Mantra Health Privacy Policy

Washington and Nevada 

Last modified: September 21, 2026

1. About This Policy

This Consumer Health Data Privacy Policy explains how Mantra Health, Inc. (“Mantra,” “we,” “us,” “our”) collects, uses, shares, and protects consumer health data, and the rights you have with respect to that data.

It applies to you if you are a resident of Washington, a resident of Nevada, or a person whose consumer health data is collected in Washington. It supplements, and does not replace, our general Privacy Policy and the Wellround Notice of Privacy Practices.

“Consumer health data” means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. It includes information about mental health conditions and treatment, health care services you have sought or received, and data derived or inferred about your health status through algorithms, machine learning, or similar means.

2. Information This Policy Does Not Cover

Certain categories of information are excluded from Washington’s and Nevada’s consumer health data laws. This policy does not apply to:

  • Protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Mantra handles this information as a business associate of Wellround, P.C. Its treatment is described in the Wellround Notice of Privacy Practices.
  • Health care information collected, used, or disclosed in accordance with chapter 70.02 RCW, and patient identifying information governed by 42 C.F.R. Part 2.
  • Personal information governed by and collected, used, or disclosed pursuant to the Family Educational Rights and Privacy Act (FERPA). 
  • Identifiable private information collected in connection with human subjects research under 45 C.F.R. Part 46.
  • Information that has been deidentified in accordance with 45 C.F.R. Part 164, and aggregate information that does not identify any individual.

3. Categories and Purpose of Collected Consumer Health Data

We collect the categories of consumer health data set out below. We collect each category either with your consent or because it is necessary to provide a product or service you have requested.

Category of consumer health dataPurpose for collection and how it is used
Health and mental health information you provide directly,  including your medical history, symptoms, current concerns, medications, and the reason you are seeking support, where that information is collected before or outside a clinical relationship governed by HIPAATo determine eligibility, route you to the appropriate level of care or support, schedule services, and respond to your requests
Information indicating that you have sought, scheduled, received, or declined health care services, including appointment, referral, registration, and eligibility informationTo operate the Services, coordinate care with your University and with Wellround providers, and administer your account
Survey & Analytics Services input — your responses to Mantra wellbeing and mental health surveys, your messages to and interactions with the AI Companion (if used by your institution), and information about your use of the Services such as whether you started or completed a survey or used the AI Companion (if used by your institution).To deliver the Survey & Analytics Services your University sponsors, to measure change over time by connecting responses across survey periods, and to produce the analytics and inferences described below
Information your University provides about you in connection with the Survey & Analytics ServicesTo invite you to participate, associate your responses with the correct record across survey periods, and enable your University to support you
Automated scores and indices estimating wellbeing and the likelihood that a student may not persist in their studies, and flags indicating areas where you may benefit from support, as well as AI-generated narratives provided to you and to staff members about you, summarizing your responses and recommending support priorities.To help you and your University identify where support may be useful. The narratives are produced in part by artificial intelligence, including third-party large language models. They are informational only and are not medical, clinical, or professional advice.
Safety-related information arising from your use of the AI Companion (if used by your institution), including that a safety concern was identified and a summary of that concernTo respond to potential risk of harm and to enable your University to respond
Self-care and wellness content engagement in the Mantra Hub, including which modules, skills, or resources you view or completeTo deliver and personalize the content you request and to improve the Services
Identifiers and device and usage data collected on our Site — IP address, device and browser type, operating system, cookie and analytics identifiers, clickstream data, pages viewed, and the date and time of your visit — where collected on pages concerning mental health care services or otherwise linked to a category aboveTo operate and secure the Site, understand usage, and improve the Services
Precise or approximate location dataTo verify that you are located in a state where your selected provider is licensed to provide care, and to confirm your eligibility for care with that provider
Payment information, for students who pay Mantra directly for care (not sponsored by their institution). This information is entered by the student directly in Stripe, our third-party payment processor, and is not held on our platform or subject to HIPAA.To process payment for care that you pay for directly. This information is collected and processed by Stripe on our behalf and is not stored on our platform.

If you access or use the Site or Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Site and the Services under applicable state laws, federal laws or the authorization of a parent or legal guardian who agrees to be bound by these Terms (or have approval to treat from Mantra/Wellround). Anyone under age 18 that does not have sufficient authority and capacity to consent to access or use the Services may not provide any information to or through the Site without our permission. We do not knowingly collect Personal Data from persons who lack adequate authority and capacity to consent to access and use the Services. If you are under 18 and lack sufficient authority to access or use the Services, do not use or provide any information on the Site or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at hi@mantrahealth.com.

4. Sources of consumer health data

We collect consumer health data from the following categories of sources:

  • Directly from you, when you register, complete a form or survey, interact with the AI Companion, use Mantra Hub content, request services, or correspond with us
  • From your University or sponsoring institution
  • Automatically from your device and browser, through cookies, analytics services, and similar technologies
  • From our service providers and AI providers, including inferences generated in the course of providing the Services
  • From health care providers and Wellround, where permitted by law and, where applicable, with your authorization

5. Categories of consumer health data we share, and with whom

We share consumer health data only as described below. We do not share it for any purpose not disclosed in this policy.

