Effective Date / Last Updated: June 17, 2022
What Information We Collect
We collect a variety of information to provide our Services and operate our business, including personal information. This information includes the following:
Information we receive directly from you: This includes both information you provide to our Services or our Site. For example, we collect the following information:
Information we automatically collect from you: When you visit our Site or use our Services, we automatically collect aggregate information on what pages you visit, how your mouse moves, how you use our Site and/or Services, whether you read emails we send you, and your general geographic location, as indicated by your IP address and other technical connection information.
Information we collect from our customers: We collect various information from our business customers, which include email addresses of the users they wish to enroll in their subscribed Services and any personal information contained within the training. Our customers are primarily employers, who then extend access to our Services to their employees. We do not have control and are not responsible over the specific contents of the trainings offered by our customers.
Information we collect from third-party sources: Advertisers, application providers, and other third parties provide us information in connection with tools we offer and through tools they use to collect information about you when you use our Services. The information they collect may be associated with your personal information and they may collect information about your online activities over time. They may use this collected information to provide you with interest-based advertising or other targeted content.
Please note that other parties may collect personally identifiable information about your online activities over time and across third-party websites when you use our website or services. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.
How We Use Your Information
We may use the personal information we collect for a variety of purposes, including the following:
Please note that we may combine information we gather about you from different sources in order to accomplish any of the above tasks.
How We Disclose Your Information
Bloomfire may share the personal information we collect to support our Services or as permitted or required by applicable law, or as directly authorized by you. For example, we may disclose your personal information to:
Sweepstakes, Promotions, and Contests
We occasionally offer promotions in the form of gift cards and gift card raffles, in return for participation in surveys, visiting the Site, and etc. The specific terms of a promotion are provided in that promotion. You have the right to withdraw from any promotion or contest we offer at any time.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary by browser and version. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will be unable to use some of the features on our Site and Services.
Cybersecurity and Destruction of Your Personal Information
Bloomfire strives to protect your personal information. We use technical measures designed to protect your information such as encryption to protect your personal information, particularly your payment details. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot warrant the security of any information you transmit to us.
Personal Information of Legal Minors
Our Site and Services are only intended and designed for use by adults over the age of eighteen years old. If you are a parent or guardian of a legal minor who has discovered that your minor child has been using the Site and/or the Services, please inform us using the contact information below.
International Transfer of Personal Data
Although we have offices and hosting facilities located in the United States of America, we do not, to the best of our knowledge, transfer personal information collected and used on our Services into the United States from the European Union or Canada. We currently separately host our Services in the European Union and Canada for customers located in those jurisdictions.
Please note that, where our customers are transferring data across international borders, they are responsible for ensuring that those data transfers are subject to an adequate level of data protection. For more details on a specific customer’s international data transfer practices, please consult that customer’s relevant privacy notice(s).
Please note that our Site is hosted in the United States.
Opt-Out of Marketing Emails
If you wish to opt-out of our marketing emails, you can easily unsubscribe using the ‘unsubscribe’ or ‘opt-out’ links found at or near the bottom of the marketing email or by contacting us at firstname.lastname@example.org. Please note that we may still use your email address for non-marketing or administrative purposes (such as notifying you of major system updates, customer service needs, or items for which you have requested communication).
Changes to this Policy
If you have questions or concerns regarding the security or privacy of your personal information, please use the contact information below:
Data Protection Officer
1717 W. 6th St. Suite 100
Austin, TX 78703
California Privacy Notice
The following privacy notice applies to residents of the US state of California.
The table below identifies the categories of personal information that we have collected about consumers in the prior 12 months, as well as how we have disclosed such information for a business purpose. Please note that we do not control data collection or use by customers who use our platform. For details on a specific customer’s practices regarding personal information submitted to our platform, please consult that customer’s privacy notice.
