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

Therapy and life-coaching apps have been rapidly growing in number, flavors, and popularity. However, their users routinely share highly sensitive and personal information, such as traumas, fantasies, desires, relationship difficulties, and other mental health concerns. This prompts the need for an empirical analysis of privacy practices in this ecosystem, and particularly the alignment between these apps' privacy policies and their actual behavior. In this paper, we present a comprehensive analysis of 25 popular Android mental health and life-coaching apps, combining static analysis, dynamic network capture, and LLM-assisted privacy policy extraction validated against manual annotation. Our findings highlight serious concerns and substantial transparency gaps. First, every app embeds at least one tracker SDK that its privacy policy does not name, and 68% of apps fail to disclose at least half of the trackers detected in their APKs; Talkie alone embeds 20 while naming none. Second, we identify 16 permission-policy contradictions across 13 apps, i.e., a dangerous permission is declared in the manifest but omitted from the policy, including 6 apps that request camera or microphone access without disclosing photo, video, or audio collection. Third, 48% of apps disclose third-party AI processing (e.g., via OpenAI, Anthropic, Groq), with one app sending journal entries to all three simultaneously, while 7 apps use only generic language that leaves recipients unidentified. Taken together, our findings demonstrate that current disclosure practices fall short of the transparency required for meaningful informed consent. We argue for a significantly updated regulatory framework governing therapy apps in the spirit of the professional and ethical standards that bind licensed human therapists.