Pronoia Performance, LLC – HIPAA Notice of Privacy Practices

Effective Date: June 1, 2025
Applies To: Pronoia Performance, LLC (“PP,” “we,” “our,” “us”) in its role as a Management Services Organization (Business Associate) providing administrative services to Mindful Medicine, PC (“MM”), the licensed medical practice and covered entity responsible for your clinical care.

Your rights

You have the right to

Right

How to Exercise

Get a copy of your medical record

Submit a written request (mail or email) to PP’s Privacy Officer. We will provide a paper or electronic copy within 30 days

Ask us to correct your record

Same method. We may deny if inaccurate or incomplete information was not created by us; you may add a statement of disagreement.

Request confidential communications

You may ask that we contact you at a different mailing address, phone number, or via secure portal only.

Request a restriction on uses of discolosures

We will honor reasonable requests; we are not required to agree to all restrictions (except for self-paid services under 45 CFR §164.522(a)(1)(vi)).

Get a list of disclosures

Receive an “accounting of disclosures” for the prior 6 years, excluding routine treatment, payment, and health-care-operations uses.

Choose someone to act for you

If you have given someone medical power of attorney or they are your legal guardian, that person can exercise your rights.

File a complaint

See “Complaints” section below; you will not be retaliated against.

Our Uses and Disclosures

We typically use or share your Protected Health Information (“PHI”):

Purpose

Example

Treatment (on MM’s behalf)

Scheduling visits, coordinating with MM’s clinicians, or reminding you of lab appointments.

Payment

Managing subscription invoices, collecting card payments, and transmitting payment data to MM.

Health-Care Operations

Quality assessment, customer-service training, legal/compliance audits, and IT security.

Text Messages & Unsecured Email

We may send appointment reminders or administrative messages by SMS or unencrypted email without PHI. You may opt out or request alternative methods at any time.

We may also share your information for:

Category

Conditions

Business Associates

Vendors performing services for us under a HIPAA-compliant agreement (e.g., U.S.-based cloud hosting).

Public Health & Safety

Reporting adverse events if required by law, preventing serious threats to health or safety.

Legal / Law Enforcement

Court orders, subpoenas, or as otherwise required by federal or Colorado law.

We never sell your PHI or use it for marketing without your written authorization.
Uses and disclosures not listed here will be made only with your written permission, and you may revoke that permission at any time.

Our Responsibilities

  • Maintain the privacy and security of your PHI in accordance with HIPAA and Colorado law.

  • Provide you with this notice and abide by its terms.

  • Notify you without unreasonable delay if a breach compromises the security or privacy of your PHI.

  • Not use or disclose genetic, psychotherapy, or substance-use treatment notes except as permitted by 45 CFR §164.508.

We reserve the right to change this notice and the revised version will apply to all PHI we maintain. A current copy will always be available on https://pronoiaperformance.com/privacy and by request.

Contact Information

Privacy Officer: Devlon Haase
Mailing Address: 1942 Broadway St, Suite 314C, Boulder, CO 80302
Telephone: (720) 414-3515
Email: [Privacy-Officer-Email]

Complaints

If you believe your privacy rights have been violated, you may file a complaint with:

  1. Pronoia Performance Privacy Officer (contact above), or

  2. U.S. Department of Health & Human Services, Office for Civil Rights
    200 Independence Avenue SW, Washington, DC 20201
    Phone: (800) 537-7697 | Online: https://ocrportal.hhs.gov

You will not be penalized or retaliated against for filing a complaint.

Acknowledgment

We will ask you to sign a separate form acknowledging receipt of this Notice.
If you decline, we will document our good-faith effort to provide it.

For Colorado Residents

Pronoia Performance currently provides management services solely for patients located in Colorado. Colorado law affords you the same or greater privacy protections as federal law; where state law is more stringent, we follow state requirements.

This Notice is issued jointly by Pronoia Performance, LLC (Business Associate) and Mindful Medicine, PC (Covered Entity). For clinical questions, please contact Mindful Medicine directly.

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