|Category under the California Consumer Privacy Act||Specific Description||Disclosed for a Business Purpose in the Last 12 Months|
|Yes/No||Categories of Third Parties|
|Identifiers||Your name and email address, survey responses, and any personal information contained within trainings submitted by our customers to our Services.||Yes||Sales and Marketing Tool, Data Storage Service Provider|
|Customer records||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information.||No||–|
|Protected classifications||Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No||–|
|Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No||–|
|Usage data||Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. Page views, mouse movements, site visits before and after our Services, email open rate, and other usage information (in aggregate); IP address and other, related connection information.||Yes||Sales and Marketing Tool, Ad Network, Data Analytics Provider|
|Sensory data, such as audio, video and electronic data||Includes audio, electronic, visual, thermal, olfactory, or similar information, such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices for health and safety purposes), photographs and images (e.g., that you provide us) and records of calls, webinars and video conferences. We may collect the above information as contained within training submitted by our customers to our Services.||Yes||Data Analytics Provider|
|Biometric Information||Includes iris and retina scans, fingerprints, voice recordings, facial recognition, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.||No||–|
|Geolocation Information||Includes data derived from a device and that is intended to locate a customer within a geographic area.||No||–|
|Professional-or-employment-related information||Your job role, employment-related biographical information; personal information contained within trainings submitted by our customers to our Services.||Yes||Social Network, Data Broker, Sales and Marketing Tool|
|Education Information||Information that is not ‚Äúpublicly available personally identifiable information‚Äù as defined in the California Family Educational Rights and Privacy Act, including education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No||–|
|Inferences||Inferences regarding the use of the Site and popularity of the content on it or sent via email.||Yes||Sales and Marketing Tool, Ad Network, Data Analytics Provider|
To understand more about the purposes for which we collect personal information, see “How We Use Your Information.” To learn more about the sources from which we collect information about you, please see “What Information We Collect.”
As is common practice among businesses that operate Internet websites, we may also have disclosed certain identifiers, information about the use of our websites and apps, and inferences drawn about you to our social media, advertising, and analytics partners for monetary or other valuable consideration in the last 12 months. These disclosures may qualify as “sales” of personal information under California law. This enables us to identify broad demographic trends, target advertising to your interests, and perform analytics to understand our audience and improve our services. We do not sell the personal information of individuals who we know to be under 16 years of age.
If you are a California resident, you have: (1) the right to know what personal information we collect, use, disclose, and sell; and (2) the right to request that we delete your personal information.
You may exercise these rights by:
You may also opt out of the sale of your personal information by visiting our “Do Not Sell My Personal Information” page.
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your right to the deletion of your information. In connection with such verification, we may ask you to provide your name, email address, and the Bloomfire customer with whom you are associated. We may also ask you to confirm your identity via an associate email account. We may limit our response to your exercise of the above rights as permitted by law.
You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization.
We may not discriminate against you for exercising any of the above rights as available to you under California law. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to such a request made under California law. However, as permitted by law, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.
Please note that we do not have any control over any personal information about you uploaded by one of our customers into our Services. To have that information removed, please contact the uploading customer.
European Privacy Notice
The following privacy notice applies to residents of the European Economic Area, the United Kingdom, and Switzerland.
Where Bloomfire determines the purposes and means of processing your data (e.g., when you visit our website), it acts as a ‘data controller.’ In particular, the data controller is:
1717 W. 6th St. Suite 100
Austin, TX 78703
Note that we provide services to our business customers on behalf of those businesses. When our business customers upload personal information to our platform, they act as a ‘data controller’ and you should refer to their privacy notice(s) to understand their data use and your rights.
Note that the provision of your name and email address is required to open a new account on our Services and our Site. If you do not provide us with this information, we cannot provide our Services to you. We share personal information with the categories of recipients described in our notice above.
We do not use automated decision-making to make decisions regarding how we treat our users or otherwise impacting their rights.
If you live in the European Union or Economic Area, the United Kingdom, Switzerland or Brazil, you have certain rights over your personal data where Bloomfire acts as a data controller. These rights are:
You have the right to object to our processing of your personal information where the processing is for marketing purposes or the processing is for our scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. If you make such an objection, we will cease to process your personal information unless we can demonstrate compelling, legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of our own legal claims.
You also have the right to restrict the processing of your personal information where:
Where processing has been restricted on these bases, we may continue to store your personal information. However, we will only otherwise process it with your consent; for the establishment, exercise, or defense of our own legal claims; for the protection of the rights of another natural or legal person or for other reasons of important public interest.
You may exercise these rights by emailing email@example.com. Upon receiving your request, we will confirm our receipt of it and endeavor to verify your identity by providing your name, email address, and the Bloomfire customer with whom you are associated. Following successful verification of your identity, we will fulfill the provided request if we are capable of doing so or provide you with an explanation as to why we cannot fulfill it.
Please note that may limit our response to your EU rights as permitted by law and we do not control personal information about you uploaded by one of our customers into our Services. To exercise rights with respect to such data, please contact the uploading customer.
If you believe that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the country where you reside or where you work. Most supervisory authorities allow you to file a complaint on their website or, where they do not, their website contains detailed instructions on how to file a complaint. For specifics, please review the website of the supervisory authority with whom you intend to file a complaint.
All personal information is maintained according to our corporate retention schedule. Your personal information will not be stored for longer than necessary for the purposes for which they were collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We will take into account the length of time your personal data is required to: