Depending on how you interact with us, we may collect minimal personal data that can be used to identify you. Notably personal data does not include publicly available information or anonymised or aggregated information.

When you use our app and services

When you use the app and services, we collect the following information. You control the information you share with us.

We design our app to collect as little personal data as possible to keep your data safe and protect your privacy. This means there is less risk of your information being misused. When you share information with Wysa, we are responsible for taking care of it.

Information provided by you.

• Information about you. This includes things like your nickname, age-range, gender, pronouns, or identifiers you may voluntarily reveal about yourself. Contact information shared with Wysa Therapist or as required for your Institution.

• Conversation data. This covers what you type in messages, your challenges, preferences, feelings, moods, thoughts, task lists, and safety information. It also includes answers to surveys or questionnaires from us or your Institution, and how you use our tools we offer. This includes everything you type in messages or say in voice or video calls with your Wysa Therapist.

• Correspondence data. If you email us, you might share personal data like your name, email address, home address, the company you are part of, your job title, and what you talk about in the message.

• Feedback data. When we ask for your thoughts on our App and Services, we gather your contact info and some basic details about you.

Information collected via automated means or by third parties.

• Information from your Institution. Sometimes, your Institutions or their appointed representatives might share your personal data, like your contact details, so we can offer you our services.

• App event data. We collect information about what you do in the App, like where you tap, what actions you take, your settings, notifications you get, and the screens you visit.

• Device data. When you install the App, we get an ID for your device from the Google Play Store. We also collect information about your device, like the type of phone, its time zone, and its operating system. A service provider that helps us deliver content might also get your IP address to provide our services.

• Cookie Information. We and our third-party providers collect information about your app use via cookies or similar technologies. We use mandatory or necessary cookies to provide our services.

When you participate in a Wysa research study.

You can choose to sign up and join any of our or our research partner run studies. When you volunteer, we will collect some information from you. These include:

• Information about you. This may include but not limited to your contact details, country, gender, socio-economic details, age-range.

• Health and Wellness data. This may include but not limited to ethnicity, alcohol/substance use concerns, use of medication, any mental disorder diagnosis or treatment, about hallucination, validated assessment responses.

When you use the E-triage Referral Service

If you need extra help in an emergency, we might tell local services about it so they can help you. You will have to fill in a form in the App with your details so your Institution appointed care provider can get in touch with you. We use this information, on behalf of your Institution, to make sure you get the support you need.

When you participate in the Dreamkit program:

Wysa will collaborate with well-being providers and technology partners to provide a phygital solution, a hybrid offering to support your mental well-being in a digital and physical setting. Your Institution will inform the appropriate age group who can participate in such initiatives. When you do participate and use our app, we may collect these additional information from you.

• Device data. This may include collection, storing and use of a pseudonymised Wysa user identifier when you scan Wysa provided QR code.

• Health and Wellness data. This may include but not limited to questionnaire or assessment responses.

No full names, nicknames or personal identifiers will be asked and collected when you use our app for the Dreamkit program. Your language preference will be collected to allow text-based conversations in your preferred language.

• Certification data. Your Institution will provide us your full name, class/division and other information to provide a certification.

When you use the Wysa+ or Generative AI Service

By default, Wysa AI Coach uses proprietary artificial intelligence and third-party Generative AI (“Gen AI”) to provide the service. Users on older versions of the App will continue to avail the on-demand Wysa+ services. Where opted by you, Wysa+ uses third-party Gen AI along with our proprietary AI to chat with you.

Use of Gen AI or Wysa+ provides an improved experience of the AI Coach service. It allows us to provide you with high-quality, and safe responses. This helps the AI Coach talk about varied conversations and provide responses that are more suited to you. Where provided, the AI Coach allows you to chat in native English and specific Indian languages. Your conversation data is processed and part of the input to the Gen AI to provide this service. The input to and the output from the Gen AI passes through our safety guardrails and quality checks before we use it. Our clinical staff check the appropriateness of the Gen AI response at frequent intervals to make sure they are safe, and work well.

Generated Insights within Weekly Report:
Where you use weekly reports, we use third-party Gen AI to create generated insights. These reports give you personalized and useful information based on how you use the app. This can help you learn more about yourself and improve your mental health and well-being.

We share only derived and anonymous data with the Gen AI. The data we use each week comes from the information you provide and your choices while using the app. Here is what we collect each week:

• Mood Description: This is taken from the smiley face you choose at the start of a session. It tells us if you are feeling not great, mostly low, somewhere in the middle, pretty good, or in high spirits.
• Topics and feelings: These are keywords from your conversations with the AI Coach at the beginning of a session. For example, feelings could be sad, calm, confused, happy, numb, confident. Topics could be work or education.
• Tools Used: This is the list of Wysa tools you used during your time on the app.

