Privacy Policy

c) User Account Information

When you register for the Platform or use our Services, we ask that you provide information that can be used to personally identify you. This includes details such as your full name, email address, phone number, year of birth, delivery address, and billing address.

d) User Credentials.

When you register for the Platform, you will be asked to provide credentials to allow you to access your account. These credentials may include a username, password, security questions, and responses to security questions.

e) User Identifiers:

We assign you one or more unique numbers or other identifiers that we use to identify you in iBloom’s internal systems and recognize you over time and across different devices, websites, and online services. These identifiers may be used in conjunction with cookies and other technical information.

f) Payment Card Information:

We may collect and store [ex. the last four digits and expiration date] of any payment card that you use to make a purchase on the Platform. However, we do not collect or store full payment card numbers on our systems. All payments are processed using a secure third party. Payments made using the third party are subject to the Terms and Conditions and Privacy Policy for that organization. Prior to payment, you may review those documents. iBloom is not responsible for data or information collected and/or stored by any other third party.

g) Precise Location Data:

In some circumstances, we may collect precise geolocation data (geolocation data sufficient to identify a street name and name of a city or town) from your device when you access the Platform.

h) User Content:

We collect the data you submit when you contact iBloom customer support; provide ratings or feedback for products or retailers; publish or otherwise make available User Postings and Input; or otherwise engage directly with iBloom personnel. User Content may include information submitted by you and AI Content. This also includes metadata relating to the method you use to communicate with iBloom.

i) Usage and Device Data:

We collect certain information automatically when you access the Platform or by using cookies, as described below and in our Cookie Policy. This technical information may include your browser type and operating system; your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area; websites you visited before and after visiting the Platform; pages you view and links you click on within the Platform; information collected through cookies, web beacons, and other technologies; information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and standard server log information.

a) From You Directly:

We receive Personal Information directly from you or affiliated Users (such as Schools) when provided to us, such as when you register for the Platform or place an order. Additionally, you may be required to provide Personal Information when you contact us for support or with questions so that we can respond appropriately.

b) From Third Parties:

We receive Personal Information from third parties that have legally obtained it, either directly from you or from other third parties. This may be from School Personnel, Parent Users, and Tutors, or third party applications that you use to connect to the Services.

a) Providing Services:

We may use Personal Information to make the Platform and Services available to you. For example, we may use your Personal Information to create and update your account; facilitate the fulfillment of your orders and payment regarding same; administer and manage your account; authenticate your identity; protect your account; provide you with updates about your orders and account; and administer any contest or promotions.

b) To Improve, Personalize, and Develop the Services:

We use information to tailor the content and information that we may send or display to Users, to offer personalized content and instructions, and to otherwise personalize your experience while using the Services, including on various devices you may use to access the Services. We collect statistics to better understand how Users access and use our Services, monitor the effectiveness of our Services, detect usage patterns, and to diagnose or fix technology problems.

We also use information to demonstrate the effectiveness of the Services and perform research, and to develop, support, and improve our Services and other educational products and services.

c) Communicating With You:

We may use your Personal Information to communicate with you. For example, we may send you text messages or other notifications (such as “push notifications” through your mobile device) about the status of your orders and deliveries. You may control how we communicate with you by adjusting your notifications preferences in your account settings.

iBloom also uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns, and to monitor and improve our customer support responses and processes. We do not use Student Data to send marketing communications, and we do not send marketing communications to student or child users. We may also communicate with you through our iBloom Newsletter (“Newsletter”). The Newsletter is intended to provide you with information about the Services or new information or services iBloom may be offering. When you register with iBloom you consent to receive the Newsletter. If, for whatever reason, you decide you no longer with to receive the Newsletter, you must unsubscribe, which is located at the bottom of any communication we send.

d) Data Aggregation:

