THERAPIST HANDOFF CONSENT AND PROTOCOL
Hunch — operated by CMA Solutions LLP
Document Reference: HUN-LEG-THP-V3.0 Version: 3.0 (Draft for attorney review) Effective Date: [TO BE INSERTED ON VERSION 2 COMMERCIAL LAUNCH] Last Updated: [TO BE INSERTED]
NOTICE — DRAFT INSTRUMENT. This document is a draft prepared for review by qualified Indian legal counsel, with particular reference to the Mental Healthcare Act, 2017 and the Rehabilitation Council of India Code of Professional Conduct. It must not be published, relied upon, or executed in its present form. The Designated Partners of CMA Solutions LLP shall obtain a written opinion from health-law counsel before commercial launch of the Therapist Handoff feature.
RECITALS
A. CMA Solutions LLP ("Company") operates a conversational artificial-intelligence service marketed as "Hunch" (the "Service"). The Service uses Vedic astrology and behavioural-pattern analysis to support self-reflection.
B. In Version 2 of the Service ("Version 2"), the Company facilitates referrals from Users to clinical psychologists and rehabilitation psychologists registered with the Rehabilitation Council of India ("Professionals") through a platform-based directory.
C. The Service is not, and does not hold itself out to be, a Mental Health Establishment ("MHE") as defined in Section 2(p) of the Mental Healthcare Act, 2017 ("MHCA"). The Company does not employ, supervise, control, or direct any Professional in the conduct of professional practice. Professionals exercise independent professional judgment.
D. This Therapist Handoff Consent and Protocol ("Protocol") governs: (i) the consent required from the User in connection with a referral; (ii) the data flow between the Service, the User, and the Professional; (iii) the contractual relationships among the Company, the User, and the Professional; (iv) the commercial arrangements between the Company and Professionals; (v) the User's rights upon withdrawal of consent; (vi) the handling of emergency situations.
1. DEFINITIONS AND INTERPRETATION
1.1 Capitalised terms used and not defined in this Protocol bear the meaning given in the Terms of Service (HUN-LEG-TOS-V3.0) and the Privacy Policy (HUN-LEG-PP-V3.0). In addition:
"Behavioural Brief" — an AI-generated summary, in the form approved by the Company from time to time, of the User's interactions with the Service, comprising recurring topics, self-disclosure patterns, and astrological correlations identified by the Service. The Behavioural Brief does not constitute a clinical assessment, diagnosis, or treatment recommendation.
"Eligible Professional" — a Professional who satisfies the criteria set out in Clause 3.
"Engagement" — the professional engagement between the User and the Professional that arises consequent upon a referral, including consultations, sessions, written communications, and other services agreed between them.
"Handoff" — the process by which the User is connected with a Professional, including the User's authorisation to share the Behavioural Brief.
"Layer 4 Consent" — the specific and informed consent required for a Handoff under Layer 4 of the Consent Framework (HUN-LEG-CF-V3.0).
"Platform Fee" — the periodic flat fee payable by an Eligible Professional to the Company for access to the Service's platform, directory listing, and supporting technology, as described in Clause 8.
"Professional Records" — clinical notes, assessments, treatment plans, and other records generated by the Professional in the course of the Engagement, which are the property of the Professional and governed by the Professional's own retention and confidentiality obligations.
"RCI Code" — the Rehabilitation Council of India Code of Professional Conduct, as in force from time to time.
"Referral Event" — the event by which the Service offers, and the User accepts, the connection to a Professional.
2. SCOPE AND APPLICATION
2.1 This Protocol applies exclusively to Version 2 of the Service and is not operative in Version 1.
2.2 This Protocol applies only where the User has expressly initiated a Handoff or has accepted a Service-initiated suggestion for a Handoff.
2.3 The Handoff is never automatic. A Handoff occurs only upon: (a) the User's express request for a connection with a Professional; or (b) the User's affirmative response to a Service prompt suggesting that the User may benefit from a Professional consultation; in either case, accompanied by Layer 4 Consent given in accordance with this Protocol.
