Privacy Policy

Effective: September 2025

MoodEaser (“we,” “our,” or “us”) is firmly committed to safeguarding the privacy and confidentiality of all individuals who interact with our platform, including licensed Therapists and their clients. This Privacy Policy outlines the principles and practices governing the collection, use, disclosure, and protection of personal data and other information obtained through your use of our services. These services include, but are not limited to, the MoodEaser mobile application, web-based platform, Therapist Dashboard, and all associated features, functionalities, and digital tools (collectively referred to as the “Service”).

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. This Policy is designed to comply with applicable data protection laws, including the General Data Protection Regulation.

1. Data Collection and Processing

MoodEaser collects and processes information from both therapists and end-users (clients/patients) for the purpose of delivering platform services, enhancing user experience, ensuring system integrity, and maintaining regulatory compliance. The categories of data collected include, but are not limited to:

1.1. Account Information

• Therapists: Full name, email address, encrypted password, and professional credentials including qualifications, licensing status, and clinic affiliation details.
• Clients: Full name, email address, encrypted password, and therapist connection codes used to establish linked therapeutic relationships.

1.2. Activity Data

• Clients: Interactions with Luna (AI companion), journaling entries, mood tracking inputs, meditation usage logs, homework compliance status, and goal progression metrics.
• Therapists: Usage of dashboard features including session note creation, scheduling activities, progress tracking, and communication logs.

1.3. Sensitive Health Data

Mood entries, journals, therapist homework tasks, and progress reports may constitute special category “health data” under GDPR. This is only collected with explicit consent.

1.4. Payment Information

Subscription payments made by therapists and clients are securely processed via third-party payment processors (e.g., Stripe). MoodEaser does not store raw credit card or payment instrument data on its servers.

1.5. Technical Data

MoodEaser may collect technical identifiers including IP address, device ID, operating system type, browser version, session cookies, and diagnostic logs (e.g., crash reports and analytics) for the purpose of system optimization, security monitoring, and performance analysis.

1.6. Communications

MoodEaser retains records of communications initiated by users, including emails, in-app messages, and support requests submitted to the platform’s customer service or technical support teams. These communications may be used for service improvement, dispute resolution, and compliance verification.

All data is processed in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). Users may exercise their rights to access, rectify, or request deletion of their data as provided under GDPR.

2. Legal Basis for Processing

MoodEaser processes personal and sensitive data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and other applicable data protection laws. The legal bases for processing vary depending on the nature of the data and the context of its use, and include the following:

• Consent: We obtain explicit, informed consent from data subjects prior to collecting or processing special category data, including sensitive health information such as mood entries, journaling content, and AI-generated therapeutic insights. Consent is also required for any AI-based analysis of session data that may influence therapeutic recommendations.
• Contractual Necessity: Processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to entering into a contract. This includes facilitating therapist–client connections, managing subscriptions, enabling access to the Therapist Dashboard, and delivering core platform functionalities.
• Legal Obligations: We may process personal data to comply with statutory requirements, including but not limited to obligations related to accounting, taxation, fraud detection and prevention, and lawful requests for disclosure from regulatory or judicial authorities.
• Legitimate Interests: Processing may be carried out where it is necessary for the purposes of MoodEaser’s legitimate interests, provided such interests are not overridden by the rights and freedoms of the data subject. These interests include improving platform performance, monitoring and preventing misuse or abuse, maintaining system security, and conducting anonymized research and analytics to better understand mental health trends and user engagement.

3. How We Use Your Information

MoodEaser collects and processes personal and usage data for specific, legitimate, and clearly defined purposes, in accordance with applicable data protection laws. The data collected from therapists and clients is used to:

• Deliver and Enhance Platform Services: Facilitate and improve the functionality, responsiveness, and personalization of the MoodEaser platform for both therapists and clients, ensuring a seamless and effective user experience.
• Authenticate User Accounts and Secure Access: Verify identity, manage login credentials, and protect accounts from unauthorized access or misuse through appropriate authentication protocols and security measures.
• Support Therapeutic Workflows: Enable core platform features including session documentation, SOAP note generation, homework assignment and tracking, progress monitoring, and AI-powered Copilot functionalities designed to assist therapists in their professional practice.
• Process Financial Transactions: Facilitate subscription billing and payment processing through secure third-party providers, ensuring compliance with financial and data protection regulations.
• Respond to inquiries and provide customer support.
• Generate Aggregated and Anonymized Insights: Analyze usage patterns and behavioural trends in a non-identifiable format to improve platform performance, inform product development, and contribute to research on mental health engagement.
• Communicate Service Updates: Send service-related communications, including updates to features, changes to terms, system notifications, and relevant announcements via email or in-app messaging.