We may use your Personal Information to create aggregated and/or anonymous data records (collectively “Aggregate Data”). We de-identify data by removing information (including any contact information) that would allow the remaining data to be linked back to you. We may use Aggregate Data for internal purposes, such as analyzing patterns, program usage, demographic trends, and user behavior patterns and preferences to improve our Services and for other lawful purposes.

e) Compliance, Protection, and Safety:

We may use your Personal Information as we believe necessary to comply with any Applicable Laws, court orders, subpoenas; to respond to lawful requests by law enforcement, regulators, or government entities; to detect, prevent, investigate or combat possible crime, such as identity theft, or other fraudulent activity; to protect the security of the Platform and Services; to enforce or apply our online Terms of Service or other agreements; to protect our own rights or property or the rights, property, or safety of our users or others; and to investigate or address claims or disputes relating to the Services.

f) Research and Development:

We use data for testing, research, analysis, product development and machine learning to improve the user experience. This helps us make our Services more convenient and easier to use, enhance the safety and security of the Services, and develop new services and features. iBloom performs the above activities on the grounds that they are necessary for purposes of iBloom’s legitimate interests in improving and developing new services and features.

g) Analytics:

We may use analytics, machine learning, and data models (“Analytics”) to support our data processing activities. Some of our Analytics rely upon Personal Information that we collect from you, your interactions and use of the Platform, and from third parties. Using this Personal Information, our Analytics allow us to tailor our Services to your specific needs and preferences, provide certain services to our partners, and develop new features.

a) Third Parties:

We share information with consent and at the direction of Schools and Parent Users. For example, a School or Parent User may direct iBloom to share specific information with another individual, such as a Tutor or School Personnel. Similarly, we may share Personal Information with third parties, for example, if a School authorizes Google login or similar authentication tools for that School's User Accounts.

b) Other School Users:

iBloom may share information collected from Users associated with a School with other Users or persons designated by the School, such as School Personnel. Messages and content shared or posted by members of a school community, such as messages between a teacher and students in a class, will be accessible by school administrators or other designated School Personnel.

c) Promotions:

At certain times, we may provide you with access to deals, promotions, or opportunities (“Promotions”) in association with our partners. If you register for their products and/or services, communicate with these partners, or download their content or applications as part of a Promotion, you may be providing your information to both iBloom and the partner. If this is the case, we will provide disclosures as part of the Promotion. We are not responsible for our partner’s data practices and you should carefully review each partner’s Privacy Policy before participating in a Promotion that they are sponsoring.

d) Affiliates and Business Transfers:

We may share your Personal Information with our subsidiaries, and affiliates for use consistent with this Privacy Policy. Additionally, we may share your Personal Information in connection with, or during negotiations of, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or a portion of our business, assets or stock, including a bankruptcy or similar proceeding.

e) Service Providers:

We provide data, including Personal Information, to vendors, consultants, research firms, marketing (provided that we will not knowingly use Student Data to target advertising or marketing) and other service providers. These include payment processors and facilitators; analytics, background check and identity verification providers; cloud storage providers; data analytics providers; research partners, including those performing surveys or research projects in partnership with iBloom or on iBloom’s behalf; vendors that assist iBloom to enhance the safety and security of the Platform and Services; lawyers, accountants, and other professional service providers; and insurance and financing partners.

f) Compliance with Laws and Protection of Rights:

We may disclose your Personal Information as we believe necessary to comply with any Applicable Laws, court orders, subpoenas; to respond to lawful requests by law enforcement, regulators, or government entities; to detect, prevent, investigate or combat possible crime, such as identity theft, or other fraudulent activity; to protect the security of the Platform and Services; to enforce or apply our online Terms of Service or other agreements; to protect our own rights or property or the rights, property, or safety of our users or others; and to investigate or address claims or disputes relating to the Services.

g) With Consent:

We may share your data other than as described in this notice if we notify you and obtain your consent.

a) Generally:

iBloom retains user data for as long as necessary for the purposes described above and for our internal business purposes, which may extend beyond the termination or cancellation of your subscription or User Account. Please note that we may retain your Personal Information after a deletion request due to District Agreements or legal or regulatory requirements. You may request deletion of your Personal Information at any time as described in more detail in the Choice and Transparency section of this Privacy Policy.