3. ELIGIBILITY OF PROFESSIONALS
3.1 Mandatory criteria. A Professional shall be eligible to receive Handoffs only if the Professional:
(a) holds a current and unrestricted registration with the Rehabilitation Council of India as a clinical psychologist or rehabilitation psychologist;
(b) holds a postgraduate qualification recognised under the Rehabilitation Council of India Act, 1992, and Regulations made thereunder;
(c) has executed a Data Processing Agreement with the Company in the form prescribed by the Company (HUN-LEG-DPA-V3.0);
(d) has executed the Professional Platform Agreement with the Company (HUN-LEG-PPA-V3.0);
(e) has obtained and maintains professional indemnity insurance with coverage of not less than Indian Rupees Twenty-Five Lakhs (INR 25,00,000) per claim;
(f) provides to the Company: (i) a copy of the current RCI registration certificate; (ii) proof of postgraduate qualification; (iii) evidence of in-force professional indemnity insurance; (iv) a self-declaration of fitness to practise; (v) declarations as to any past or pending disciplinary proceedings.
3.2 Verification. The Company shall verify the Professional's RCI registration via the official RCI registry at the time of onboarding and shall re-verify on each renewal cycle.
3.3 Continuing obligations. A Professional shall promptly notify the Company of: (a) any change in RCI registration status; (b) any disciplinary proceeding initiated against the Professional; (c) any lapse in professional indemnity insurance; (d) any conviction for any offence; (e) any direction by a court or regulatory authority restricting the Professional's practice.
3.4 Suspension and removal. The Company may suspend or remove a Professional from the directory: (a) on receipt of credible information bearing on the Professional's eligibility; (b) on receipt of a User complaint warranting investigation; (c) at the Company's discretion in the interest of User safety.
3.5 No employer relationship. Nothing in this Protocol shall constitute the Professional as an employee, agent, or partner of the Company. The Professional is an independent practitioner.
4. INFORMED CONSENT — LAYER 4
4.1 Form of consent. Before any Handoff occurs, the User shall be presented with a plain-language consent notice substantially in the form set out in Schedule 1 to this Protocol, drawn in compliance with: (a) Section 6 of the DPDP Act (specific and informed consent); (b) Rule 5 of the SPDI Rules (consent prior to SPDI processing); (c) Section 22 of the MHCA, to the extent the User may be a person with mental illness (informed consent and right to know information of the nature contemplated by the MHCA).
4.2 Content of consent notice. The consent notice shall, at minimum: (a) identify the Professional by name and RCI registration number; (b) describe the Behavioural Brief to be shared; (c) describe the categories of additional data to be shared (Clause 5.1); (d) describe how the Engagement will proceed; (e) describe the User's right to withdraw consent at any time; (f) describe the User's right to review and edit the Behavioural Brief before transmission; (g) describe the User's right to refuse a particular Professional and to select another; (h) disclose the Company's commercial arrangement with the Professional, in summary form (Clause 8); (i) confirm that the Professional is an independent practitioner and not a Hunch employee; (j) confirm that the Service is not a Mental Health Establishment; (k) describe applicable fees (if any) payable by the User to the Professional; (l) describe applicable emergency-services information (Clause 9).
4.3 Affirmative consent. Consent shall be obtained by the User's affirmative reply (e.g., "YES, CONNECT ME") to the consent notice. Continuation of conversation, silence, or implied conduct shall not be sufficient.
4.4 Recording of consent. Each Layer 4 Consent event shall be recorded with: (a) timestamp (UTC and Indian Standard Time); (b) the version of the consent notice presented; (c) the language in which the notice was presented; (d) the User's affirmative response; (e) the Professional's identifier; (f) hash of the Behavioural Brief at the time of consent.
5. DATA SHARED WITH THE PROFESSIONAL
5.1 Categories of data shared. Upon Layer 4 Consent, the Company shall share with the Professional:
(a) the Behavioural Brief (as reviewed and, if applicable, edited by the User); (b) the User's date, time, and place of birth and computed Kundli (only where the User affirmatively elects); (c) the User's name (or preferred name) as known to the Service; (d) the User's contact identifier for purposes of scheduling the Engagement; (e) the date and time of consent.
5.2 User review and edit. Before transmission, the User shall be presented with the Behavioural Brief and given the opportunity to: (a) read the Behavioural Brief in full; (b) edit, redact, or expand any portion thereof; (c) refuse transmission of the Behavioural Brief, in which case the Handoff may proceed without it (subject to the Professional's acceptance); (d) refuse transmission of the Astrological Data; (e) refuse the proposed Professional and request another.
