Peroya / Promenade LLC
Version 1.0 · Effective 27 JUN 2026
Promenade LLC ("Promenade," "we," "our," or "us") is a technology company based in Caguas, Puerto Rico. We operate Peroya (peroya.app), a patient advocacy application that helps people access, understand, and act on their health information.
Peroya is not a health plan, health insurer, healthcare provider, or licensed clinical professional. We do not provide medical or legal advice, diagnose conditions, or make coverage decisions. We build tools that help patients work more effectively within the healthcare system they already belong to.
This Privacy Policy applies to the Peroya mobile application and the peroya.app website. It applies to all users regardless of their preferred language. Where Peroya provides content in languages other than Spanish and English through AI-assisted translation, this policy applies equally.
The Spanish and English versions of this policy have been reviewed by qualified personnel. Translations into other languages provided upon request may be AI-assisted and will be identified as such.
When you connect a health plan to Peroya and authorize us to act on your behalf, we retrieve your health records from that plan's secure digital connection. This data may include claims and encounter records, prior authorization requests and status, diagnoses, conditions, and medications, provider and facility information, and laboratory results and clinical notes where available from your plan.
This health information is Protected Health Information (PHI) under HIPAA. See Section 6 and our HIPAA Notice of Privacy Practices at peroya.app/hipaa for full detail.
When you ask Peroya to contact your health plan on your behalf, to request data access, submit an appeal, or file a grievance, we record your authorization before taking any action. That authorization is logged with a timestamp and accessible to you in the app at all times. Peroya acts as your representative, not independently.
Peroya provides health information in Spanish and English as primary languages. These translations are human-curated and professionally reviewed. For patients who prefer other languages, Peroya offers AI-assisted translation. When you receive content through AI-assisted translation, a disclosure is displayed in your selected language. We use your language preference to deliver content in the most useful form for you, and we use aggregated language preference data to prioritize which languages to add as professionally reviewed options.
Some Peroya features use artificial intelligence to generate plain-language health summaries, draft appeal letters, and provide prior authorization guidance. For these features, only the minimum necessary clinical information, such as diagnosis codes and medication codes, is used. Your name, date of birth, address, and member ID are not included. AI-generated content is reviewed by you before it is used or sent.
Peroya accesses your health plan records solely under your authorization, exercising your federal right to direct your health data to an app of your choosing under 45 CFR § 164.524. Your health plan remains the HIPAA covered entity responsible for maintaining and protecting your original records. Peroya holds a copy of those records for the sole purpose of displaying them to you and acting on your instructions.
We have signed a Business Associate Agreement with Google Cloud Platform, our cloud infrastructure provider, which governs how your health data is stored and protected on our systems. All health data is encrypted at rest (AES-256) and in transit (TLS 1.3).
For your full rights under HIPAA and how we handle protected health information, see peroya.app/hipaa.
We share data with service providers only as necessary to operate Peroya, under written data processing agreements:
When you direct Peroya to contact your health plan on your behalf, we share only the information necessary to fulfill that request, under your explicit recorded instruction.
If you authorize a caregiver or family member to access your account, that person will see your health data within the permissions you set. You can adjust or revoke access at any time.
Peroya serves patients of all ages. Parents and legal guardians may access minor children's health records through Peroya subject to applicable HIPAA and Puerto Rico law. Certain health services, including mental health, substance use, reproductive health, and STI treatment, are protected under minor consent laws and are not accessible to parents through Peroya. Emancipated minors receive fully independent accounts. See peroya.app/hipaa for detail.
We will notify registered users of material changes by email and post an updated version at peroya.app/privacy with a new effective date.