Privacy Policy

Last updated: May 24, 2018

This Privacy Policy describes the type of data gathered on Bloom, how the data is processed, details about account and data limitations, and how to contact Bloom about the policy. It is required to read and agree to this policy before proceeding to access and use Bloom.

1. Introduction

This Privacy Policy describes the types of data gathered by Bloom from its users and how that information is used on https://www.bloom.li ("Website") and distribution services ("Plugins" or "Newsletters"), referred to altogether as "Services".

This policy should be read and agreed to before accessing the Services. The agreement is made by Bloom and you, the user, ("you", "user"). By accessing and using with the Services, you explicitly confirm that you have read, understand and agree to be bound by this policy. If you do not wish to be bound by this policy, do not access or use the Services. Bloom and its subsidiaries and affiliates ("Bloom") provide you with access to the Services as specifically indicated herein. Access to and use of the Services is governed by this policy.

2. User Information

A. Collection and Processing of User Information

The Services may use the following personal information separately or combined, such as for grouping or profiling, to provide the user with personalized features and access on the Services. Depending on the amount of information provided by the user or consented to collect from the user, the Services may be limited to offering the user certain features.

This section is split into two main sections:

  • Personal Identifying Information: Describes a unique, natural person.
  • Non-Personal Information: Association to a person in a non-personal manner.
i. Personal Identifying Information

The personal information collected on the Services is asked for the user to provide at their own consent and does not obligate the user to provide this information. The Services prompt the user for personal information when the user requests registration for a Website account, Plugin subscription, and Newsletter subscription.

The personal information is only stored in secure databases within the United States that are owned either by Bloom or CRM's that the user may subscribe to using the Services (Section 2.B.i).

Bloom does use personal information for:

  • Authorization and Security: To authorize access to the account using personal information only known and accessible to the user.
  • Communication: To send information to the user.
  • Greeting: To label the account and provide personal greetings by name.

Bloom does not use personal information for:

  • Advertising: Bloom does not offer or engage in advertising.
  • Sale: Personal information is not made accessible to third-parties for purchase.
  • Publicizing: Personal information is kept private and is only accessible to the user on the Services. An exception may be that the user has authorized Bloom to communicate the personal information to a third-party (Section 2.B.i).
a. Required Personal Information

The following personal information must be provided from the user in order to access certain Services.

Email Address: To become a registered user of the Website or subscriber of a Plugin or Newsletter, the user must confirm their identity with an email address. The purpose of the email address is to uniquely identify the user, to personalize their experience on Plugins, and to communicate information with Newsletters they are subscribed to. Additionally, Bloom regularly makes updates for its Services and offers an internal newsletter where the user's email address is used to communicate the information.

Name: The user must provide a single name to label their account with. This name is used regularly on the Services to greet the user. The name may or may not be the user's personal legal name.

ii. Non-Personal Information
a. Required Non-Personal Information

i. Device and Connection Information for Third-Party Services

Bloom uses third-party services to assist with the analysis of usage of Bloom's Services. These third-party services only collect non-personal information about the user's device, connection, and behaviors while using Bloom's Services.

The third-party services used and their privacy policies include:

The purpose of these third-party services is to provide Bloom with analysis on how users are accessing and using specific features on the Services. Bloom uses this insight to help make decisions to improve the Services.

The following information may be collected by the third-party service:

  • URLs accessed
  • Referral URLs
  • IP address
  • Operating system, device type, and web browser
  • Date and time of visit
  • Length of visit

2. Interactions with News Content

While using the Services that present News Content, Bloom collects information on how the user is interacting with the content. Currently, Bloom only collects the information if the user has clicked a particular News Content on any of the Services.

The purpose of this information is to provide insight for the following:

  • User: To view the News Content they have interacted with and to view recommendations for other News Content related to their interactions.
  • Publisher: To view a non-personal summary of the users who have interacted with their News Content on the Website, Plugins, and Newsletters.
  • Host: To view a non-personal summary of the users who have interacted with News Content on their Plugins or Newsletters.
  • Bloom: To view or analyze interactions happening on News Content and the Services to help improve the Services, to recommend News Content to Users, and to provide insights to Publishers and Hosts.
b. Optional Non-Personal Information

By utilizing the Services, users have the option to opt-in or opt-out of the processing of non-personal information that is associated with their account. As of May 24, 2018, these settings are turned off by default for new users and require the user to manually opt-in in order to enable its processing. By not opting-in to the following processes, the user may not be able to access or use certain features of the Services.

i. Device and Internet Connection Information

Upon entry to the Services, information is collected about the device and Internet connection being used. This information includes details about the web browser, operating system, device type, and IP address of the Internet connection. This information is not unique to the user, their device, or their connection as more than one user may access the Services with the same type of device and/or on the same Internet connection.

