Privacy and Cookie Policy for PsychPlus App

Effective from: June 2026

This Privacy & Cookies Policy of the PsychPlus App (the “Privacy Policy”) applies to any collection and/or processing of personal data by Koa Health LLC and its affiliates (collectively, “Koa Health,”, “Koa,” “we,” “us,” “our,” or “ours”), performed as a result of your use of the PsychPlus application (the “App” or “PsychPlus”). All data collected by the App will not be processed for any other reason than is outlined in this Privacy Policy.

Note that this App might collect sensitive personal data that is health-related (hereinafter “Sensitive Data”). If you do not agree with this Privacy Policy, please do not access or use the App and the services provided therein.

Summary of Privacy Policy - Reading time 2 mins

This summary helps you quickly understand the main points of the Privacy Policy. It is provided for convenience only. Because it does not replace our full Privacy Policy, please read the full Privacy Policy to understand the complete picture of how we handle personal data.

We’re Koa Health.

Koa Health is now part of the PsychPlus group of companies. The services are provided by Koa Health, which is now a subsidiary of PsychPlus. For the purposes of data protection law, Koa Health remains the primary controller of your information but may share administrative and compliance resources with our parent company, PsychPlus, to improve your care. PsychPlus is built to help you prioritize your health and manage daily stress effectively. As part of our integrated approach, the product also serves as your gateway to clinical support. You can now use PsychPlus to connect directly with PsychPlus clinics for professional therapy services, bringing digital wellbeing and clinical excellence together in one place.

We collect the information we need to run and improve PsychPlus.

We collect your information to help you support and maintain your health and wellness. We may collect additional information with your permission or to comply with applicable law.

You can choose not to share some information with us.

You can use the settings menu to understand what information you can stop sharing with us, and what App functions you will lose access to if you stop sharing.

We share information about you with third-party service providers.

This helps us provide some parts of the service (such as notifications). We ask our service providers to keep your information safe.

We may need to process your health data for Clinical Services

If you choose to use our therapy services, we will collect and process the information necessary to facilitate your care, as well as your financial and/or insurance data to manage the payment process.

We may share certain information with organizations that we work with.

If you have access to PsychPlus through your employer or from another organization, we may share anonymized or aggregated summary reports with this organization (such as how many sign-ups there have been). Beyond our service providers and Customers, we may also share anonymized or aggregated information with researchers to help us improve PsychPlus.

We have different age restrictions depending on where you are and the services you are using.

By using PsychPlus, you are telling us that access to PsychPlus self-guided or Plus membership content requires that you are at least 18 years old in the US, and at least 16 years old in the UK, the EEA and or other countries. Access to clinical care is managed when scheduling appointments and requires a separate consent process.

We work hard to keep your information safe.

We work to protect your information from being lost, stolen or misused. Because no system is perfect, you can help by keeping your password and account details safe.

We use your information to contact you.

We also may contact you and respond to your questions.

Index

Summary

1. Who collects, controls and processes your personal data?

2. Why do we collect personal data about you and what do we do with it?

3. What personal data do we collect about you and how?

4. Do we share personal data about you with others?

5. How long do we keep your data?

6. What rights do you have related to your personal data and how can you use them?

7. International data transfers

8. How do we keep your data safe?

9. Changes to this Privacy Policy

10. Protected Health Information and HIPAA

11. Cookies Policy

1. Who collects, controls and processes your personal data?

The controller responsible for collecting and processing your data changes depending on your place of residence associated with your account:

When you are a registered user residing in the US or Canada:

The service provider is Koa Health Digital Solutions LLC, a company registered in the United States (“US”) with its registered address at 75 State Street, Boston MA 02109, United States of America. Koa Health is part of the PsychPlus group of companies. You can contact Koa at privacy@PsychPlus.com for any privacy related matter.

When you are a registered user residing in the UK, the EEA, Australia or rest of world:

The personal data controller is Koa Health Digital Solutions Limited, a company registered in the United Kingdom (registered number 13298286) with registered address at 55 Baker Street, London WU1 7EU, UK.

