What's on Your Mind? Exploring Privacy of Mental Health Apps

Abstract

Therapy and life-coaching apps have grown rapidly in number, variety, and popularity. At the same time, their users often share highly sensitive and personal information, including mental health issues, trauma experiences, fantasies, desires, and relationship difficulties. This prompts the need to examine privacy practices across the ecosystem. In this paper, we present a comprehensive analysis of a corpus of 25 popular Android mental health and life-coaching apps, such as Replika and Headspace. It builds on static analysis and dynamic network traffic analysis, coupled with identifying gaps between each app's observed behavior and its privacy policies. Our analysis highlights serious concerns and substantial transparency gaps. First, every app in our corpus embeds at least one tracker SDK not named in its privacy policy, and 85\% of the apps we instrument fail to disclose at least half of the trackers detected in their APKs. Second, more than half of the apps declare several dangerous permissions without corresponding privacy-policy disclosures, including camera or microphone permissions. Third, nearly half the apps disclose third-party AI processing (e.g., via OpenAI, Anthropic, and Groq) in their privacy policies, while several use only generic language (e.g., "AI services"), failing to identify which company receives user data. Overall, our results show that current disclosure practices fall short of the transparency needed for meaningful informed consent. We argue for a significantly updated regulatory framework for therapy apps that more closely aligns with the professional and ethical standards that bind licensed human therapists.