The purposes for collecting and processing this information include:

  • Analytics: Identifying how certain devices and connections are using the Services and, perhaps, if they are limited due to restrictions of the device or connection. With this insight, Bloom is able to make decisions to improve the Services for the given device or connection.
  • Security: Identifying if a user's account is attempting to be accessed by an unexpected device or connection. In the case that an unexpected device or connection is recognized, Bloom may contact the user by email address to verify authorization.

2. Location Information

Geographic location information is collected when accessing and searching for News Content by location on the Services, such as the Website's interactive map and Local Search Plugin.

Initially, the Services will prompt the user to provide a location by:

  • Geolocation: Precise current location provided by the web browser. This option is only available if the website that embeds the Service has a secure connection and if the user has provided consent for the browser to obtain the location.
  • IP Address: Estimated location provided by the Internet connection.
  • Custom: Any location typed or clicked.

The purpose of associating this information to a user's account is to populate their browsing history to show where they have browsed News Content and allow them to quickly select a location to view again. The Services may analyze the location history to determine the user's preferred locations and adjust recommendations for the user accordingly. The user may be recommended News Content from a local Publisher or opportunities to subscribe to Newsletters nearby.

B. Distribution of User Information

User information may be made accessible to third-party services if the user provides consent. Bloom does not disclose or distribute any user information to third-parties without consent from the user.

User information is not displayed publicly or privately to other users on the Services. User information is only disclosed privately to its user as they are accessing the Services.

i. User Subscriptions to CRMs

The only distribution of user information made available on Bloom to third-party services is with subscriptions. If a user decides to subscribe to a Plugin or Newsletter, they are providing consent for Bloom to communicate personal information, such as email, and non-personal information, such as preferred location, to the CRM of the owner of the Plugin or Newsletter. The owner may either be a registered Publisher or Host on Bloom. The CRM will then have a copy of the user information and the owner can offer their services to the user based on the preferences provided.

When communicating user information to and from CRMs, Bloom requires the CRM's connection to be secure with a security certificate and modern API mechanisms.

On the subscription form, Bloom provides information about the CRM and a link to their privacy policy for the user to review. By subscribing, the user's consent states that they have read and agreed to the privacy policy of the CRM.

Currently, Bloom offers subscription services for the following CRMs:

C. Rights to Personal Information

Registered users of the Website who have provided personal information have full access and control to their personal information. Each user has the right to change or delete the information immediately at any time, including:

  • Update personal information, such as name and email address.
  • Update or disable non-personal information associated with their account, such as subscriptions, connection history, or location history.
  • Download personal information and non-personal information associated with their account. (Section 2.D)
  • Withdraw from processing personal information by updating privacy settings or deactivating their account. (Section 2.E)
  • Erase their personal information and terminate their account permanently. (Section 2.F)

Additionally, users have the right to:

  • Contact Bloom to help retrieve, question, or analyze certain personal or non-personal information associated with their account.
  • Lodge a complaint with a supervisory authority in regards to how Bloom is collecting or processing personal information.

D. Downloading of User Information

To respect data portability, Bloom has made it easy for each user to immediately download their personal and non-personal information associated with their account. Users can download the data into a JSON file, or JavaScript Object Notation, which is a human- and machine-readable format. The download option can be used while the user is logged into Bloom by visiting the Manage Account page.

Depending on the information available on the user's account, the file may contain the following:

  • Personal Information: Name and email address
  • Connection History: IP Addresses and devices that the user's account is associated with
  • Location History*: Locations that the user has visited and subscribed to on Bloom
  • Subscriptions: Personalized newsletters provided by Bloom that the user is subscribed to
  • Account Actions*: Activity that the user has performed on Bloom, such as logins, account updates, content interactions

Currently, the download feature will retrieve the past 3 months of time-sensitive activity (marked with asterisks * in the list above). To retrieve data from an earlier date, the user must make the request to Bloom directly by email. Depending on the type of request, the user will receive the personal information file within 30 days after the request is made.