Important Note: We do not share any of your personal details, including device identifiers with the third-party service provider.

Provision of personalised recommendations of supportive well-being resources and tools

To support your mental health and wellbeing, we use Artificial Intelligence technology to derive key insights from your conversation data and recommend appropriate self-help resources and tools. These insights and recommendation information is never shared with third parties for marketing or commercial purposes. If you wish to delete your conversation data including the derived recommendations, you can do so by choosing the “Reset my data” from the app setting. On reset my data, all your conversation data will be permanently deleted from our system and cannot be retrieved. Please note that provisioning of personalised recommendation is core to providing our services. Opting out of this feature may limit your access to our app functionality and services. If you have any questions about this processing, please write to us at [email protected].

Sources of personal data

We get your personal data either from you or your Institution, or service providers your Institution asks us to work with.

Legal grounds

We need to follow data protection laws that make sure we look after your personal data properly. Here is how and why we might use it:

1. Consent: Sometimes, we ask you if it is okay to use your personal data. You can always change your mind later if you decide you do not want us to use it anymore by writing to us

2. Contract Performance: When you use our app or services, we might need some of your personal data to provide our services and make sure everything works properly.

3. Legitimate Interests: We or someone we trust, might use your personal data to keep our services safe from fraud or security problems. We might also use it to make our services better.

4. Legal Obligation: Sometimes, we need to use your personal data to follow the law or to protect our company and the people who provide the services.

Sometimes, we need to use sensitive data that you share, like how you feel, your mood, or other things about your emotional health. We will only do this if we follow the law and have a good reason, such as:

1. Helping you with advice or support or keeping you safe while you use our App and services.

2. Acting on behalf of your Institution to redirect you to care resources.

Uses of your Information

We might use the information you give us on our App and Services for these reasons.

1. Information about you

   1. To provide and manage App and Services: Here is what we do with your information:

      1. To recognize which Institution you are part of.
      2. To recognize whether you are a new or existing user to the app and service.
      3. When needed, we will ask for your permission to turn on your device's microphone and camera.

      4. We collect, move, save, and use your information to make our services work.

      5. We set up and keep track of your chats and use of our services.

      6. We let you change your nickname

      7. Where needed, we will connect with your Institution's approved systems to handle your information.

      8. If your Institution offers the Wysa therapist Service, we will connect you with a human mental health and well-being professional.

      9. If there is an emergency, Wysa Therapist can call you or someone you trust.

      10. We keep a record of any permissions you give us.

      11. We let you know if we change our rules or privacy notice in the App

      Legal grounds: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests and consent.
2. Use of Conversation data

   1. To provide and manage App and Services: We do the following with your information:

      1. We come up with ideas and create AI programs, stories, and ways to talk for our AI Coach.

      2. The AI coach translates your preferred language to English and the other way around. This helps us understand each other and keep chatting with the AI Coach.

      3. The AI coach remembers the text messages you send and choices you make while using the app.

      4. The AI coach figures out if you are feeling happy, sad, or have any problems or questions. This helps us chat with you safely and give you required resources.

      5. The AI coach makes sure we understand you so our conversations make sense.

      6. The AI coach shows you safe tools and techniques that can help you.

      7. We make sure any personal details you accidentally share in your messages are removed and cannot be traced back to you.

      8. The AI coach looks for any medical or emergency words in your messages to help keep you safe.

      9. If the AI coach detects something that seems like an emergency, we may inform your Institution.

      10. We might use some anonymous chats to help our AI learn better.

      11. To provide personalised recommendations of supportive self-help resources and tools.

      12. We give you information and resources when you text your Institution clinician or well-being advisor. Any data involving safety or risk is shared automatically to ensure that your clinician or well-being advisor is aware.

      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests. Use of appropriate additional conditions for any sensitive data.

   2. To perform well-being assessments: We do the following with your responses:

      1. The AI coach will ask you about how you feel and your mental well-being from time to time.

      2. The AI coach recognises if you inform any emergencies and may let your Institution know to provide support.

      3. The AI coach guides you to helpful hotlines and support resources if you need them.

      4. The AI coach recommends tools, tips, and resources to help you to manage your mood and improve your wellbeing.

      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests. Use of appropriate additional conditions for any sensitive data.

   3. To Provide Wysa Therapist Services:We do the following with your information:

      1. To take your permission to turn on your device's microphone and camera.

      2. You can send text messages and have video or audio calls with your Wysa Therapist.

      3. The service gives you information and resources shared by your Wysa therapist.

      4. The service shares your AI Coach conversation data with your Wysa therapist to help with your care. You can stop this sharing anytime from the app settings.

