Privacy Policy

1. Introduction

Metacog Health Private Limited (“Company”, “Mitsu”, “we”, “us”, or “our”) is committed to protecting your privacy and safeguarding the personal information entrusted to us.

This Privacy Policy describes how we collect, use, disclose, store, and protect information when you access or use:

• The Mitsu website located at [www.mitsu.care](http://www.mitsu.care) (“Website”);
• The Mitsu mobile application (“App”);
• In-person services provided through Mitsu clinics (“Clinics”);
• Teleconsultation and online services;
• Employer-sponsored programs;
• Any other products or services offered by Mitsu from time to time (collectively, the “Services”).

By accessing or using the Services, you consent to the collection, use, storage, and disclosure of information in accordance with this Privacy Policy and applicable laws.

2. Information we collect

We may collect Personal Information, Health Information, and Usage Information necessary to provide and improve our Services.

A. Personal Information

Personal Information refers to information that identifies or can reasonably identify an individual.

This may include:

• Name;
• Date of birth;
• Gender;
• Phone number;
• Email address;
• Postal address;
• Emergency contact information;
• Government-issued identification details where required;
• Employer or organization details;
• Payment and billing information.

B. Health Information

As a mental healthcare provider, Mitsu may collect sensitive health-related information, including:

• Responses to intake questionnaires;
• Mental health assessments and screening tools;
• Mood logs and journal entries;
• Self-reported symptoms and concerns;
• Therapy and psychiatric consultation records;
• Clinical notes and observations;
• Diagnoses and treatment plans;
• Prescription information;
• Medication history;
• Assessment reports and recommendations;
• Session history and progress information;
• Information provided by parents, guardians, caregivers, or authorized representatives.

C. Usage and Technical Information

We may automatically collect certain information relating to your use of our Services, including:

• Device information;
• IP address;
• Browser type;
• Operating system;
• App usage patterns;
• Website interactions;
• Cookies and analytics information;
• Log files and timestamps.

D. Aggregated and de-identified information

We may create aggregated, anonymized, or de-identified information that does not reasonably identify an individual.

Such information may be used for:

• Improving Services;
• Research and analytics;
• Measuring program effectiveness;
• Business operations;
• Statistical reporting
• Clinical quality improvement; an
• Scientific or academic research, provided such information does not reasonably identify individuals.

3. How we collect information

A. Website and App

Information may be collected when you:

• Create an account;
• Complete intake forms;
• Use self-help programs;
• Participate in exercises and activities;
• Maintain journals or mood logs;
• Contact Mitsu;
• Schedule appointments;
• Use messaging or support features.

B. Clinic Services

Information may be collected during:

• Therapy sessions;
• Psychiatric consultations;
• Psychological assessments;
• Administrative interactions;
• Billing and payment processes.

C. Teleconsultations

Information may be collected through online consultations conducted using third-party communication platforms

D. Employer-sponsored programs

Where Services are provided through an employer or organization, we may receive limited information necessary to facilitate participation, including:

• Name;
• Company email address;
• Employee identification details;
• Workshop attendance information;
• Anonymous survey responses.

E. Parents, Guardians and Caregivers

For services involving minors or individuals requiring support, we may collect information from:

• Parents;
• Legal guardians;
• Caregivers;
• Authorized representatives.

F. Cookies and similar technologies

We may use cookies and similar technologies to:

• Improve user experience;
• Analyze Website and App usage;
• Maintain security;
• Understand user preferences.

Users may manage cookie preferences through their browser settings.

4. How we use information

We may use information for the following purposes:

To Provide Services

Including:

• Delivering therapy and psychiatric care;
• Conducting assessments;
• Coordinating appointments;
• Facilitating teleconsultations;
• Providing digital tools and support.

To support continuity of care

To enable coordination among authorized members of Mitsu’s care team.

To communicate

Including:

• Appointment reminders;
• Service updates;
• Notifications;
• Responses to inquiries.

To Improve services

Including:

• Research and analytics;
• Quality assurance;
• Program development;
• Operational improvements.

To Ensure safety

Including:

• Assessing risks to health or safety;
• Preventing harm to Users or others;
• Managing emergencies.
• Supporting clinical decision-making and continuity of care.

To comply with legal obligations

Including:

• Regulatory requirements;
• Professional obligations;
• Court orders and lawful requests.

5. Integrated Care

1. Mitsu provides care through a combination of digital tools, clinics, teleconsultations, and other services.
2. To support continuity and quality of care, information collected through the Website, App, Clinics, teleconsultations, assessments, and other Services may be combined and accessed by authorized members of Mitsu’s care team involved in providing care to you.
3. Access to such information is restricted to personnel who reasonably require it for clinical, operational, administrative, legal, or safety purposes.

6. Sharing of information

Mitsu does not sell, rent, trade, or otherwise commercially exploit Personal Information or Health Information.

Information may be shared only in the circumstances described below.

A. Service Providers

We may engage third-party service providers to support the delivery of Services, including:

• Payment processors;
• Cloud infrastructure providers;
• Video consultation platforms;
• Communication providers;
• Analytics providers;
• IT and software vendors.
• Messaging and communication service providers;

Such providers are required to maintain appropriate confidentiality and security measures.