MoodEaser does not use personal data for profiling, behavioural advertising, or any purpose incompatible with the original intent of collection. All processing activities are subject to appropriate legal bases and technical safeguards.

4. Sharing Your Information

MoodEaser is committed to limiting the disclosure of personal data and only shares information when it is necessary, lawful, and proportionate to the purpose for which it was collected. Data may be shared under the following circumstances:

Therapist–Client Connections

Therapists are granted access solely to the data of clients who have explicitly and voluntarily linked their accounts to the therapist through the platform. No therapist may view or access client data without such authenticated connection.

Third-Party Service Providers

We engage trusted third-party processors to support the delivery and maintenance of our services. These include:

• Stripe: For secure processing of subscription and payment transactions.
• Cloud Infrastructure: Including Amazon Web Services (AWS), Firebase, and DynamoDB for hosting, data storage, and platform scalability.
• Analytics Tools: For performance monitoring and product improvement, using aggregated and anonymized usage data that does not identify individual users.

All third-party providers are contractually bound to maintain confidentiality, implement appropriate technical and organizational safeguards, and process data solely in accordance with our instructions and applicable data protection laws.

Legal and Regulatory Compliance

We may disclose personal data if required to do so by law, regulation, court order, or other lawful request from a competent authority. Such disclosures will be limited to the scope necessary to comply with the legal obligation.

MoodEaser does not sell, rent, or otherwise disclose personal data to advertisers or marketing platforms for commercial gain. We do not engage in behavioural advertising or profiling based on sensitive health data.

5. AI and Data Processing

MoodEaser utilizes artificial intelligence technologies to enhance platform functionality and support therapeutic workflows. Specific features, including Luna (AI companion) and the Therapist Copilot tools, may process user-generated content such as text inputs, audio recordings, and journal entries. These processes may be facilitated through third-party AI providers under contractual and regulatory safeguards.

To minimize the exposure of personally identifiable information, MoodEaser implements pseudonymization techniques wherever technically and operationally feasible. This includes stripping or masking direct identifiers prior to transmitting data to AI processing endpoints, in accordance with GDPR.

All AI-generated outputs are provided for informational and supportive purposes only. They do not constitute medical advice, diagnosis, or treatment, and must not be relied upon as a substitute for professional clinical judgment. Final responsibility for interpreting, validating, and applying AI-generated suggestions rests solely with the licensed therapist or authorized professional.

MoodEaser disclaims any liability arising from the misuse, misinterpretation, or overreliance on AI outputs in clinical or legal contexts. Use of AI features constitutes acknowledgment of these limitations and acceptance of professional responsibility.

6. International Data Transfers

Where personal data is transferred to jurisdictions outside the United Kingdom or the European Union, MoodEaser ensures that such transfers are conducted in full compliance with applicable data protection laws. In particular, we rely on appropriate safeguards to protect the integrity and confidentiality of personal data during cross-border transfers. These safeguards may include:

• Standard Contractual Clauses (SCCs): Adopted by the European Commission or the UK Information Commissioner’s Office, which impose contractual obligations on the recipient to ensure adequate data protection standards.
• Equivalent Legal Mechanisms: Recognized under applicable law, such as adequacy decisions, binding corporate rules (BCRs), or other lawful transfer instruments.
• Technical and Organizational Measures: Including encryption, pseudonymization, and access controls, to mitigate risks associated with international data flows.

MoodEaser conducts periodic assessments of its data transfer practices to ensure ongoing compliance and to verify that recipient jurisdictions offer a level of protection that is essentially equivalent to that provided under the GDPR and other applicable frameworks.

7. Data Security

MoodEaser implements robust technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data processed through its platform. These safeguards include, but are not limited to:

• Encrypted Storage: Sensitive data, including health-related information and account credentials, is stored using industry-standard encryption protocols to prevent unauthorized access or disclosure.
• End-to-End Security Protocols: All data transmitted between users and the platform is protected through secure transport mechanisms (e.g., TLS/SSL) to ensure confidentiality during transit.
• Role-Based Access Controls: Access to personal data is strictly limited to authorized personnel based on defined roles and responsibilities. Therapists may only access data linked to their verified accounts and connected clients.
• Security Audits and Monitoring: MoodEaser conducts regular security audits, penetration testing, and continuous monitoring to detect vulnerabilities, prevent breaches, and ensure compliance with applicable data protection standards.
• Data Controller and Processor Roles: Therapists act as independent data controllers, while MoodEaser serves as a data processor. Client data is stored securely and processed only as necessary to provide platform services.
• Client Consent: Therapists are responsible for obtaining appropriate client consent for data usage in accordance with applicable laws and ethical guidelines.

