2. What Information We Collect
2.1. In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purpose for which we may process personal data; and
- the legal bases of processing.
2.2. From Visitors we collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages Visitors access or visit, and information volunteered by the Visitor.
2.3. From Users and Administrators we collect information such as name and email. It is optional that Users and Administrators provide job role, bio information, and profile picture—this information will be collected if provided.
2.4. From Subscribers we collect all information as for Users and Administrators. In addition we collect billing address, and phone number.
3. How We Use Your Information
3.2. We may use your email address or other personal information to send occasional commercial, educational, or marketing messages. Bloomfire is compliant with the CAN-SPAM Act of 2003. However, if you wish to opt-out of these emails you can easily unsubscribe with the ‘unsubscribe’ or ‘opt-out’ links contained within them or with an email to email@example.com(1). We may use your email address without further consent 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).
3.4. We reserve the right to share your information to respond to duly authorized information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state or company security is at issue (such as with the World Trade Center terrorist act in September, 2001), we reserve the right to share our entire database of visitors and customers with appropriate governmental authorities.
How We Store and Protect Information
4.1. Bloomfire uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Bloomfire. Although Bloomfire owns the code, databases, and all rights to the application and feedback, you retain all rights to your data.
4.3. We may disclose your email address to our suppliers or subcontractors insofar as reasonably necessary for providing contractual Service.
4.4. Financial transactions relating to our Site and Service are handled by our payment service provider. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing payments/refunds.
4.5. In addition to the specific disclosures of personal dataset out in the Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims whether in court proceedings or in an administrative or out-of-court procedure.
5. Transfer of Customer Information
5.1. Customer lists and information are properly considered assets of a business. Accordingly, if we merge with another entity or if we sell our assets to another entity, our customer lists and information, including personally identifiable information you have provided us, would be included among the assets that would be transferred.
International Transfer of Personal Data
6.1. In this Section 6, we provide information about the circumstances in which personal data of residents of the European Union may be transferred to countries outside of the European Union.
6.2. We have offices in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
6.3. The hosting facilities for our Service are situated in the United States of America and Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
7. Your Rights
7.1. In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2. Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
7.3. You have the right as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it; with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9. You have the right to object to our processing of your personal data for 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.
7.10. To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11. If you consider 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 EU member state of your habitual residence or your place of work.
7.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13. You may exercise any of your rights in relation to your personal data by written notice.
8. Cookies that we use
9. Managing Cookies
9.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
9.2. Blocking all cookies will have a negative impact upon the usability of many websites.
9.3. If you block cookies, you will not be able to use all of the features on our website Service.
10. Other Information
Bloomfire adheres to the US Safe Harbor privacy principles. For more information about the Safe Harbor framework, see the Department of Commerce’s website at http://export.gov/safeharbor/.
Data Protection Officer
1717 W. 6th St. Suite 100
Austin, TX 78703
The above contact information may also be used to request access to the information we collect about you. This access may be subject to a fee to cover our costs.
As a convenience to our Visitors and Users, the Site may contain links to a number of sites that we believe may offer useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
(1) E-mails from firstname.lastname@example.org (or any other internal @bloomfire address) are represented in the statement above. If you become a member of an independent free trial or owned Bloomfire Service, you have direct control of those messages within your Bloomfire profile page.