Privacy Policy

1. Who we are

MindCare Zambia ("MindCare", "we", "us") is a digital mental health and wellbeing service operated by Senditoo Zambia Limited, Kabulonga, Lusaka, Zambia. We decide how and why your personal data is used, which makes us the data controller under the Data Protection Act No. 3 of 2021 ("the Act").

2. What we collect

We only collect what we need to give you support, keep you safe and run the service:

• Account details: your email address, name and sign-in method (email and password, or Google).
• Profile details you choose to give: date of birth, town or area, language, preferences and emergency or trusted contacts.
• Wellbeing information you record: mood check-ins, journal entries, voice notes, wellness and wellbeing check answers, healing-journey progress and conversations with Tula, our wellness companion.
• Care information: your sessions, messages with your therapist, and the session notes and care plans your therapist writes.
• Payment information: amounts, the mobile money number you pay from and payment references from our payment provider. We do not store card numbers.
• Funding information: if an employer, NGO or insurer pays for your care, the access code or programme you used and the number of sessions funded.
• MindCare Teens and family links: for young people, links to a parent or guardian that the young person agrees to, and any safety reports or requests for help.
• Technical information: device and browser type, sign-in times and security logs.

3. Why we use it and our legal basis

Information about your mental health is sensitive personal data under the Act. We process it only with your explicit consent, which you give when you create your account and which you can withdraw at any time (see section 9), or where the law allows it without consent, for example to protect someone's life.

• To provide the service: booking and running sessions, reminders, messages, receipts, refunds and your wellbeing tools (your consent and our agreement with you).
• To keep people safe: when something you write or a check you complete suggests a risk of serious harm, our safeguarding staff are alerted so they can reach out (to protect vital interests, and our safeguarding duties).
• To meet legal, financial and professional record-keeping duties (legal obligation).
• To secure and improve MindCare, for example preventing fraud and fixing faults (legitimate interests, never overriding your rights).

Optional AI features, such as Tula, AI insights on your mood and journal, and voice-note analysis, only use your words after you switch on "External AI processing" in your privacy settings. Voice transcription through your browser needs its own separate permission. You can also choose whether your anonymised data is included in national statistics.

4. Who can see your information

• Your therapist sees your sessions, your messages with them and the notes and care plans they write. A therapist only sees clients who have booked with them.
• MindCare safeguarding staff see a safety alert and what is needed to respond to it, only when a risk signal is raised.
• A small number of MindCare administrators can see booking, payment and account records to run the service. Every administrative action is logged.
• Employers, NGOs and other sponsors never see your journal, Tula conversations, messages or clinical notes. They see programme figures that are combined and de-identified, and groups smaller than our minimum size are hidden so no one can be singled out. If you switch on "Share wellbeing band with sponsor" in your privacy settings, they can also see your overall wellbeing band, never your answers, notes or conversations.
• Parents and guardians of young people only see what the young person has agreed to share, unless a safeguarding duty requires more.

We do not sell your personal data and we do not show advertising.

5. Service providers we use

We use trusted providers to run MindCare. They may only use your data to provide their service to us:

• Base44: application hosting, database, sign-in and email delivery.
• Lipila: mobile money payments and refunds.
• Daily.co: video and audio sessions. Sessions are not recorded.
• An AI language model provider, reached through Base44: Tula, AI insights and voice-note analysis, only if you switch AI processing on.
• Your browser vendor (for example Google for Chrome): voice transcription, only if you switch on browser speech recognition.
• Google: sign-in, only if you choose "Continue with Google".

6. Where your data is stored

Our providers run on cloud servers that may be located outside Zambia, including in the United States. The Act requires sensitive personal data, including health data, to be processed and stored in Zambia. We are moving sensitive personal data to storage in Zambia and will update this policy when that is complete. Until then, transfers are protected by our providers' contractual commitments and by encryption and access controls.

7. When we may share without your consent

We will only share information without your agreement when we have to: if someone is at serious risk of harm, to protect a child, or when the law, a court or a regulator requires it. We share only what is necessary and record why.

8. How long we keep it

We keep your information while your account is open. When you delete your account (Profile → Delete account), your profile, mood, journal, voice notes, Tula conversations, trusted contacts and notifications are deleted straight away.

Some records must be kept even after you leave, with your name removed: past sessions and payments (financial records), messages and notes held by your therapist (clinical records) and safeguarding records. We keep these only for as long as the law and professional rules require.

9. Your rights

Under the Act you have the right to:

• Get a copy of your data. You can download it yourself at any time from Profile → Download my data.
• Have inaccurate data corrected.
• Have your data deleted, from Profile → Delete account, subject to the records we must keep (section 8).
• Withdraw your consent, including switching AI processing, browser speech recognition or sponsor sharing off in your privacy settings. Withdrawing consent does not affect what was done before.
• Object to or restrict some uses of your data.
• Complain to the Office of the Data Protection Commissioner of Zambia if you are unhappy with how we handle your data.

10. Young people

MindCare Teens is for young people aged 13 to 17. MindCare is not for children under 13. We encourage young people to involve a trusted adult, and parent or guardian access is based on the young person's agreement, except where we must act to keep a child safe.

11. Security

Data is encrypted in transit. Access is limited by role, so each person only sees what their job needs, and sensitive actions are logged. No system is completely secure, so please keep your password private and tell us straight away if you think your account has been misused.

12. Changes and contact

We will tell you in the app before any material change to this policy takes effect.

To ask about your data or exercise your rights, write to: The Data Protection Officer, MindCare Zambia, Senditoo Zambia Limited, Kabulonga, Lusaka, Zambia.