Privacy Policy

CareCompass is a software service operated by Mindful Me, LLC. In this Privacy Policy, "Mindful Me, LLC," "CareCompass," "we," "us," and "our" refer to Mindful Me, LLC. This Privacy Policy describes what information CareCompass collects from clinicians who use the platform, why we collect it, how we use and protect it, and the choices you have. It will be updated as CareCompass evolves. CareCompass does not make a blanket representation that every workspace or use of the service is HIPAA compliant. PHI may be used only in a workspace CareCompass has explicitly authorized for PHI, and for an external, customer clinician workspace this additionally requires that any applicable Business Associate Agreement (BAA) requirement has been satisfied; see the HIPAA & Health-Data Notice.

1. Information you provide

• Account and profile information: legal name, email address, password (stored only as a hash), professional credentials, and role within your practice.
• Clinician application and licensing information, professional license type, license number, licensing jurisdiction, and any documentation (such as a license image) you upload while applying for clinician access.
• Onboarding responses: the population preferences and onboarding-status responses you provide so we can tailor the product to your practice.
• Policy-acceptance records: a record that you accepted a specific version of the CareCompass policy bundle, together with the acceptance timestamp and limited technical metadata (such as a hashed IP-address representation) used to maintain an immutable audit trail.
• Subscription and billing information: your Stripe customer identifier, subscription identifier, plan, subscription status, and limited billing metadata (such as the last four digits of your payment card and card brand) received from Stripe. CareCompass never receives your full payment card number.
• Clinician-entered content: the clinical-context content you enter into CareCompass, including check-ins, notes, roadmaps, summaries, goals, resources, and similar items. Unless your workspace has been explicitly authorized for PHI, this content must not include PHI or client-identifying information (see §5 below).
• AI-assisted feature inputs and outputs: when you intentionally invoke an AI-assisted feature, the text you submit to that feature and the response generated for it (see §3 below).
• Feedback and support communications: the messages, feedback, and support requests you send to us and their contents.

2. Information collected automatically

• Authentication, MFA, and session information, sign-in events, multi-factor authentication events, trusted-device records, and session identifiers used to keep you signed in.
• Security and audit information: security events, administrative-action audit logs, email-send records, and related integrity data used to detect and investigate abuse.
• Technical data: approximate browser and device characteristics reported by your browser, request timestamps, and technical error logs.
• IP-address handling: the CareCompass policy-acceptance record stores a server-generated hashed representation of the request's first-hop IP address. Mindful Me, LLC does not intentionally store the raw IP address in the policy-acceptance table. Hosting, CDN, authentication, email, security, and infrastructure providers may process or temporarily retain raw IP addresses in operational or security logs under their own terms. We do not represent that every CareCompass security or audit path hashes IP addresses.
• Cookies and browser storage: first-party cookies and browser storage used to keep you signed in, remember trusted devices, and store lightweight interface preferences (see §11).

CareCompass does not currently integrate a third-party product- analytics, session-replay, or advertising provider in production, and does not collect information for advertising purposes.

3. AI-assisted features

External clinical AI processing is not enabled in the current PHI-authorized CareCompass production path. CareCompass does not send PHI from that production path to an external AI provider.

Before any future AI-assisted clinical feature is authorized to process PHI, Mindful Me, LLC will separately review the provider, intended data flow, minimum-necessary use, retention and training-use terms, security controls, and any required Business Associate Agreement. A future AI feature is not authorized for PHI merely because the core CareCompass platform is authorized.

4. Billing information

Subscription payments are processed by Stripe, Inc. CareCompass never receives your full payment card number. Stripe provides us a customer identifier, subscription status, plan, and limited billing metadata (such as the last four digits of your card and its brand) so we can operate your subscription. Stripe's handling of your payment information is governed by Stripe's own privacy policy.

5. Clinical and health-related information

CareCompass is designed to support clinical-context collaboration between clinicians. Unless your workspace has been explicitly authorized for PHI:

• You may not enter PHI or client-identifying information into CareCompass, including inside AI-assisted feature prompts.
• You may enter only initials, non-identifying labels, demonstration information, or properly de-identified content.
• Obtaining client or guardian consent does not authorize a clinician to enter PHI or client-identifying information into a workspace that has not been explicitly authorized for PHI. This prohibition applies regardless of consent.
• Clinical-context information may be sensitive even when it is not PHI and even when it is properly de-identified. The current PHI-authorized production path stores clinical information in encrypted Amazon RDS PostgreSQL within the CareCompass AWS production environment.
• You remain responsible for data minimization and for your professional, ethical, and legal obligations regarding client information.