5.3 Limitations on data shared. The Company shall not share with the Professional: (a) Payment Data; (b) raw Conversation Data beyond that included in the Behavioural Brief; (c) Pseudonymised Data of any other User; (d) any data not necessary for the Engagement.
5.4 Mode of transmission. Data shall be transmitted through a secure channel maintained by the Company, with encryption in transit. Where the Professional accesses the Service's professional portal, role-based access controls shall apply.
6. ROLES AND RELATIONSHIPS
6.1 Tri-party structure. The Handoff gives rise to three distinct relationships:
(a) User and Company. Governed by the Terms of Service and this Protocol. (b) User and Professional. A practitioner-client relationship governed by the RCI Code, the MHCA where applicable, and any engagement letter executed between the User and the Professional. This relationship is independent of the Company. (c) Company and Professional. Governed by the Professional Platform Agreement and the Data Processing Agreement.
6.2 No therapeutic relationship with the Company. Nothing in this Protocol shall create any therapeutic, clinical, fiduciary, or professional-advisory relationship between the User and the Company.
6.3 No control over clinical practice. The Company: (a) does not select the modality of treatment; (b) does not direct the content of any session; (c) does not review or retain Professional Records; (d) does not interfere with the Professional's clinical judgment.
7. EMERGENCY SITUATIONS
7.1 Service is not a crisis service. The Service is not equipped to handle, and shall not be relied upon for, any medical or psychological emergency, including: (a) thoughts of self-harm or suicide; (b) thoughts of harm to others; (c) acute psychotic, manic, or depressive episodes; (d) any other emergent mental-health condition.
7.2 Handoff is not an emergency response. A Handoff to a Professional is a scheduled, non-urgent process. It is not, and shall not be represented to the User as, an emergency-response mechanism. Connections to Professionals may take twenty-four (24) to seventy-two (72) hours or longer.
7.3 Emergency directive. If during conversation the User indicates a state of crisis as described in Clause 7.1, the Service shall: (a) provide the User with the emergency-services information set out in Clause 5.3 of the Terms of Service; (b) discontinue further conversational engagement on the substantive topic; (c) not initiate or continue a Handoff process during the crisis state; (d) log the event in accordance with the Company's safeguarding protocol.
8. COMMERCIAL ARRANGEMENT WITH PROFESSIONALS
8.1 Platform Fee — flat subscription model. Eligible Professionals shall pay to the Company a Platform Fee in consideration of:
(a) inclusion in the Service's directory; (b) access to the Service's professional portal and supporting technology; (c) administrative facilitation of Referral Events.
8.2 Structure of Platform Fee. The Platform Fee shall be:
(a) a flat amount payable on a monthly or annual basis at the Professional's election; (b) not computed by reference to: (i) the number of Handoffs received by the Professional; (ii) the number of sessions conducted by the Professional; (iii) the consultation fee charged by the Professional; (iv) the gross revenue of the Professional; (c) disclosed to the Professional in the Professional Platform Agreement.
8.3 No fee-splitting. The Company affirms, and the Professional warrants, that the Platform Fee is not a fee-splitting arrangement of the kind prohibited under the RCI Code. The Platform Fee is a flat consideration for platform services and does not compensate the Company for referrals.
8.4 Fees payable by the User. The User pays no fee to the Company in connection with the Handoff or the Engagement, save as expressly provided in the Terms of Service or the Refund Policy. The User pays the Professional directly for any session, consultation, or service in accordance with the engagement letter executed between the User and the Professional.
8.5 Disclosure to the User. The User is, at the point of Layer 4 Consent, informed in summary form that the Professional pays a flat platform fee to the Company. The Company shall publish the structure (but not the quantum) of the Platform Fee on the Website at use-hunch.com/legal/therapist-platform.
8.6 No conflict influence. The Company shall not: (a) order the directory in a manner reflecting Platform Fee tier; (b) accept any additional payment from a Professional in consideration of preferential placement in the directory; (c) suppress User complaints in respect of a Professional by reason of the Platform Fee; (d) be financially incentivised to prefer one Professional over another save by reference to objective User-experience metrics.
9. USER FEES AND PAYMENT
9.1 Fees to the Company. As at the Effective Date, the User pays no fee to the Company in respect of the Handoff or the Engagement.