E. Withdrawal of User Information Processing

Each user has control over the processing of their personal and non-personal information associated with their account, and can opt-in or opt-out of such processing immediately at any time by doing the following:

Opting-out of individual processes:

  • Device and Location History: Each user has access to a Privacy Settings page on the Website that lists two options for processing device/connection and location history. Users can update these settings on this page themselves.
  • Subscriptions: Users who have subscribed to newsletters hosted or processed by Bloom will see two options to update the subscription criteria or unsubscribe. The user can choose either of these options from the Subscriptions page on the Website or they may unsubscribe directly in the newsletter email by clicking the "Unsubscribe" link.
  • Publishers and Hosts: As mentioned in Section 3.A, users who have registered Publishers or Hosts on Bloom have an option to deactivate the accounts individually.

To opt-out of all processes, but keep their account accessible, users have the option to deactivate their account. This deactivation option will immediately, automatically disable processing for Device and Location History, and Subscriptions. Registered Publishers and Hosts will continue to remain in active state but will not able able to perform tasks such as geotagging content, displaying plugins, and sending or retrieving content in any other way on Bloom. Users may reactivate their account at any time, where all processes will be reverted to their previous state.

F. Erasure of User Information

Each user has the ability to terminate their account by requesting to erase their personal information and non-personal information associated with their account. This erasure option can be used while the user is logged into Bloom by visiting the Manage Account page.

Once this is requested, personal information stored on Bloom will be immediately erased and the user will be emailed a confirmation. Bloom's staff will receive the request and perform the following tasks within 30 days of the request being made:

  • Determine user subscriptions to third-party CRMs that use Bloom and contact the owner of the CRMs to delete the user's information. An exception may be made if the user is subscribed to a non-Bloom newsletter in a CRM that requires their information to be kept.
  • Suspend associated Publisher accounts
  • Suspend associated Host accounts
  • Delete personal information from offline backup files

Alternatively, Bloom may decide to delete personal information, upon the user's consent, if any of the following applies:

  • Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • Personal data have been determined to be unlawfully processed
  • Personal data have been determined to be erased for compliance with a legal obligation of Bloom

3. Company Information

This section only applies to users who have or are interested in registering for a Publisher or Host account on Bloom.

A. Collection of Company Information

In order to obtain a Publisher or Host account, additional information about the user will need to be provided to verify the user's association with the company. Bloom staff may request contact information from an applicant and will use that information solely for the purpose of confirming the information within their application.

  • Publishers: There are specific Publisher requirements listed on the Website that point out the additional information sought from an applicant. If this information is not publicly and easily accessible, the applicant may be contacted to provide the information.
  • Hosts: The only specific requirements for Hosts are an email address, company name, and company website URL. Additionally, since Hosts may embed Plugins or use Newsletters, it may be required to get more information on how the Host will use these Services. If it is not obvious to Bloom, the applicant may be contacted to provide the information.

Users with registered Publishers and Hosts may update their company information on the Website. The only exception is for company information that was distributed in a Newsletter email, which becomes inaccessible after the email is sent to subscribers.

If the user would like to disable processing for a particular Publisher or Host, there is an option to immediately deactivate a single entity's account. This action will suspend their Plugins and Newsletters, and will suspend a Publisher's geotagging ability and remove their content from all Services.

B. Presentation and Distribution of Publisher Information

A registered Publisher that geotags News Content on Bloom consents that their content will be presented and distributed to users on the Services. To respect the Publisher's brand, the News Content will always be presented alongside company information provided by its Publisher.

4. News Content

News Content includes any text, images, links, or other materials provided by registered Publishers to associate with a geographic location on Bloom. News Content on the Services will always be presented alongside company information provided by its Publisher.

The Services use News Content for the purposes of:

  • Distributing to users accessing the Services
  • Generating reports for analytical purposes, including combining News Content data to determine patterns, insights, and trends across locations, times, and categories.

New Content is not owned or controlled by Bloom, although, recommendations may be made to the Publisher during the geotagging process. The Publisher of the News Content has control over whether to update or delete the content from the Services.

Depending on the information and context provided, News Content may contain text, images, or links that may seem inappropriate to users. Bloom's Privacy Policy does not apply to the websites linked in News Content and, therefore, Bloom encourages users to be aware of the privacy policies of any linked website.

