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 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. This policy governs access to and use of the Services.
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 to the Services. Depending on the information supplied 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:
The personal information collected on the Services is asked for with the user’s 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 owned by Bloom or a Customer Relationship Management (CRM) system that the user may subscribe to using the Services (Section 2.B.i).
Bloom does use personal information for:
Bloom does not use personal information for:
The following personal information must be provided by the user 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 identify the user uniquely, to personalize their experience on Plugins, and to communicate information with Newsletters they are subscribed to. Additionally, Bloom regularly updates 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. This name is used regularly on the Services to greet the user. The name is not required to be the user's legal name.
i. Device and Connection Information for Third-Party Services
Bloom uses third-party services to assist with the analysis of the 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 access and use 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:
ii. Interactions with News Content
Bloom collects information on how the user is using its Services to view and interact with content ("News Content") provided from a newsroom ("Publisher") who have registered on Bloom.
The purpose of this information is to provide insight into the following:
By utilizing the Services, users can opt-in or opt-out of the processing of non-personal information 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 to enable its processing. By not opting in to the following processes, the user may not be able to access or use certain Service features.
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 or on the same Internet connection.
The purposes for collecting and processing this information include:
ii. Location Information
Geographic location information is collected when accessing and searching for News Content by location on the Website and Services.
Initially, the Services will prompt the user to provide a location by:
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 select a location to view again quickly. 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.
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. Personal user information is only disclosed privately to its user as they are accessing the Website and Services.
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 location, to the CRM of the owner of the Plugin or Newsletter. The owner may either be a registered Publisher or Business Partner 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 associated with the user's information.
When communicating user information to and from CRMs, Bloom requires the CRM's connection to be secure with an active security certificate and modern application programming interface ("API").
Currently, Bloom offers subscription services for the following CRMs:
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 at any time either immediately on the Website or Services, or within a reasonable time by emailing an appropriate representative at Bloom. Update options for personal information include:
Additionally, users have the right to:
Depending on the information available on the user's account, the file may contain the following:
The download feature will retrieve the past three (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.
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:
To opt-out of all processes, but keep their account accessible, users can deactivate their account. This deactivation option will immediately, automatically disable processing for Device and Location History, and Subscriptions. Registered Publishers and Business Partners who choose to deactivate their account will continue to remain in an active state, but will not be able to perform tasks such as geotagging content, displaying plugins, and sending or retrieving content in any other way on Bloom. Any user may reactivate their account at any time, which will revert all processes to their previous state.
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 their Account page.
Immediately after the erasure request is made, personal information stored on Bloom will be erased, and the user will be emailed a confirmation. A representative of Bloom will receive the request and perform the following tasks within 30 days of the request being made:
Alternatively, Bloom may decide to delete personal information, upon the user's consent, if any of the following applies:
This section only applies to users who have or are interested in registering for a Publisher or Business Partner account on Bloom.
To obtain a Publisher or Business Partner account, additional information about the user will need to be provided to verify the user's association with the company. Bloom may request contact information from an applicant and use it solely to confirm the information within their account application.
Users with registered Publishers and Business Partners may update their company information on the Website. The only exception is for company information that has been distributed in a Newsletter email, which becomes inaccessible after the email is sent to subscribers.
If the user wants to disable processing for a particular Publisher or Business Partner, there is an option to immediately deactivate a single entity's account. This action will suspend the processing of their Plugins and Newsletters and will suspend a Publisher's geotagging ability and remove their content from all Services.
Registered Publisher's and Business Partner's consent that their information may be presented and distributed to users on the Services.
News Content includes any text, images, links, or other materials on Bloom provided by registered Publishers and associated with a geographic location. News Content on the Services will always be presented with the company information provided by its Publisher.
The Services use News Content for the purposes of:
News Content is not owned or controlled by Bloom, although Bloom may make recommendations for the News Content to the Publisher. Publishers have control to update or delete their News Content from the Services.
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.
To assist with analytics and comply with potential legal obligations, Bloom stores copies of data from specific points in time. These copies are only accessible to Bloom and authorized legal officers who may receive requested data from Bloom.
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 daily to ensure that the input from users had the intended output. This allows Bloom to look at specific activity in detail and ensure no errors or miscommunication occurred. Logging makes temporary copies of data and is only stored for a maximum of 1 month.
All data on Bloom is backed up regularly. The backups are stored separately from the Services, securely within the United States.
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:
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.
Third-party services (Section 2.A.ii.a.i) may require cookies to be stored on the user's computer based on the user's activity.
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.
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.
If a user finds information harmful or inappropriate on the Services, it is recommended to contact a Bloom representative 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.
Bloom is not suitable for people under the age of 16 years and recommends that people under 16 do not access or view the Services. People between the ages of 16 and 18 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 the supervision of a parent or guardian who will hold responsibility for monitoring the person's use of the Services.
In any case where there is a data breach of the information of users, Publishers, Business Partners, 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 a 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.
Individual users may not be notified if they are not involved with the data breach, where:
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 by notifying users by email or publishing a notice on the Website or Services.