See the HIPAA & Health-Data Notice for details on PHI-authorization rules, BAA status, and HIPAA-readiness work.

6. Why we use this information

• Provide and maintain accounts: create, secure, and support your CareCompass account.
• Verify clinician eligibility: review clinician applications and licensing information.
• Authenticate users and enforce MFA: sign you in, enforce multi-factor authentication, and remember trusted devices.
• Provide CareCompass features: operate the platform features you use, including collaboration, roadmaps, check-ins, notes, and summaries.
• Process payments and subscriptions: operate subscription billing through Stripe.
• Transactional communications: send approved CareCompass communications. Clinical caregiver/respondent email invitations use Paubox. Caregiver SMS delivery uses Notifyre only after the required text-message consent and authorization checks. CareCompass minimizes message content and uses secure CareCompass links rather than clinical narrative in transactional messages.
• Support: respond to your questions, feedback, and support requests.
• Prevent fraud, abuse, and unauthorized access, detect and investigate misuse, abuse, and security incidents.
• Debug and improve reliability: diagnose errors and improve platform reliability.
• Legal and compliance obligations: comply with applicable law and respond to valid legal process.
• Immutable acceptance and audit records: maintain policy-acceptance and audit records that must be preserved for legal, security, and accountability purposes.

We do not use clinician-entered clinical-context content to train generalized AI models for unrelated customers or purposes, and we do not use it for advertising.

7. Service providers and subprocessors

CareCompass uses third-party service providers to operate the platform. Their handling of information is governed by their applicable agreements, terms, and privacy practices. This list reflects the providers we could confirm from the current production configuration and is not a permanently exhaustive list; providers may change, and we will disclose material changes appropriately.

• Amazon Web Services (AWS): the PHI-authorized clinical production boundary, including application hosting on ECS/Fargate, PostgreSQL data storage in RDS, clinician identity and MFA through Cognito, TLS through Application Load Balancer and Certificate Manager, secrets management, logging/monitoring, configuration history, backups, and container-image storage.
• Paubox: secure transactional email for approved clinical caregiver/respondent invitations. CareCompass minimizes message content and sends the recipient a secure, expiring CareCompass link rather than clinical narrative.
• Stripe, Inc.: payment processing and subscription billing. Stripe is outside the CareCompass clinical-PHI data path described above.
• Notifyre: SMS provider for approved, consented caregiver/respondent text delivery. Production SMS is enabled for this consent-bound path. CareCompass records consent, supports STOP opt-out/revocation, processes delivery callbacks, and does not treat ordinary inbound SMS as a clinical communication channel. Automated weekly SMS delivery remains separately disabled.

8. Selling, advertising, and sharing

• Mindful Me, LLC does not sell your personal information.
• Mindful Me, LLC does not use your personal information for targeted advertising and does not share personal information with third parties for their own advertising purposes.
• We share information with the service providers listed in §7, acting on our behalf to operate the platform, and only for the purposes described in this Policy.
• We may share information with other CareCompass users only where you intentionally share it (for example, invited collaborators within your practice).
• We may disclose information when required by valid legal process or when we reasonably believe disclosure is necessary to protect the rights, safety, or property of CareCompass, our users, or the public, or to investigate fraud or misuse.
• If Mindful Me, LLC is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to appropriate confidentiality protections and any notification required by applicable law.

9. Data retention and deletion

Formal, category-by-category retention schedules remain part of our ongoing HIPAA-readiness work. In the meantime, we apply the following criteria-based retention approach:

• Active account data: retained while your account is active and as needed to operate the service for you.
• Deleted or closed accounts: active platform content is removed or de-associated within a reasonable period after deletion, subject to the exceptions in this section.
• Clinician applications and license uploads, retained as needed to evaluate the application, document eligibility decisions, and support compliance and fraud-prevention reviews.
• Subscription and billing records: retained as needed for accounting, tax, and financial-compliance purposes; some records are retained by Stripe under Stripe's own retention rules.
• Policy-acceptance records: retained on an immutable basis so we can demonstrate which policy version each user accepted and when.
• Security and audit logs: retained on an immutable basis for a period appropriate to their security and compliance purpose.
• Email delivery records: retained by the transactional email provider for a period appropriate to its deliverability and abuse-prevention purpose.
• Provider-side records outside CareCompass's direct control: approved subprocessors may retain operational records under their own agreements and retention practices.
• Backups: infrastructure providers may maintain backups or disaster-recovery copies under their own retention schedules. Deleted information may remain in those backups until the applicable provider retention cycle ends.

