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Legal Stuff


Bloom Privacy Policy

Bloom (hereinafter “Bloom”, “we”, “us” or “our”) considers your personal information to be very important and it should be protected. This Privacy Policy describes how we treat the information we collect for [Bloom] (“Bloom”).  Please take the time to read this Privacy Policy carefully.  This Privacy Policy should be read in conjunction with the terms and conditions contained in the [Terms and Conditions / Terms of Use] (the “Terms of Use”) found at All capitalized terms used herein not otherwise defined shall have the meanings ascribed to them in the Terms of Use.

By using Bloom or otherwise providing us with your personal information, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time, and agreeing to our collection and use of your personal information in accordance with this Privacy Policy. If you do not agree to the collection, use and disclosure of your personal information in this way, please do not use Bloom or otherwise provide Bloom with your personal information.



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.



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.

We are responsible for all personal information under our control, including any personal information that we transfer to third parties for processing, storage [or other purposes]. The activities of third parties that provide services to us or that you link to through your use of Bloom, or that may collect information about you themselves or that we may share your information with in accordance with this Privacy Policy are governed by the respective privacy policies of those third parties.

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.



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.



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.]



[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.]  



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.]



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 may disclose personal information to third party providers of Bloom, including third parties engaged to assist us in providing Bloom services (including but not limited to software development and hosting, data processing, transaction processing services, document management and office administration) to you or to carry out one or more of the uses described above. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by Bloom and to comply with the general privacy principles described in this Privacy Policy.

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.



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.]



We use physical, electronic, and administrative safeguards to assist us in preventing unauthorized access, maintaining data accuracy, and correctly using your personal information. Except as specified in this Privacy Policy, we use commercially reasonable efforts to limit access to your personal information to the employees, agents, and officers of Bloom on a need-to-know basis.



Bloom reserves the right to make changes to this Privacy Policy from time to time by posting the updated version of this Policy [by emailing a copy of the updated Privacy Policy to you / to]. In such a case, we will update the effective date of the updated version of this Privacy Policy. You may find the current effective date at the bottom of this Privacy Policy. You are bound by any changes to this Privacy Policy when you use Bloom after such changes have been first posted.



If you wish to know what information we have in our files about you, ask a question about the information in your file or request a change to the information in your file, or have any questions regarding this Privacy Policy, please contact us here:



Kitchener, On


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