9.2 Fees to the Professional. Fees payable by the User to the Professional are set by the Professional and shall be disclosed to the User in writing before any session. The Company is not a party to such fee arrangements.
9.3 Payment processing. Where the User pays the Professional through any payment facility integrated with the Service, such payment shall be processed by the Payment Processor in accordance with the Privacy Policy and the Refund Policy.
10. WITHDRAWAL OF CONSENT AND DATA DELETION
10.1 Right to withdraw. The User may withdraw Layer 4 Consent at any time by: (a) messaging "STOP SHARING", "WITHDRAW THERAPIST CONSENT", or equivalent terminology to the Service; (b) emailing support@use-hunch.com.
10.2 Effect on Behavioural Brief. Upon withdrawal: (a) the Company shall instruct the Professional to delete the Behavioural Brief and ancillary data within seven (7) calendar days; (b) the Professional shall confirm such deletion to the Company through the professional portal; (c) the Company shall log the deletion confirmation.
10.3 Effect on Professional Records. Professional Records generated during the Engagement remain the property of the Professional and are subject to: (a) the Professional's own retention obligations under the RCI Code and the MHCA (where applicable); (b) the engagement letter between the User and the Professional; (c) the User's separate request to the Professional, exercising statutory rights under MHCA §22 (right to information) and other applicable rights.
The Company shall facilitate communication between the User and the Professional in respect of such records, but shall not direct the Professional's compliance.
10.4 No effect on lawful prior processing. Withdrawal does not invalidate any processing or treatment lawfully undertaken prior to the date of withdrawal.
10.5 Effect on Service access. Withdrawal of Layer 4 Consent does not affect the User's access to the Service.
11. PROFESSIONAL'S OBLIGATIONS UPON HANDOFF
11.1 The Professional shall: (a) treat the Behavioural Brief and all User data as Confidential Information; (b) exercise independent professional judgment, informed but not determined by the Behavioural Brief; (c) clearly inform the User that the Behavioural Brief is AI-generated and may contain inaccuracies; (d) obtain such additional informed consents from the User as required by the RCI Code and the MHCA; (e) maintain Professional Records in accordance with the RCI Code; (f) not redisclose the Behavioural Brief save as required by Applicable Law; (g) on termination of the Engagement, delete the Behavioural Brief and ancillary data (as distinct from Professional Records) within thirty (30) days, in accordance with the Data Processing Agreement.
11.2 The Professional shall not: (a) advertise the Engagement as endorsed by the Company beyond accurate factual reference to platform listing; (b) use the Company's brand or trade marks in any manner not authorised by the Professional Platform Agreement; (c) solicit Users outside the platform in a manner inconsistent with the RCI Code.
12. LIABILITY AND DISCLAIMERS
12.1 Independent acts of the Professional. The Company is not liable for any act, omission, advice, diagnosis, treatment, or outcome of the Professional. The User's recourse in respect of professional malpractice lies against the Professional, with the assistance, where applicable, of the RCI and the Consumer Disputes Redressal Commission.
12.2 Behavioural Brief disclaimer. The Behavioural Brief: (a) is generated by automated systems; (b) may contain errors, omissions, or fabrications; (c) is provided as context only and is not, and shall not be relied upon as, a clinical assessment; (d) does not displace the Professional's independent clinical evaluation.
12.3 Limitation of liability. Without prejudice to the limitations in Clause 11 of the Terms of Service, the Company's aggregate liability arising out of or in connection with a Handoff or Engagement shall not exceed the higher of: (a) the aggregate amount paid by the User to the Company in the twelve (12) months immediately preceding the event giving rise to the claim; or (b) Indian Rupees One Thousand (INR 1,000),
subject to the carve-outs set out in Clause 11.3 of the Terms of Service.
13. GRIEVANCES
13.1 Complaints concerning the Service or the Handoff process. The User may file a grievance under the Grievance Redressal Policy. Complaints concerning the Handoff process shall be investigated within seven (7) calendar days.
13.2 Complaints concerning a Professional. Where the User's complaint concerns the conduct of a Professional: (a) the Company shall acknowledge the complaint within forty-eight (48) hours; (b) the Company shall investigate within seven (7) calendar days; (c) the Company may suspend the Professional from the directory pending investigation; (d) the Company shall offer the User an alternative Professional if appropriate; (e) the Company shall notify the RCI where professional misconduct is reasonably suspected; (f) the User retains the right to file a complaint directly with the RCI and any consumer-protection forum.