      5. Some of the messages you send to your Wysa Therapist are checked for quality. This helps make the service better and safer.

      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests and consent. Use of appropriate additional conditions for any sensitive data.

   4. To provide in-app notifications and reminders: We will send you alerts if you choose to set reminders and notifications. We will remind you about upcoming service events. We will send appropriate Wysa Therapist session reminders.

      Legal basis: contract performance, consent.

   5. For research, analytics, and compliance reporting: We might remove details that show who you are so that no one can tell the information is about you. We will use this changed information to check how well our App is working and to see if it is safe and useful. Sometimes, we also share this information with regulators to make sure we are following the laws.

      Legal basis: For each purpose listed above we will rely on one among the following, legitimate interests, legal obligations.
3. Use of Correspondence data

   1. To communicate effectively with you:We do the following with your responses:

      1. We answer your questions, requests, complaints, and other feedback.

      2. We fix any problems with our services.

      3. We send you important service updates.

      4. We keep track of our conversations with you to make sure we are doing a good job and following the rules, and also to help train our team.

      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests.
4. Use of Feedbacks

   1. To improve our App and Services: We do the following with your information:

      1. To invite you to join activities like sharing your thoughts about our product, or helping us test it.
      2. To understand your feedback so we can make our product and services safer and better.
      3. To use your personal details to make sure everyone has a fair chance to join in and that we test our product with the right groups of people.
      Legal basis: For each purpose listed above we will rely on one among the following, legitimate interests, consent
5. Regarding Information sharing with your Institution

   1. To provide and manage App and Services: We do the following for your Institution:

      1. We may send you links or allow you to use codes so you can use the App.
      2. The apps may check to make sure you are part of your Institution.
      3. We share required reports and statistics with your Institution.
      Legal basis: contract performance. Use of appropriate additional conditions for any sensitive data.
6. Use of App event and device data

   1. To understand App and service usage: We do the following with your information:

      1. We remove any identifiers from your information before using it to check how well our App works and to make sure your information is safe.
      2. We check and record the safety and performance of the App so we can report to your Institution or meet our legal requirements.
      3. We confirm sessions with your Wysa Therapist.
      4. We share data that cannot identify you about your usage of the App with trusted analytics providers. This helps us make the App and its services better.
      5. We use the Information to create new services, technologies, and products.
      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests, legal obligation. Use of appropriate additional conditions for any sensitive data.

   2. For marketing purposes: We do the following with your information:

      1. Sometimes, we create and run campaigns, send out surveys, and give updates about our programs.
      2. We also use anonymous data to understand how well we are doing, make marketing materials, and benchmark ourselves with others.
      Legal basis: For each purpose listed above we will rely on one among the following, legitimate interests, consent.

   3. To ensure availability and security: We do the following with your information:

      1. To make sure the content on our app works well.
      2. To keep your information safe from hackers and online threats.
      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests.

   4. For fraud prevention: To prevent fraud or misuse of our services and to secure our systems.

      Legal basis: legitimate interests.
7. Use of Cookie Information

   We need to use some necessary cookies to make sure our App works properly. Here is a simple guide to the kinds of cookies we might use:

   • Essential cookies. These are very important and are needed for the App to work. They help make sure everything runs smoothly, like when you chat on the App. These cookies do not collect any information about you. We handle these cookies ourselves.

   • Analytical cookies. We also use these cookies to see how well our App is doing. They help us understand what is working and what needs fixing. Sometimes, we use our own cookies for this, and sometimes we use Google Analytics. If you want to know what Google Analytics does with the information, you can visit their website. https://www.google.com/policies/privacy/partners/. You can opt out from Google’s cookies by downloading the Google Analytics Opt-out Browser Add-on Download Page. We do not use special Google tools to show you ads or test features on the App. We do not use Google signals, which means we do not collect information about you or what you like.

   "Do Not Track" (DNT) is something you can turn on in your web browser to keep your online activities more private. However, even if you turn DNT on, we do not collect those signals today.

   Legal basis: legitimate interests.

Additional processing for e-triage referral services

1. For processing your onward support request

   1. To process your provided data:We do the following with your information when you choose to seek additional support during any emergencies:

      1. We gather, move and store the information we need from you.
      2. We delete your personal data when we no longer need it, as agreed with your Institution.
      3. We help you find safety resources and guide you on how to use them.
      Legal basis: contract performance and as defined by your Institution.