RecipientWhat is sharedWhy
Your University or sponsoring institutionSurvey responses; AI-generated inferences including scores, indices, flags, summaries, and recommended support priorities; safety-related information; enrollment and registration information related to your participationSo that your University may support you, subject to your consent and applicable law
AI providers — third parties providing large language models and related artificial-intelligence infrastructure:
Anthropic, PBC
Amazon Web Services, Inc.
Aptible, Inc.
Langfuse GmbH
Your input to the Survey & Analytics Services and the AI Companion. This data is personally identifiable information (PII) collected through the Survey & Analytics Services and is governed by FERPA. We do not share protected health information (PHI) with AI providers.To operate the Services on our behalf. These providers must keep your data confidential, may process it only to provide the Services, and may not use input that identifies you to train their models without your separate consent
Wellround, P.C. and its health care providersInformation necessary to establish and deliver clinical careTo provide the clinical services you request. Once a clinical relationship exists, that information is governed by the Notice of Privacy Practices
Service providers and processors — cloud hosting and IT infrastructure, survey and analytics platforms, communications and messaging, scheduling, security, and customer support vendorsThe categories necessary for each vendor’s functionTo operate, secure, and support the Services under written contracts that restrict their use of the data
Government authorities, courts, and law enforcementAs required by the specific legal processTo comply with a court order, law, or legal process, or to protect the rights, property, or safety of you, Mantra, or others
A buyer or successor entityData held by Mantra that forms part of the transferred assetsIn connection with a merger, acquisition, restructuring, or sale of assets

Before we collect or share a category of consumer health data not listed above, or share it for a purpose not listed above, we will update this policy and obtain your consent.

6. We do not sell consumer health data

Mantra does not sell consumer health data. Under Washington law, a “sale” means exchanging consumer health data for monetary or other valuable consideration. We do not engage in any such exchange, and we would not do so without first obtaining your signed, standalone written authorization as required by law. 

7. Your rights

If you are a Washington resident, or your consumer health data is collected in Washington

You have the right to:

  • Confirm whether we collect, share, or sell your consumer health data, and access that data
  • Obtain a list of all third parties and affiliates with whom we have shared or to whom we have sold your consumer health data, together with an active email address or other online contact for each
  • Withdraw your consent to our collection and sharing of your consumer health data
  • Have your consumer health data deleted, including from our archived and backup systems. When you make a deletion request, we will notify our affiliates, processors, contractors, and the third parties with whom we have shared your data, and direct them to delete it
  • Appeal a refusal to act on your request

If you are a Nevada resident

You have the right to:

  • Confirm whether we are collecting, sharing, or selling your consumer health data
  • Obtain a list of all third parties with whom we have shared or to whom we have sold your consumer health data
  • Direct us to stop collecting, sharing, or selling your consumer health data
  • Have your consumer health data deleted
  • Appeal a refusal to act on your request

8. How to exercise your rights

Submit a request in any of the following ways:

  • Mail:
    Mantra Health, Inc.
    Attn: Privacy Officer
    c/o Primary Co-working
    26 Broadway #356
    New York, NY 10004
  • Telephone: 1 (240) 307-4648

Verification. We will take reasonable steps to verify your identity before acting on a request. We may ask for information sufficient to match you to the data we hold. We will not use information you provide for verification for any other purpose.

Authorized agents. You may use an authorized agent to submit a request where the law permits. We may require proof of the agent’s authority.

Timing. We will respond without undue delay and in all cases within 45 days of receiving your request. Where reasonably necessary given the complexity or number of your requests, we may extend that period by an additional 45 days and will tell you the reason before the first period ends.

Cost. We provide our response free of charge, subject to the limits the law allows for manifestly unfounded or excessive requests.

No discrimination. We will not deny you goods or services, charge you a different price, or provide you a different level of service because you exercised these rights.

Appeals. If we decline to act on your request, we will tell you why and how to appeal. You may appeal by writing to privacy@mantrahealth.com with the subject line “Consumer Health Data Appeal.” We will respond to your appeal in writing within 45 days.

If your appeal is denied. Washington residents may submit a complaint to the Washington State Attorney General at www.atg.wa.gov/file-complaint. Nevada residents may submit a complaint to the Nevada Attorney General’s Bureau of Consumer Protection at ag.nv.gov.

9. How we protect consumer health data

We restrict access to consumer health data to the employees, processors, and contractors for whom access is necessary to provide the Services or to further the purposes described in this policy. We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of consumer health data, including encryption of information in transit and at rest, access controls, and contractual restrictions on our vendors.

10. Geofencing

We do not use a geofence around any health care facility to identify or track consumers seeking health care services, to collect consumer health data, or to send notifications, messages, or advertising related to consumer health data or health care services.

11. Changes to this policy

We may update this policy. When we do, we will change the effective date at the top of this page and post the updated policy at https://mantrahealth.com/privacy-policy-washington-nevada/.  If we make a material change to how we collect, use, or share consumer health data, we will notify you by email to the address associated with your account and, where required, obtain your consent before the change takes effect.

12. Contact us

Mantra Health, Inc.
Attn: Privacy Officer
c/o Primary Co-working
26 Broadway #356
New York, NY 10004
(240) 307-4648
privacy@mantrahealth.com