Peroya / Promenade LLC

HIPAA Notice of Privacy Practices

Version 1.1 · Effective: 13 AUG 2026

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully. This notice is available in Spanish and English. Patients who prefer other languages may request a translation by contacting [email protected].

1. About This Notice and About Peroya

Promenade LLC operates Peroya, a patient advocacy application. This Notice of Privacy Practices is required by HIPAA and describes how we may use and disclose your Protected Health Information (PHI) and your rights regarding that information.

Peroya operates as a third-party patient application. You authorize Peroya to access your health records from your health plan on your behalf. Your health plan remains the HIPAA covered entity responsible for your records. Promenade LLC acts as your representative under your direction, on your behalf, and with your recorded authorization before any action is taken.

2. Language Access and This Notice

This Notice is provided in Spanish and English. Patients who prefer other languages may request a translated version by contacting [email protected]. Where AI-assisted translation is used for this Notice at a patient's request, a disclosure will accompany the translation.

3. How We May Use and Disclose Your PHI

3.1 Uses to Provide You the Peroya Service

  • Retrieve and display your health records in plain language in your preferred language
  • Track prior authorization status and notify you of changes
  • Help you understand your options after a prior authorization decision, including your right to appeal
  • Prepare advocacy documents you review and authorize us to send on your behalf under your recorded authorization, such as data access requests, appeal letters, and grievance submissions
  • Enable caregivers or family members you have authorized to support your healthcare management

3.2 Patient-Authorized Communications with Health Plans

When you ask Peroya to reach out to your health plan, your authorization is recorded before any action is taken. These communications are made as your representative, carrying out your explicit instruction. You may revoke any authorization at any time within the app.

3.3 Uses and Disclosures Requiring Your Written Authorization

Peroya will not use or disclose psychotherapy notes obtained from your health plan without your separate written authorization, beyond what is necessary to provide you the Peroya service.

3.4 Special Categories of Health Information

Certain categories of health information receive additional protection under federal and Puerto Rico law. Peroya's sensitive service filters ensure these categories are never displayed to parents, caregivers, or other authorized representatives without the patient's explicit consent, regardless of the permissions otherwise granted to that representative.

  • Mental health and substance use records: protected under 42 CFR Part 2 and applicable Puerto Rico law
  • Reproductive health information: protected under minor consent laws; not accessible to parents through Peroya
  • HIV and STI records: subject to additional state and federal restrictions

3.5 Uses Permitted Without Authorization

  • As required by law (court orders, legal process)
  • Public health reporting as required by applicable authorities
  • To avert a serious and imminent threat to health or safety

4. Your HIPAA Rights

4.1 Right to Access Your PHI

You may inspect and obtain a copy of your PHI that Peroya holds. Use the data export feature in the app or contact [email protected]. We will respond within 30 days.

4.2 Right to Request Amendment

If you believe health information Peroya has retrieved on your behalf is inaccurate or incomplete, Peroya will submit a formal correction request to your health plan on your behalf, under your recorded authorization. Your health plan, as the covered entity responsible for your records, will evaluate and respond to the request. Peroya will track the status of your correction request and notify you of the plan's response. To initiate a correction request, use the correction request feature in the app or contact [email protected].

4.3 Right to an Accounting of Disclosures

You may request a list of disclosures of your PHI other than those you authorized. Contact [email protected].

4.4 Right to Request Restrictions

You may request restrictions on how Peroya uses or discloses your PHI. Contact us via email at [email protected].

4.5 Right to Opt Out of the Provider Access API

You may opt out of the Provider Access API feature at any time in Peroya's privacy settings, as established under CMS-0057-F.

4.6 Right to Communications in Your Language

You have the right to receive communications about your health information in a language you understand. Peroya provides Spanish and English as primary languages with professional review. For other languages, contact [email protected] to request a translation.

4.7 Right to Request Archived Records

You have the right to access records of actions taken on your behalf that have been transferred to the archive. If you wish to obtain records that no longer appear in your active history, you may submit a request directly from the app. Go to your profile, select "Privacy and Data," and follow the instructions to submit your archive request.

Peroya will process your request within the thirty-day window required by HIPAA. Requested records will be displayed inside the Peroya app using the screens you already know. The fulfilled request content will remain available for thirty days. Seven days before the expiration date, you will receive a reminder notification. Once thirty days have passed, the delivery content will clear from the server. The underlying records remain permanently in the archive and can be requested again at any time.

5. Retention of Protected Health Information

Health information from your plan: Peroya retrieves your clinical information directly from your health plan under your authorization and presents it within the app. Peroya does not store your clinical records permanently. Your health plan is the source and custodian of those records.

Records of actions taken on your behalf: formal grievances, prior authorization denial appeals, claim denial appeals, and payer-to-payer data transfer requests that Peroya prepares and submits on your behalf constitute protected health information that Peroya retains in its active database for twelve months. Records older than twelve months are automatically transferred to a secure archive in Google BigQuery, with CMEK encryption in the us-east1 region, where they are retained for six years from the date of creation.

Immutability of audit records: all actions taken on your behalf are captured in security audit logs and protected health information access logs. These records are immutable once written, are retained for six years under the HIPAA audit controls provision at 45 CFR 164.312(b), and are not subject to deletion at any stage or in any production environment. Their purpose is to protect your rights as a patient in any regulatory or legal review.

6. Our Obligations

  • Promenade LLC accesses your health plan records solely under your authorization, exercising your federal right to direct your health data to an app of your choosing. We are legally and contractually obligated to protect the privacy and security of any health information we handle, consistent with applicable federal law and our agreements with our infrastructure providers.
  • We are required to provide you this Notice and to follow its terms.
  • We will notify you following any breach of your unsecured PHI as required by 45 CFR §§ 164.400–414.

7. Complaints

If you believe your privacy rights have been violated, you may file a complaint with Promenade LLC or with HHS Office for Civil Rights. You will not be penalized for filing a complaint.

  • Promenade LLC: [email protected]
  • HHS Office for Civil Rights: www.hhs.gov/ocr | 1-800-368-1019

8. Contact

Previous Versions

HIPAA Notice of Privacy Practices v1.0, in effect June 27, 2026 through August 12, 2026: peroya.app/hipaa-v1-0