   2. To transfer your request to authorised parties: We do the following with your information:

      1. We send your request to your Institution or care provider.
      2. If you ask us to, we can also send you a copy of your request.
      3. If you ask us to, we can send a copy of your request to your parent or guardian too.
      Legal basis: consent and as defined by your Institution.

We do not share or sell your information, messages, or how you use our App to advertisers or companies that buy data. If we ever want to use your name to show other people how good our App is, we will always ask you first.

Additional processing for the Dreamkit program

1. To process your device data: We do the following when you use the app.

   1. We collect, transfer, store and use the Wysa generated user identifier to identify you with your Institution.

   2. We associate all your app-provided information against the pseudonymised user identifier.
   3. We associate the preferred language of conversation within the app.
   4. We anonymise the user identifier so your identity is protected.
   Legal basis: contract performance and as defined by your Institution, Legitimate Interest.

2. To process health and wellness data: We do the following with your anonymised assessment responses.

   1. We collect, transfer, store and use the offline assessment response sheets and information provided by you.
   2. We aggregate the anonymised responses received and share aggregated analytics with your Institution.
   3. We use the aggregated analytics to improve our app and service performance and safety.
   Legal basis: None as no personal data is involved.

3. To issue your assessment certificate: We do the following with your Institution-provided information.

   1. We collect, transfer, store and use the information shared by your Institution about you.
   2. We use the information received to conduct examinations and issue Wysa completion certificates.
   3. We use the information to assess user outcomes and progress.
   4. We share insights and certificates with your Institution.
   Legal basis: consent and as defined by your Institution.

Additional Processing When you use the Gen AI or Wysa+ service

1. Use of Conversation data

   1. To provide the Gen AI or Wysa+ Service:We do the following with your information:

      1. We share your relevant conversation messages to Gen AI (“Input”) for classification purposes or to receive controlled Gen AI responses.
      2. To provide personalised recommendations of supportive self-help resources and tools.
      3. We design prompts to guide Gen AI to respond appropriately to the Input. The prompts include your message, summaries of your chats over a period and our validated instructions.
      4. Detect personal identifiers that you might have shared by mistake. If there are any, the AI coach will ask you to change your conversation message before sending it to Gen AI.
      5. We have safety guardrails to keep your chats with Gen AI safe. All Inputs go through these guardrails. If your message does not clear the guardrails, we do not send it to Gen AI. When Gen AI responds (“Output”), it also has to pass the safety rules. If it does not, we do not release the Output, instead providing a pre-defined safe response.
      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests.

   2. To provide the Generated Insights within Weekly Report: We do the following with your information:

      1. Find topics and feelings through Wysa’s programs.
      2. Derive mood values from your choices during check-ins.
      3. Record how you use Wysa’s tools.
      4. Prepare an anonymous dataset.
      5. Share this anonymous dataset with the third-party service provider.
      6. Get and store the output received from Gen AI.
      7. Ensure everything is safe, private, and secure through proper precautions.
      8. Create useful insights from the results and add them to the weekly report.
      9. Talk with you, answer your questions, and provide help.
      10. Follow the law and protect your rights and interests.
      Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests. Use of appropriate additional conditions for any sensitive data.

Additional processing during participation in research studies

1. To process the information shared by you during participation: We do the following.

   1. Inform about the study purposes
   2. Understand your eligibility for the study.
   3. Manage your joining process.
   4. Send study related information and reminders.
   5. Contact you during the study for research purposes and respond to requests.
   6. Seek your feedback and clarify any questions.
   7. Perform analysis using the information provided.
   Legal basis: your consent and legitimate interests.

   Note: You can stop participating in the research at any time after it starts. You can do this by changing the settings in the app or sending an email to [email protected] with the subject "opt out of Wysa Study". Once you opt out, we will delete your enrollment data within one year. However, the data you provided while using the app will be kept according to our data retention policy, which you can read about here. Your study data will always be kept safe. You can learn more about how we protect your data here.

Additional processing during campaigns or promotions or marketing events.

1. To process the promotion event data: We do the following.

   1. Sign you up and get you started on the promotion or campaign.
   2. Contact you about campaigns and promotions.
   3. Send you information about promotions, newsletters, webinar invites, and reminders.
   4. Make sure we follow the rules about not sending unwanted messages before we contact you for marketing or business reasons.
   Legal basis: For each purpose listed above we will rely on one among the following, your consent, legitimate interests and as defined by your Institution.

Note: If you want to leave the promotion or campaign, you can email us at [email protected]. We will reply within 3 business days. Your information will stay private.

We use Meta Ads Manager to make ads about our service, to send these ads, and to see how well they are doing. We also group users together for anonymous cohort analysis. We use Google Analytics to see how much people use this service, but no personal data is collected or shared with them.