transcripts are being shared and used it lots of ways... which means they aren't what you might expect to call "private." Plus, it’s possible that they're part of the personal information that Ginger is allowed to share in an anonymized and aggregate form. In the US version of the Privacy Policy, they mention that that could include your (de-identified) health information too.

Given that Ginger is offered through employers, and that access to licensed therapists is available, but at a higher cost and sometimes only if your employer sponsors that, it seems most Ginger users will rely on these text-based "emotional coach" conversations. So remember, those conversations are likely not nearly as private as the video-based conversations you can sometime get through Ginger with a license therapist (those cost a lot more and sometimes require your employer to sponsor that feature). As one Ginger user pointed out, "When a patient has no way of knowing who at a healthcare practice knows the details of their mental health concerns, it means there are an undisclosed collection of people wandering around the world with knowledge of and access to that patient’s most private struggles, habits, and thoughts. This also means confidentiality — and any subsequent breach thereof — is nearly impossible to track."

What's the worst that could happen with Ginger? Well, the idea that your "emotional coaching" chat transcripts exist is enough to give us the privacy heebie jeebies. Knowing they could be shared around internally at Ginger and then having to trust an employer-sponsored app to keep everything private, well, we're glad Ginger has a decent privacy policy. We're still wary of such a model for mental health care and suggest you think this through before signing up and sharing that you really hate your boss with that emotional coach you're chatting with at 2am.

Dicas para se proteger

  • Do not give access to your photos and video or camera
  • Do not log in using third-party accounts
  • Do not connect to any third party via the app, or at least make sure that a third party employs decent privacy practices
  • Do not give consent for sharing of personal data for marketing and advertisement.
  • Choose a strong password! You may use a password control tool like 1Password, KeePass etc
  • Do not use social media plug-ins.
  • Use your device privacy controls to limit access to your personal information via app (do not give access to your camera, microphone, images, location unless neccessary)
  • Keep your app regularly updated
  • Limit ad tracking via your device (e.g. on iPhone go to Privacy -> Advertising -> Limit ad tracking) and biggest ad networks (for Google, go to Google account and turn off ad personalization)
  • Request your data be deleted once you stop using the app. Simply deleting an app from your device usually does not erase your personal data.
  • When starting a sign-up, do not agree to tracking of your data if possible.
  • mobile

Pode me bisbilhotar? informações

Câmera

Dispositivo: Não aplicável

Aplicativo: Sim

Microfone

Dispositivo: Não aplicável

Aplicativo: Sim

Rastreia localização

Dispositivo: Não aplicável

Aplicativo: Não

O que pode ser usado para se inscrever?

For employer-sponsored benefits, a unique access code is required to sign up for the account, which is sent to members directly – or, a combination of first name, last name, date of birth, ZIP code, and work email address.

Que dados a empresa coleta?

Como a empresa usa esses dados?

"We will not sell or rent your personal information to any other company or organization."

The company representative shared with us that "Ginger does not rent or sell member Personal Information to third parties for marketing or other purposes. Ginger uses Personal Information only to provide care, personalize care, ensure the quality of care, process payments, and improve the delivery of our services." and "As a healthcare provider and covered entity, Ginger does not use identifiable user data for marketing purposes and does not advertise to users without an individual’s authorization and opt-in consent."

"Your Protected Health Information may be used and disclosed for treatment, payment, healthcare operations and other purposes permitted or required by law. Ginger Medical may use and disclose your Protected Health Information for the following purposes: "

Como você pode controlar seus dados?

"We store your Account Data and Personal Information for as long as we need it to provide you our services, to serve the purpose(s) for which your personal information was processed, or as necessary to comply with our contractual and legal obligations, resolve disputes, or enforce our agreements to the extent permitted by law.

If you would like your Account Data or other Personal Information permanently removed from our database, please contact us at [email protected]. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law."

Qual é o histórico conhecido da empresa na proteção de dados dos usuários?

Médio

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

Informações de privacidade infantil

"Ginger does not knowingly collect or maintain personally identifiable information from persons under 13 years of age. Individuals under the age of 18 must receive consent from their parent or guardian in order to access Ginger Services."

Este produto pode ser usado offline?

Não

Informações de privacidade fáceis de entender?

Não

Links para informações de privacidade

Este produto atende aos nossos padrões mínimos de segurança? informações

Sim

Criptografia

Sim

Senha forte

Sim

Atualizações de segurança

Sim

Gerencia vulnerabilidades

Sim

Ginger has an active bug bounty program in place through HackerOne. Vulnerabilities can be reported through HackerOne. Researchers can also submit the security vulnerabilities directly to [email protected]

Política de privacidade

Sim

https://www.ginger.com/privacy-policy

O produto usa inteligência artificial? informações

Sim

AI assists users by directing them to the right kinds of content that are relevant to their issues as well as by matching them to the caregivers most likely to give them the best outcome for their concerns and interests.

Esta inteligência artificial não é confiável?

Não foi possível determinar

Que tipo de decisões a inteligência artificial faz sobre você ou por você?

A empresa é transparente sobre como funciona a inteligência artificial?

Sim

One example is a recent publication in the Journal of Medical Internet Research (JMIR) – “Content Recommendation Systems in Web-Based Mental Health Care: Real-world Application and Formative Evaluation."

O usuário tem controle sobre os recursos da inteligência artificial?

Não

According to the company representative "Members can ignore content recommendations and have self-guided access to the full content library."
*Privacidade não incluída

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