A. Social Media Sharing

The Website uses various links to third-party websites that allow users to share News Content provided by Bloom. These third-party websites' privacy policies govern the collection and use of the information collected on those websites.

5. Data Retention

To assist with analytics and comply with potential legal obligations, Bloom stores copies of data from certain points in time. These copies are only made accessible to Bloom's staff and authorized legal officers who may receive certain requested data from Bloom's staff.

A. Data Logging

For the purposes of internally analyzing activity from registered users, certain Services have an internal logging tool that makes a copy of certain data, separate from databases. The logging and analysis are performed on a daily basis to ensure that the input from users had the intended output. This allows Bloom to look at certain activity in detail and ensure no errors or miscommunication occurred.

Logging makes temporary copies of data and are only stored for a maximum of 1 month. The logging tool is a temporary solution that may be replaced with more efficient internal analytics tools in the future.

B. Data Backups

All data on Bloom is backed up on a regular basis. These backups are kept for approximately 6 months until they are deleted. The backups are stored separately from the Services, within the United States.

6. Disclosure of Information

Bloom does not share, rent or sell personal information with other people or companies without the consent of the user (Section 2.B.i). Bloom reserves the right to disclose any non-personal information that may be collected. Bloom may also release personal information when believed that doing so is appropriate:

  • To comply with the law (for example, to respond to a lawful subpoena, warrant or court order)
  • To enforce or apply the policy
  • To initiate, render, bill, and collect for amounts owed to Bloom
  • To protect the company rights or property
  • To protect the users from fraudulent, abusive or unlawful use of the Services, or
  • If reasonably believed that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

The Services and all collected information about the users are business assets of Bloom. Consequently, information about users, including personal information, will be disclosed as part of any merger or acquisition, sale or pledge of company assets, or in the creation of a separate business to provide the Services or to fulfill products, as well as in the event of an insolvency, bankruptcy or receivership.

7. Cookies

Bloom only stores cookies for registered users who are logged in and have checked the checkbox to allow them to stay logged in. If the user is not logged in to the Services, cookies from the Services will not be stored on their computer. Bloom uses cookies specifically to understand how users use the Services and to help improve the Services based on the analytical reports.

Third-party services (Section 2.A.ii.a.i) may require cookies to be stored on the user's computer based on the activity performed by the user.

Users may refuse to accept a cookie from the Services and third-party services entirely by following the procedures in their web browser. However, refusing to accept cookies may affect their experience using the Services.

8. Security

Bloom has implemented security measures in the Services to protect against the loss, misuse and alteration of the collected information. However, Bloom cannot guarantee the protection of information against interception, misappropriation, misuse or alteration, or that the user's information may be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

9. Erasure of Information

As explained in User Information (Section 2.F) and News Content (Section 4), Bloom has options available for users and registered Publishers to remove certain information from their account.

If a user finds information harmful or inappropriate on the Services, it is recommended to contact Bloom's staff to bring the information to their attention. Bloom's staff may update the status of the particular information if agreed to be harmful or inappropriate.

10. Information about children

Bloom is not suitable for people under the age of 16 years and recommends people under the age of 16 to not access or view the Services. People between the age of 16 and 18 years may view the Services, but may not register for a user account. If under the age of 18 and would like to register for a user account, the person must be under supervision of a parent or guardian who will hold responsibility for monitoring the person's use of the Services.

11. Data Breach

In any case where there is a data breach of the information of users, Publishers, Hosts, or News Content, Bloom will notify the users involved as soon as possible, within 72 hours after becoming aware of the situation. The data breach may include a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the information. Bloom will keep thorough record of data breaches that may occur, including the information involved, their effects, and actions taken to resolve the breach. This record will be made available to the users involved.

Certain users may not be notified if they are not involved with the data breach, where:

  • Bloom has implemented appropriate technical and organizational measures that render the user's personal information unintelligible to anyone not authorized to access it, such as encryption, or
  • Bloom has taken subsequent measures to ensure that a high risk to the user is not possible to materialize.

12. Policy Changes

Bloom reserves the right to change this policy should it be deemed advisable to do so. If any significant changes are made that affect the use or disclosure of personal information, Bloom will make reasonable efforts to notify all users of the changes either by notifying users by email or publishing a notice on the Services.

13. How to Contact Bloom

If you have any questions regarding this policy, please contact Bloom by email at .

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