We may not be able to comply with your request in all circumstances. For example, certain requests to access, update or delete Personal Information and data associated with a School’s account or license may be subject to approval by the School. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing, and tax purposes.

b) Student Data:

We will not knowingly retain Student Data beyond the time period required to support an educational purpose, unless authorized by a School or parent. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School. The School is responsible for maintaining current student rosters and identifying Student Data which the School no longer needs for an educational purpose by removing students from the school’s master roster or by submitting a deletion request.

Unless otherwise directed by a School or parent / Parent User, we will delete or de-identify Personal Information of student and child users after a period of inactivity, after the termination or cancellation of the license subscription, or after termination of a District Agreement, in accordance with the terms of any applicable District Agreement, written requests from authorized School Personnel, and our standard data retention schedule.

We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual.

a) Device Permissions: Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

b) Platform Inbox, Push Notifications, and SMS Messaging: When you first register to use our Platform, you may authorize us to communicate with you through the Platform inbox, push notifications, and SMS messages. You can adjust these settings at any time in IBloom App.

c) Email Communications: We include an “unsubscribe” link in each electronic newsletter or promotional e-mail we send you as required by Applicable Law. If you no longer wish to receive such communications from us, please click that link and follow any additional instructions.

d) Tracking Technologies: Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. If you do not accept cookies, you may experience some inconvenience in your use of the Platform. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit the Platform.

e) Updating and Correcting Your Information: If you are a registered user, you have the ability to update or correct your Personal Information by accessing your profile page once you are logged in. If you are unable to make the necessary updates or corrections there, please request changes by sending an email to info@ibloom.io. If you are a Parent User or guardian of a student who uses the Services through a School, please refer all questions and requests regarding access, modification, or deletion of your student's User Account or Student Data to your child’s school. The School may, at it's discretion, address such requests with iBloom and iBloom shall respond promptly to all access, modification and deletion requests it receives from Schools.

f) Deleting Your Information: You have the right to request that we delete from our records any Personal Information from our systems, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your Personal Information from our records unless an exception applies. Please note that it may take us several days to verify your identity and process your request.

a) Generally, States: This notice supplements our Privacy Policy. In certain regions, you may have certain additional rights. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict iBloom using it for certain purposes. If you wish to exercise a right, please contact iBloom and reference the Applicable Law. Our ability to respond to specific requests may be limited by applicable law and the functionality of our Services.

b) California Minors’ Rights: If you are a registered User under the age of 18 residing in California, you are entitled to request removal of content or information you have posted publicly on our Services. To request removal, please contact iBloom for assistance. Please note that your request does not ensure complete or comprehensive removal, as the content or information may be retained subject to Applicable Law.

c) General Data Protection Regulation (“GDPR”): If you are a resident in the European Union, United Kingdom, or other countries part of the European Economic Area, you may have certain additional rights:

• i. Right of Access & Portability:The right to obtain access to your Personal Information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller.
• ii.Right to Rectification:The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
• iii.Right to Erasure:The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
• iv.Right to Restriction:The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• v.Right to Object:The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing.
• vi.Right to Withdraw Consent:The right to withdraw your consent at any time (though withdrawing your consent will not affect the lawfulness of processing that occurred before you withdrew your consent).You may also have the right to make a complaint to the relevant Supervisory Authority.
  
  If you need further assistance regarding your rights, please contact us and we will consider your request in accordance with Applicable Law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or becauseprocessing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
  
  For personal data subject to the GDPR, we rely on several legal bases to process the data. These legal bases include where (a) the processing is necessary to perform our contractual obligations in our Terms of Service or other contracts; (b) the processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Services, marketing the Services, such as new features or products that may be of interest, and promoting safety and security; (c) you give us consent to do so for a specific purpose; or (d) the processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims.