Washington Consumer Health Data Privacy Policy
Last updated: October 9, 2026
Legal entity: Zyna Mind Inc.
App name: Zyna: CBT Thought Journal
Contact: privacy@zynamind.com
Policy URL: https://zynamind.com/wa-health-privacy
This Consumer Health Data Privacy Policy applies to Washington State residents and consumers whose consumer health data is processed in Washington, pursuant to the Washington My Health My Data Act (MHMDA). It supplements our general Privacy Policy.
1. Categories of consumer health data we collect
Because MHMDA defines “consumer health data” broadly, data we process that may fall under this classification includes:
- Health conditions, symptoms, or mental health status preferences you choose to log.
- Metadata you associate with journaling (such as emotional intensity) and related self-reported psychological preferences, including when stored inside your encrypted journal / Inbox clinical blob.
- Encrypted journal entries and Inbox content stored as zero-knowledge ciphertext blobs (
ciphertext_payload,iv,auth_tag) when cloud sync is enabled. - AI operation and cost token metrics used for budgeting and free-tier limits. These are not metrics that describe your psychological state.
- Spoon budget values you set on your device are a local preference and are not synced as server-held consumer health data.
2. Sources of consumer health data
We collect this data directly from you when you interact with the app, generate AI reflections you request, or adjust mental health–related preferences within the app settings.
3. Why we collect this data
We collect this data strictly to provide the cognitive behavioral therapy (CBT) reflection services you request, sync your encrypted clinical data across devices when cloud sync is enabled, operate account and preference features, and run transient AI thought analysis via Google Gemini Enterprise when you consent.
4. Categories of third parties we share data with
We do not sell your consumer health data.
We share encrypted data and session data with specific processors to operate the service, including:
- Google Cloud — encrypted hosting (Firestore) and API infrastructure (Cloud Run).
- Google Gemini Enterprise — transient AI processing of text you submit for analysis.
5. Prohibition on geofencing
Zyna Mind Inc. does not implement a geofence around any facility that provides in-person healthcare services for the purpose of identifying, tracking, or collecting consumer health data.
6. Your consumer health data rights
Under MHMDA, you have the right to:
- Confirm whether we are collecting, sharing, or selling your consumer health data.
- Access your consumer health data.
- Withdraw your consent regarding our collection and sharing of your data.
- Request the deletion of your consumer health data.
To exercise these rights, please email privacy@zynamind.com. We will respond to authenticated requests within 45 days. If your request is denied, you may appeal by replying to our denial email.
You may also export your data (JSON) or delete your account in the app under Settings → Data & export, which removes synced server data as described in our Privacy Policy and delete-account instructions.
Contact
Email: privacy@zynamind.com
Company: Zyna Mind Inc.
Mailing address: 2003-2967 Dundas St. W., Toronto, ON M6P 1Z2
This policy describes our current practices under MHMDA. It is not legal advice.