8. Data Retention

MoodEaser retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including the provision of therapeutic services, platform functionality, and legal compliance. Specific retention practices include:

• Service-Based Retention: Therapist and client records are retained only for the duration required to deliver services and maintain platform operations.
• Account Deletion: Upon deletion of an account by a therapist or client, all associated personal data and records are securely erased within thirty (30) calendar days, unless a longer retention period is mandated by applicable law (e.g., for legal, regulatory, or audit purposes).
• Anonymized Data: Non-identifiable, anonymized data may be retained indefinitely for research, analytics, and service improvement purposes, provided such data cannot be used to re-identify individuals.

MoodEaser adheres to data minimization principles and conducts periodic reviews of its retention schedules to ensure ongoing compliance with GDPR or other relevant frameworks.

9. Intellectual Property

MoodEaser owns and retains all intellectual property rights in and to the Platform Content, including but not limited to text, graphics, software, features, and functionality. Therapists are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Dashboard solely for professional purposes related to their provision of services via the Platform.

Except as expressly permitted in writing by MoodEaser, no part of the Platform or its Content may be:

• Copied, reproduced, or downloaded
• Modified, adapted, or reverse-engineered
• Distributed, sublicensed, or otherwise made available to third parties

Any unauthorized use constitutes a breach of this Agreement and may result in termination of access.

10. Your Rights

Subject to applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), data subjects have the following rights with respect to their personal data:

• Right of Access: You may request confirmation of whether your personal data is being processed and obtain a copy of such data.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure (“Right to Be Forgotten”): You may request deletion of your personal data where legally permissible.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Object: You may object to certain types of processing, including profiling, analytics, or direct marketing, where applicable.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.

To exercise any of these rights, please contact us at: support@moodeaser.com. We will respond to requests in accordance with applicable legal timeframes and verification procedures.

To the maximum extent permitted by law, MoodEaser shall not be liable for indirect, incidental, special, or consequential damages, including loss of data, profits, or goodwill. Therapists agree to indemnify MoodEaser against claims arising from misuse or breach of these Terms.

11. Cookies and Tracking

MoodEaser uses cookies and similar tracking technologies to enhance platform functionality, maintain security, and improve user experience. These technologies may be used for:

• Authentication and Secure Login: Verifying user identity and protecting account access.
• Session Management: Maintaining active sessions and preserving user state across interactions.
• Analytics and Crash Reporting: Monitoring performance, diagnosing issues, and improving system reliability.
• Preference Storage: Remembering user settings and interface preferences for a personalized experience.

Users may manage cookie preferences through browser settings or platform controls, subject to applicable consent requirements.

MoodEaser shall not be liable for delays or failures caused by events beyond its control, including natural disasters, war, or governmental actions.

12. Privacy Policy Amendments & Termination

• Amendments: MoodEaser reserves the right to amend or update this Privacy Policy and related Terms at any time to reflect changes in platform features, legal obligations, or data processing practices. Updates will be published on the platform and, where required by law, communicated through appropriate channels. Continued use of the Service following such updates constitutes binding acceptance of the revised terms.
• Suspension & Termination: MoodEaser may suspend or terminate access in cases of breach of Terms, prolonged inactivity, or non-payment. Upon termination:
  • Access to the Dashboard may be revoked immediately.
  • Therapist Content may be retained or securely deleted in compliance with applicable law.
  • Therapists remain liable for any outstanding fees, charges, or financial obligations incurred prior to the effective date of termination.

13. Confidentiality and Standards of Conduct

Therapists hereby undertake and agree not to disclose, disseminate, or otherwise make available to any third party any information, documentation, or materials designated or reasonably understood to be confidential by MoodEaser (“Confidential Information”), without the prior written consent of MoodEaser. This obligation shall apply irrespective of the medium of communication, including but not limited to oral, written, digital, or electronic formats.

Therapists acknowledge that any unauthorized disclosure of Confidential Information may result in immediate and irreparable harm to MoodEaser, and MoodEaser shall be entitled to seek injunctive relief, specific performance, and any other remedies available under applicable law, including damages, without the necessity of proving actual loss.

In addition, Therapists shall conduct themselves in a manner that upholds the integrity and professional standards of the MoodEaser platform. This includes maintaining an environment that is respectful, inclusive, and free from any form of harassment, discrimination, or abusive conduct. Therapists shall engage in civil, constructive, and professional communication at all times and shall refrain from any behaviour that may reasonably be considered offensive, disruptive, or detrimental to the experience of other platform participants.

MoodEaser reserves the right, at its sole discretion, to investigate any alleged breach of these obligations and to take appropriate disciplinary action, which may include, without limitation, suspension or termination of access to the platform, and referral to relevant regulatory or legal authorities where warranted.

14. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the United Kingdom. Any disputes arising from or relating to these Terms shall fall under the exclusive jurisdiction of the courts of the UK.

Contact Us

If you have questions about our Privacy Policy, please reach out to support@moodeaser.com.