1. PRIVACY STATEMENT
Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (the “Act”) and any other relevant privacy legislation. Bloom respects the privacy of each individual with whom it comes into contact as a user of Bloom. Bloom will not rent or sell any of your personal information to any organization or individual unless you give us permission to do so.
2. PERSONAL INFORMATION
Personal information is information that refers to an individual specifically and that is recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin and credit records but does not include aggregated data from which the identity of an individual cannot be determined. Information about individuals contained in the following documents is not considered personal information:
· public telephone directories, where the subscriber can refuse to be listed;
· professional and business directories available to the public;
· public registries and court records; and
· other publicly available printed and electronic publications.
In order for Bloom to work for all parties, we need to communicate with you. To do this, we require your email address. In order to establish your user account, we also require certain registration data. We may also request additional information to better provide you with Bloom services.
Bloom does not collect any other personal information that you do not expressly provide. If you do not want your personal information collected, do not provide it to us. If you have already submitted the information and would like us to remove it from our records, or you would like to know what information is held in our records or wish to have any of the information updated or modified, please contact us at the address set forth below. Bloom will not disclose your personal information to any third party without your consent, except as detailed below.
3. USE OF PERSONAL INFORMATION
Bloom may use and/or maintain records of your personal information such as your name, address and other registration data, current location, [financial information] and/or other unique personal identifiers, as the case may be, to provide and facilitate use of Bloom.
Bloom identifies the purpose for which your personal information is collected and will be used or disclosed. If that purpose is not listed below, we will do this before or at the time the information is actually being collected. You will be deemed to consent to our use of your personal information for the purpose of:
· communicating with you generally about Bloom and the services provided through Bloom;
· registering/becoming a client with/of Bloom;
· administering and managing Bloom services and our business operations;
· tracking and reporting on your use of Bloom including, without limitation, providing information about your activities to the persons and organizations that you specify during registration (becoming a client) for the purposes of enabling enhanced communication between the parties involved in the process;
· protecting against fraud or error;
· understanding and responding to your needs and preferences, including, but not limited to, communicating with you and to provide you with support and other services;
· providing services requested by you including, without limitation, Bloom services;
· [recommending products and services that we believe will be of interest and provide value to you];
· performing statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of Bloom so as to improve Bloom [and to gather marketing information];
· troubleshooting problems and technical or security issues;
· detecting and protecting against error, fraud or other criminal activity as required by any applicable laws, rules or regulations or governmental requirements;
· complying with legal and governmental requirements; and
· fulfilling any other purpose that would be reasonably apparent to the average person at the time we collect it from you.
· processing payments for Bloom services.
[We may also maintain and use records of such information to send you updates and news about Bloom. If you do not want to receive updates, newsletters or other notifications from us, please let us know by emailing us at the email address set forth below. Alternatively, you can opt out of receiving further communications from us by using the response mechanism in our communications with you.]
Any personal information or content that you voluntarily disclose while using Bloom, which can be viewed by other users thereof, becomes publicly viewable and can be collected and used by others.
Due to the global nature of the Internet, you may be transferring your personal information to countries outside of your jurisdiction of residence, whose legal systems do not offer the same protection for your data as the laws of your jurisdiction of residence.
4. NON-PERSONAL INFORMATION
It is possible that we may also request non-personally identifiable information, like gender, city of residence and age. We may use this data to improve Bloom and/or personalize your experience using Bloom. [This information will only be shared in an aggregate, anonymous form, which means that the information will not contain any personally identifiable information about you or any other person.]
5. USAGE INFORMATION
[In addition to collecting personal and non-personal information, Bloom and our third party service providers may also use a variety of technologies that collect non-personal, aggregated information about the registered users’ use of Bloom. Usage Information may include the browser you are using, the URL that referred you to Bloom, all of the areas within Bloom that you visit, and the time of day, among other information. This information is not personally identifiable and will only be used to find out how its registered users use Bloom. For example, this information may tell us how much time users spend on Bloom. The collection of this information allows us and 3rd parties, among other things, to create new features, prepare for traffic load demands and to efficiently distribute any email communications.]
6. EMAIL COMMUNICATIONS
From time to time we may send you e-mail with information [and/or special offers that we believe would be of interest to you]. All such communications shall be made in full compliance with Canada’s Anti-Spam Legislation. If you do not wish to receive e-mail you can notify Bloom at any time of your preference. [Bloom may use a reputable third party to deliver email. Such third party is under a contractual requirement to keep all personal information confidential and to only use any personal information for the sole purpose of sending you email on behalf of Bloom and to return any personal information once their services are completed.]
7. SHARING INFORMATION
Except with your consent and as set out herein, we will not sell, license, trade or disclose your personal information to or with others.
[We may disclose or share non-personally identifiable information with partners, advertisers or prospective partners or advertisers to help explain our business and the effectiveness of our business or for promotional purposes. For example, we may disclose aggregated demographic information which does not include any personally identifiable information.]
Bloom reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. Bloom also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Bloom or of any of the business or assets or shares of Bloom or a division thereof. Bloom will secure an undertaking from any such third party to treat the disclosed and/or transferred personal information with the same degree of diligence as had been previously provided by Bloom.
8. ACCURACY AND RETENTION OF PERSONAL INFORMATION
Bloom endeavours to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that personal information is inaccurate, incomplete or out of date, we will revise the personal information. We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. [When your personal information is no longer required for Bloom’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.]