Koa Health Digital Solutions Limited is the Data Controller (the “controller”) of all personal data collected through the App. Regardless of your location, your data will be processed as indicated in this privacy policy.

You can contact Koa Health at privacy@psychplus.com for any privacy related matter.

2. Why do we collect personal data about you and what do we do with it?

Help you manage your mental wellbeing.

The main purpose of the app is to help you better understand and manage your well-being and recommend care pathways for mental health challenges you may be facing. The application contains questionnaires and exercises designed to give you tools to manage and improve your wellbeing. Also, in some cases, we will offer you access to higher levels of support from more specialized services to help you manage your wellbeing.

Your consent is the basis for the collection and process of personal data relating to this functionality. Some of the personal data collected for this purpose may be considered Sensitive Data. You can remove this consent at any time within the privacy page of the app, or by contacting us at privacy@psychplus.com using, if possible, the same email address with which you registered in the App.

We may process personal data in a manner that removes identifiers and renders the data anonymous. Once data is anonymized, it no longer falls under data protection laws and may be used for analytical, statistical, or product improvement purposes.

Provision of basic App services:

If you create an account in our App, or sign-in with your corporate credentials using Single Sign-On (SSO), we will process some personal data for providing basic services of the App such as registration, authentication or support.

As we strictly need some personal data for the functioning of the App, the lawful basis of this processing is the performance of a contract, based on the Terms of Use of the App. Sensitive Data is not collected or processed for this purpose.

Improving the functioning of the App and our services:

We process personal data to improve the App performance and usability and to provide a better service. This includes aspects related to performance, navigation, availability and usability. To do this, we consider things like how often and for how long you use the App, how you navigate between screens, the activities you use, and which screens you spend more time on. We might also ask for your feedback through email or the App. You may also provide us some additional background information, such as gender, ethnicity or clinical background to help us understand the demography of our users and help us reduce bias in our service.

Our legitimate interest is the legal basis for this processing. Sensitive Data (such as wellbeing scores) is not collected or processed for this purpose.

Communications:

We process your contact data to send you information about our services or products, such as product updates and new content. We may use third-party services to facilitate such communications.

Our legitimate interest is the legal basis for this processing. Sensitive Data (such as wellbeing scores) is not collected or processed for this purpose. You can opt-out of these communications using the “unsubscribe” option in one of our emails. When you opt out of these communications, you may still receive emails from us when we need to communicate with you in connection with our provision of the services or products.

Coordination of Therapy Services:

During your usage of the PsychPlus app, we may recommend our integrated therapy services. If you choose to proceed, we will coordinate your care by processing the following information within our clinical system:

As part of a company agreement

When you are using PsychPlus as part of a benefit plan from your employer or other organization, they may share your personal information with us (First Name, Last Name, Year of Birth, Phone number, Email Address, residence state) to manage your eligibility to the App and so you may receive an invitation to join the App.

Enabling wellbeing or rewards programs:

When you receive PsychPlus as part of a wellbeing or rewards program, you may be asked to share some of the information in the App back to the program to support its administration and operation of the healthcare plan. If your usage of PsychPlus is part of a HIPAA covered insurance company then your insurer may require this data, in which case it can only be used under strictly regulated HIPAA conditions. In all other cases, you will control this data sharing via a specific consent process which describes how that data is used and which you may withdraw at any time.

Inquiries and Customer Support:

We process the personal information you submit to us (such as your name, contact details, and the content of your inquiry) when you reach out through any communication channel (e.g., email, contact form). The Data Processing Purpose is to effectively respond to your questions, fulfill your requests, and provide you with comprehensive customer support. The Lawful Basis we rely on is Legitimate Interests; this is because we have a legitimate interest in efficiently and effectively managing all user inquiries, especially those relating to general questions about our company, services, or products that do not involve an existing contract or purchase. This allows us to ensure every user receives a timely and helpful response while continually improving the quality of our customer service.