Immutable legal, billing, security, and policy-acceptance records may be retained where we have a legitimate legal, fraud-prevention, accounting, or compliance purpose. We do not commit to a fixed retention period we have not yet implemented.

10. Account access, correction, export, and deletion

You may request the following by contacting us at the policy address: andrea@andreagoundrycounseling.com.

• Access to the account information we hold about you.
• Correction of inaccurate profile information.
• An export of information reasonably available to us.
• Account deletion.
• Billing assistance.
• General privacy questions.

We do not currently offer a fully automated self-service export or deletion feature; requests are handled by contacting the policy address above. Deleting your account may not erase records that we must retain for legal, billing, security, fraud-prevention, or audit purposes, or that our subprocessors retain under their own terms.

11. Security

Mindful Me, LLC applies administrative, technical, and physical safeguards designed to protect information, including, where applicable:

• encryption in transit;
• password-based authentication with hashed passwords;
• multi-factor authentication (MFA) for clinician accounts;
• row-level security in the CareCompass database, scoping access to the authenticated user;
• role-based access, including a distinct administrative role;
• server-side authorization for privileged operations, so privileged actions are gated on the server rather than trusted from the browser;
• audit logging of administrative and sensitive actions;
• restricted service-role operations executed only by verified server-side code;
• payment processing delegated to Stripe, so CareCompass does not receive or store full card numbers; and
• periodic security scanning and remediation of the CareCompass codebase and database configuration.

No system can be guaranteed absolutely secure, and we do not represent that CareCompass is HIPAA compliant or holds any certification we have not obtained. You are responsible for protecting your credentials and for promptly reporting any suspected unauthorized activity on your account.

12. Cookies and browser storage

CareCompass uses first-party cookies and browser storage only for functional and security purposes, including:

• Authentication and session cookies: required to keep you signed in;
• MFA and trusted-device state: supports multi-factor authentication and remembers devices you have designated as trusted. Authentication sessions and server-side assurance-level checks determine whether MFA requirements are satisfied. Browser state may support the interface but is not the authoritative security control. MFA may be required again after sign-out, session expiration, revocation, use of a new browser or device, clearing site data, or a security-sensitive event.
• Onboarding and interface preferences: browser storage may contain temporary interface state, tour-step state, dismissed tips, and lightweight preferences. Authoritative onboarding completion, population preference, and tour-completion status are stored server-side in your database record. Clearing browser storage does not erase authoritative onboarding completion, and browser storage is not the authoritative source of authentication, authorization, subscriptions, roles, or entitlements.
• Security-related state: used to detect and mitigate abuse.

These items are necessary for the service to function correctly. CareCompass does not currently use third-party advertising or third-party analytics cookies.

13. Children and client information

CareCompass accounts are intended for adults who are approved clinicians or authorized members of an approved clinical practice. The service is not directed to children for independent account creation, and we do not knowingly permit children to create their own CareCompass accounts. Unless a clinician's workspace has been explicitly authorized for PHI, clinicians may not enter identifying child information or PHI into CareCompass. This Privacy Policy does not replace a clinician's independent responsibility to obtain any required guardian consent or authorization for a workspace's authorized client data. Mindful Me, LLC does not provide therapy and has no direct therapist-client relationship with a clinician's clients.

14. Legal disclosures and business transfers

We may disclose information:

• in response to valid legal process, such as a subpoena, court order, or other lawful request;
• where we reasonably believe disclosure is necessary to protect the rights, safety, or property of CareCompass, its users, or the public;
• to investigate suspected fraud, abuse, or violations of these policies;
• in connection with a business reorganization, financing, merger, acquisition, or sale of assets, subject to appropriate confidentiality protections; and
• where required or permitted by applicable law, including any notifications the law requires us to provide.

We do not claim unrestricted discretion to disclose information for unspecified reasons.

15. Changes to this Privacy Policy

Mindful Me, LLC may update this Privacy Policy. Updates are handled as follows:

• Minor or non-material changes (such as clarifying edits, contact-information updates, or administrative corrections) may become effective after we post the updated policy and update the "Last updated" date.
• Material changes to our data-handling practices will receive appropriate notice, and a new policy-bundle version must be accepted before a new paid Checkout Session can be created.
• Existing users will not be recorded as having accepted a policy version they never actually accepted. The server-side policy-acceptance record remains the authoritative source of which version each user has accepted.

16. Contact

Questions about privacy? The policy contact address is andrea@andreagoundrycounseling.com. The contracting entity is Mindful Me, LLC.