13.3 External recourse. Nothing in this Clause 13 precludes the User from approaching: (a) the Rehabilitation Council of India in respect of professional conduct; (b) the appropriate Consumer Disputes Redressal Commission under the Consumer Protection Act, 2019; (c) the Data Protection Board of India in respect of personal-data grievances under the DPDP Act; (d) any court of competent jurisdiction.
14. RECORD-KEEPING
14.1 The Company shall maintain, in respect of each Handoff, an audit record comprising: (a) Layer 4 Consent record (Clause 4.4); (b) the Behavioural Brief as transmitted; (c) the identity of the Professional; (d) date and time of transmission; (e) any subsequent withdrawal event; (f) any grievance arising in connection with the Handoff.
14.2 Such records shall be retained for the longer of: (a) five (5) years from the date of the Handoff; or (b) such longer period as may be required under Applicable Law.
14.3 Records shall be retained in encrypted storage with restricted access, in compliance with Clause 8 of the Privacy Policy.
15. GOVERNING LAW AND DISPUTE RESOLUTION
15.1 This Protocol is governed by the laws of India.
15.2 Disputes between the User and the Company arising out of or in connection with this Protocol shall be resolved in accordance with Clause 15 of the Terms of Service.
15.3 Disputes between the User and the Professional are governed by the engagement letter between them and applicable professional-conduct frameworks.
16. AMENDMENTS
16.1 The Company may amend this Protocol from time to time. Amendments shall be notified in accordance with Clause 16 of the Terms of Service.
16.2 Amendments materially affecting Layer 4 Consent shall require fresh affirmative consent from each existing User in respect of any future Handoff.
17. CONTACT
For questions concerning this Protocol or any Handoff:
CMA Solutions LLP LLPIN: ACP-6029 Email: support@use-hunch.com Telephone: +91 9667674105 Postal address: as set out in the Terms of Service.
SCHEDULE 1 — LAYER 4 CONSENT NOTICE (INDICATIVE FORM)
Note: this form is indicative and must be reviewed and refined by counsel before commercial use.
Connect with a Professional
You're choosing to connect with a licensed psychologist registered with the Rehabilitation Council of India. Before we proceed, here's what you should know:
The Professional: [Name], RCI Registration No. [Number]. Independent practitioner — not a Hunch employee.
What we'll share with them: a written summary of the patterns we've discussed together (the "Behavioural Brief"). You'll see this summary first and can edit, redact, or refuse it. If you wish, we can also share your Kundli — your choice.
What we won't share: your raw conversation history, your payment information, or anything from other Users.
How fees work: you pay the Professional directly for any session. The Professional pays Hunch a flat platform-listing fee to be listed in our directory. Hunch does not take any commission from your sessions.
Your rights: • You may refuse this Professional and ask for another. • You may edit the Behavioural Brief before it's shared. • You may withdraw consent at any time by replying "STOP SHARING" — we'll ask the Professional to delete the Brief within 7 days. • The session is confidential between you and the Professional. Hunch does not see what is said.
What this is not: This connection is not an emergency service. If you are in crisis, please call 112 or Vandrevala Foundation 1860-2662-345. Hunch is not a Mental Health Establishment under the Mental Healthcare Act, 2017.
The Brief is AI-generated. It may contain errors. The Professional will form their own independent assessment.
Reply "YES, CONNECT ME" to proceed. Reply "REVIEW BRIEF" to see the summary first. Reply "NOT NOW" to decline.
SCHEDULE 2 — REVISION HISTORY
| Version | Date | Summary |
|---|---|---|
| 1.0 / 2.0 | 12 / 16 May 2026 | Initial drafts (cumulatively 29 lines; superseded as materially incomplete) |
| 3.0 | [date] | Counsel-ready draft incorporating Audit Memorandum 20 May 2026, Item C-7; flat-fee platform model per Decision G-10; MHCA §22 integration |
END OF THERAPIST HANDOFF CONSENT AND PROTOCOL.
Draft for attorney review. Not legal advice. Not for publication. Health-law opinion required before commercial use.