3. What personal data do we collect about you and how?

The App’s functionalities require the collection of personal and health data. Sometimes you provide us with data, and sometimes data about you is collected or inferred through your use of the App or generated by us through analysis. We collect and process the minimum personal data necessary for each of the different purposes, and we will keep it as explained in Section 5 below. Should the purposes of the data collected change, we will inform you beforehand and ask for your consent again, where applicable, before we process any data.

The App is not intended to be used in the detection, diagnosis, prevention, monitoring, prediction, prognosis, therapy, treatment or alleviation of any condition, disease or vital physiological processes or for the transmission of time sensitive health information. See our Terms & Conditions for more information.

When you create an account within the App, or sign-in with your corporate credentials using Single Sign-On (SSO), you share with us the following information:

When you use the App and answer our questionnaires and tests, you share with us the following information:

Through the use of online tracking technologies, we collect and process the following information:

We monitor your activity in the App to improve your experience. * By analyzing aggregated data from how you use the App, we can identify usability issues and make improvements, for example, if loading times are slow or if information is too hard to find.

When you use the associated therapy services. * Mental Health Background: Information regarding your clinical history and symptoms required to initiate therapy. * Contact & Demographic Details: Your full name, address, phone number, email, gender, and age. * Clinical Records: Intake assessments, confirmed diagnoses, and medication history. * Insurance Information: Payer name, insurance plan, member ID, group number, priority, Social Security Number (SSN), and related coverage details. * Appointment Metadata: Logs of session dates, times, and duration. * Payment Information: Credit card details and billing addresses (securely processed by our third-party payment provider).

4. Do we share personal data about you with others?

Except as noted below, we do not share any personal data about you with our Customers or other companies. We will only share aggregated and/or de-identified information.

As part of the PsychPlus family, we may transfer your personal information to our parent company, PsychPlus, Inc., located in the United States. We are committed to ensuring your data receives a level of protection equivalent to that provided in the UK and EEA. These transfers are strictly conducted under documented legal safeguards.

Where the App is offered by an employer (“Customer”) to its employees, Koa may provide aggregated insights related to the usage of the App to the Customer, so that the Customer can understand the App’s impact. For example, we may provide information on what percentage of people who used the App have found it to be beneficial. These insights are aggregated statistics which are only generated when there is a sufficiently large number of users of the App, nor see any raw data you have entered into the App.

If you are receiving PsychPlus as part of an employee wellbeing or rewards program, then with your consent, we may share aspects of your summary information about your activity with the program to support its administration and operation.

If you are in the US, and your health plan company or healthcare provider is a covered entity and has signed a Business Associate agreement (BAA) with us, we may share aspects of your summary information about your activity in the app.

When logging in using your company’s Single Sign-On (SSO), we will redirect you to your company’s sign-in page. SSO is operated by your current employer or the company that provided you with PsychPlus. The provider of SSO could know you are using PsychPlus.

When you are redirected from PsychPlus to our therapy services or an employee wellbeing service/EAP service provided by your employer, we may share with them the following information needed for identifying and contacting you:

In addition to the above, when a therapy partner is engaged, we may share the following information needed for your health treatment:

Consistent with Section 3, we may share some of your personal data with service providers for specific activities such as hosting, providing customer support, analytics or application functionality such as notifications.

In the case that you accept a referral to a therapy partner, some of your data including personal and health data is shared so that the therapist can register you as a patient and begin the sessions as effectively as possible. The therapy partners operate under medical regulations such as Independent Data Controllers (EU) or Health Care Practitioners (US), and they will provide you with their respective privacy policies.

5. How long do we keep your data?

We may retain your personal data for different periods of time, depending on the type of data involved and the purposes of the processing, but generally, following these criteria:

Data protection laws may give you a series of rights regarding the personal data that we manage about you. For example, the rights of access, rectification, erasure, amendment, limitation, objection, portability, as well as not being subject to automated decision making and being able to remove your consent.

You can request to exercise these rights by contacting us at privacy@psychplus.com. When sending us a request, use the same email address with which you registered in the App and the right you want to request, if possible. If you decide to exercise one of these rights through a representative, it will be necessary to provide documentation to authorize the request.