B. Employer-sponsored programs

1. For employer-sponsored programs, Mitsu may share aggregated and anonymized information regarding program participation and effectiveness.
2. Mitsu will not disclose identifiable health information, therapy records, diagnoses, assessment reports, consultation details, or other sensitive information to employers without your explicit consent, unless required by law.

C. Legal and regulatory requirements

We may disclose information where required by:

• Applicable laws;
• Court orders;
• Government authorities;
• Regulatory bodies;
• Professional obligations.

D. Prevention of harm

We may use or disclose information where reasonably necessary to prevent or address serious risks to:

• Your health or safety;
• The health or safety of another person;
• Public safety.

Such disclosures will be limited to what is reasonably necessary under the circumstances.

7. Data Storage and Security

Mitsu implements reasonable administrative, technical, and organizational safeguards designed to protect Personal Information and Health Information against unauthorized access, disclosure, alteration, misuse, or destruction.

Such safeguards may include:

• Encryption of sensitive data during transmission and storage;
• Access controls and authentication measures;
• Secure cloud infrastructure and backups;
• Confidentiality obligations applicable to employees, clinicians, contractors, and service providers;
• Periodic review of security practices.

While Mitsu strives to protect information using industry-standard measures, no method of electronic transmission or storage is completely secure. Accordingly, Mitsu cannot guarantee absolute security of information.

8. Retention of information

Mitsu retains Personal Information and Health Information for as long as reasonably necessary to:

• Provide Services;
• Maintain continuity of care;
• Comply with legal, regulatory, and professional obligations;
• Maintain medical and clinical records;
• Resolve disputes;
• Enforce agreements;
• Protect the rights, safety, and interests of Mitsu and its Users.

Information that is no longer required may be deleted, anonymized, or otherwise processed in accordance with applicable laws and Mitsu’s internal policies.

9. Your rights

Subject to applicable laws and operational or legal requirements, Users may:

• Access their Personal Information;
• Request correction or updating of inaccurate information;
• Withdraw consent where applicable;
• Request deletion of information, subject to legal, regulatory, professional, and record retention obligations;
• Raise concerns regarding the processing of their information.
• Certain requests may not be immediately fulfilled where Mitsu is required to retain information under applicable laws or professional obligations.

Requests relating to privacy or personal information may be submitted to [hello@mitsu.care](mailto:hello@mitsu.care).

10. Privacy for Minors

1. Certain Services may be provided to individuals below the age of 18 years with the consent of a parent or legal guardian and, where appropriate, assent from the minor.
2. Information relating to minors shall be collected, used, stored, and disclosed in accordance with applicable laws and Mitsu’s policies governing services for minors.
3. Mitsu reserves the right to require documentation establishing parental or legal authority where necessary.

11. International users

If you access or use the Services from outside India, you acknowledge and agree that your information may be transferred to, stored, and processed in India or in jurisdictions where Mitsu or its service providers operate.

By using the Services, you consent to such transfer, storage, and processing, subject to applicable laws and appropriate safeguards.

12. Business Transfers

In the event of a merger, acquisition, restructuring, financing, reorganization, sale of assets, or similar transaction involving Mitsu, Personal Information and Health Information may be transferred as part of such transaction, subject to applicable laws and confidentiality obligations.

13. Third-Party Websites and Services

1. The Website, App, or Services may contain links to third-party websites or rely upon third-party platforms and services.
2. Mitsu does not control and is not responsible for the privacy practices, content, or security of such third-party services.
3. Users are encouraged to review the privacy policies of such third-party providers before using their services.

14. Updates to this Privacy Policy

Mitsu may modify or update this Privacy Policy from time to time to reflect changes in its Services, practices, technology, or legal obligations.

Updated versions of this Privacy Policy shall become effective upon publication on the Website or App.

Continued use of the Services after such publication shall constitute acceptance of the revised Privacy Policy.

15. Governing Law and Dispute Resolution

1. This Privacy Policy shall be governed by and construed in accordance with the laws of India.
2. Any dispute, controversy, or claim arising out of or relating to this Privacy Policy or the Services shall first be attempted to be resolved amicably.
3. Failing such resolution, the dispute shall be finally resolved through arbitration in accordance with the Arbitration and Conciliation Act, 1996.
4. The arbitration shall be conducted by a sole arbitrator mutually appointed by the parties. In the event the parties are unable to mutually agree upon the arbitrator, the arbitrator shall be appointed in accordance with the provisions of the Arbitration and Conciliation Act, 1996.
5. The seat and venue of arbitration shall be Mumbai, Maharashtra, India.
6. The proceedings shall be conducted in English.
7. Notwithstanding the foregoing, Mitsu shall be entitled to seek interim or injunctive relief before courts having jurisdiction in Mumbai.

16. Contact Information 

For questions, concerns, requests relating to this Privacy Policy, or grievances relating to the processing of Personal Information, Users may contact:

**Metacog Health Private Limited**

Brand Name: Mitsu

Website: [www.mitsu.care](http://www.mitsu.care)

Email: [hello@mitsu.care](mailto:hello@mitsu.care)

Registered Office:

A-401, Galleria Mall,
Hiranandani Gardens,
Powai,
Mumbai – 400076