We will respond to any other requests within a maximum of 30 days. That period may be extended by an additional 30 days if necessary. In the event of such an extension, we will notify you within 30 days of receipt of the request, together with the reasons for the delay.

If you feel your data privacy rights have been breached, you also have the right to file a complaint with the Information Commissioner’s Office, or the U.S. Department of Health and Human Services.

In order to register and use our services you must be over 18 years old. Therefore, by signing up you confirm that you meet this condition. We may contact you to confirm this. We do not knowingly collect information from those younger than 18 years old. If you are a parent or guardian and believe that your child has used the App, you may contact us at privacy@psychplus.com.

7. International data transfers

Koa Health operates globally, as do our service providers and partners. When you use our products, your personal information may be transferred to countries with different data protection laws than your own, such as countries within the European Union or the United States.

As part of the PsychPlus family, we may transfer your personal information to our parent company, PsychPlus LLC, located in the United States. We are committed to ensuring your data receives a level of protection equivalent to that provided in the UK and EEA. These transfers are strictly conducted under the following legal safeguards:

In every case, we ensure that data is moved using mechanisms allowed by applicable laws, including GDPR, HIPAA, and local regulations. We employ rigorous contractual, technical, and organizational measures—such as data protection agreements and encryption—to keep your information safe. We also maintain strict practices to challenge any disproportionate or unlawful government requests for data to ensure your privacy remains a top priority.

8. How do we keep your data safe?

Koa understands the importance of the security, integrity and confidentiality of your personal data. Therefore, as part of our commitment and in compliance with applicable legislation, we have adopted security measures and technical means designed to prevent the loss of, misuse of or unauthorized access to personal data.

We protect all communications between the App and the servers by using TLS for encryption and server authentication. Koa Health products are certified to SOC2 Type 2 which is the standard for cloud based information system security, and equivalent to the ISO 27001 standard commonly used in Europe. Data is always encrypted in storage and in transit using industry standard technology.

Also, we promise to act quickly and responsibly in the event that the security of your data may be in danger, and to inform you if necessary.

9. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time and will post any revisions on our App. We will indicate at the bottom of the Privacy Policy the Effective Date of the most recent update. If an update requires additional notice to you or your consent, we will contact you to provide that notice or seek that consent.

10. Protected Health Information and HIPAA

When you are using PsychPlus as part of your healthcare insurance plan in the US, we might receive from your insurer, your name and email address, which we will use to give you access to the App.

If you are based in the US, then some of the information we collect about you is “Protected Health Information” (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Generally speaking, the following information will be PHI: (a) the information we receive from your healthcare insurance carrier and (b) information you provide in the App that relates to your past, present, or future physical or mental health or condition; the provision of health care to you; or the past, present, or future payment for the provision of health care to you, and (c) summary information from any therapy sessions such as show/no-show, improving/worsening; information which allow us to ensure the therapist is doing a good job.

11. Cookies Policy

What are cookies?

When you access our services, using a browser, we may use cookies, pixels, and other online tracking technologies (collectively referred to here as “cookies”). Cookies are widely used by online service providers in order (for example) for services to work and/or function, or to work more efficiently, as well as to provide reporting information.

Cookies set by the controller are called “first-party cookies”. Cookies set by parties other than the controller are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided through the app you are using (such as interactive content and analytics). The third parties that set these third-party cookies can recognize your device both when it visits the service in question and also when it visits certain other websites or services.

Why do we use cookies and other tracking technologies?

The third-party cookies or similar tracking technologies such as software development Kits (“SDKs”) help us track and target the activity of our users. For example, we use cookies for analytics, configuration, and other purposes. The cookies we use include the following:

Essential cookies: Essential cookies, or strictly necessary cookies, are cookies that are essential for a website or an app to function correctly. Essential cookies cannot be turned off, as they would impact the way our products work.

Analytics: We do not use analytics cookies or other tracking technologies.

Communications: We collect and share technical data from our App, so that we can send users more relevant communications based on how they interact with the App.

How can I deactivate cookies or similar tracking technologies?

You can withdraw consent for the usage of cookies by following the instructions of Section 6 of this Privacy Policy.