BLOOM COPPA POLICY

1. PURPOSE

As part of its privacy compliance, Bloom-Ed, LLC (hereinafter referred to as “Bloom,”,”BLOOM”, “us,” “we,” “our,” or “Company”) conducts its business to address applicable statutory, regulatory, and contractual requirements for data security and privacy.  The purpose of this document is to explain Bloom’s overall processing of Children’s Personal Information, and Bloom’s compliance with applicable regulatory provisions.

2. SCOPE

This Policy applies to all Children’s Personal Information collected, processed, and maintained by Bloom.

3. DEFINITIONS
Term Definition
Child (or “Children”) An individual under the age of 13.
Parent A Child’s Parent or legal guardian
Personal Information Individually identifiable information about a Child collected online, including:

·      A first and last name;

·      A home or other physical address including street name and name of a city or town;

·      Online contact information as defined in this section;

·      A screen or username where it functions in the same manner as online contact information, as defined in this section;

·      A telephone number;

·      A Social Security number;

·      A persistent identifier that can be used to recognize a user over time and across different Web sites or online services.  Such persistent identifier includes, but is not limited to, a customer number held in a cookie, an Internet Protocol (IP) address, a processor or device serial number, or unique device identifier;

·      A photograph, video, or audio file where such file contains a Child’s image or voice;

·      Geolocation information sufficient to identify street name and name of a city or town; or

·      Information concerning the Child or the Parents of that Child that Bloom collects online from the Child and combines with an identifier described in this definition.
4. ROLES AND RESPONSIBILITIES
CEO Responsible for the development, implementation, monitoring, and maintenance of Company’s data protection responsibilities related to Personal Information hereunder.
COO Assists the CEO in implementation of this Policy.
Employees All workers who come into contact with Personal Information are expected to consistently apply the requirements of this Policy to their use of the information in their daily business activities.

 

5. NOTICE REQUIREMENTS
  • Direct Notice

Bloom makes reasonable efforts, taking into account available technology, to provide Parents with direct notice of Bloom’s practices relating to Personal Information (i) before collecting, using, or disclosing Personal Information; and (ii) when making any material changes to Bloom’s collection, use, or disclosure practices to which the Parent previously consented.

Contents of Direct Notice.
The direct notice addresses, at a minimum:

  • That Bloom may have collected the Parent’s online contact information from the Parent’s Child (and if so, the name of the Child or Parent) in order to obtain the Parent’s consent;
  • That the Parent’s consent is required for the collection, use, or disclosure of the Personal Information, and that Bloom will not collect, use, or disclose any Personal Information from the Child if the Parent does not provide consent;
  • The additional items of Personal Information the operator intends to collect from the Child, or the potential opportunities for the disclosure of Personal Information, if the Parent consents;
  • A hyperlink to Bloom’s online notice of its information practices regarding Children;
  • How the Parent can consent to the collection, use, and disclosure of the Personal Information; and
  • That if the Parent does not provide consent within a reasonable time from the date the direct notice was sent, Bloom will delete the Parent’s online contact information from Bloom’s records.

Timing of Notice
Bloom will provide Parents with the direct notice prior to collecting, using, or disclosing Personal Information.

  • Online Privacy Notice

Bloom will post a website Privacy Notice on its sites that collect, use, and disclose Personal Information.

Contents of Notice.
The Privacy Notice will address, at a minimum:

  • Contact information for Bloom, including name, address, telephone number, and email address;
  • A description of the Personal Information Bloom collects, including whether Bloom’s services allow a Child to make Personal Information publicly available;
  • How Bloom uses Personal Information;
  • How Bloom discloses Personal Information;
  • That the Parent can (i) review the Personal Information; (ii) have the Personal Information deleted; and/or (iii) refuse to permit further collection or use the Personal Information; and
  • The procedures for making the above requests.

Location of Notice
Bloom shall post its Privacy Notice to Parents on the home or landing page of Bloom’s website, as well as each area of the site where Personal Information is collected from Children.  The notice shall be available at all times via a link in the footer of Bloom’s websites and/or domains.

6. ONSENT REQUIREMENTS
  • Overview

Bloom will obtain verifiable Parental consent (i) before collecting, using, or disclosing Personal Information; and (ii) when making any material changes to Bloom’s collection, use, or disclosure practices to which the Parent previously consented.  When obtaining consent, Bloom will give the Parent the option to consent to Bloom’s Personal Information practices without consenting to the disclosure of the Parent’s own Personal Information to third parties.

  • Methods

Bloom will make a reasonable effort to obtain verifiable Parental consent using methods reasonably calculated, in light of available technology, to confirm that the person providing consent is the Child’s Parent.  These methods may include:

  • Providing a consent form to be signed by the Parent and returned to the operator by postal mail, facsimile, or electronic scan;
  • Having a Parent call a toll-free telephone number staffed by trained personnel; or
  • Using an email coupled with additional steps to provide assurances that the person providing the consent is the Parent.
7. RIGHT TO REVIEW

Upon receipt of a verifiable request from a Parent to review Personal Information collected from the Parent’s Child, Bloom will provide the following in a manner that does not unduly burden the Parent:

  • A description of the specific types or categories of Personal Information collected from Children by the operator, such as name, address, telephone number, email address, hobbies, and extracurricular activities;
  • The opportunity at any time to refuse to permit the operator’s further use or future online collection of Personal Information from that Child, and to direct the operator to delete the Child’s Personal Information; and
  • A means of reviewing any Personal Information Bloom collected from the Child.
8. TREATMENT OF CHILDREN’S INFORMATION
  • Participation in Activities

When providing the Services to a Child, Bloom will not condition a Child’s participation in a game, the offering of a prize, or another activity on the Child’s disclosing more Personal Information than is reasonably necessary to participate in such activity.

  • Security

Bloom will establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of Personal Information it collects from Children.  Such procedures will include, at a minimum, that Bloom takes reasonable steps to share Personal Information only with service providers and third parties capable of maintaining the confidentiality, security, and integrity of such information, and who provide assurances that they will maintain the information in such a manner.

  • Data Retention

Bloom will retain Personal Information for only as long as is reasonably necessary to fulfill the purpose for which the Personal Information was collected.  Bloom will delete Personal Information using reasonable measures to protect against unauthorized access to, or use of, the Personal Information in connection with its deletion.

9. VIOLATION

Violation of this Policy may result in disciplinary action, which may include loss of access privileges and/or the termination of the relationship.

10. REVIEW FREQUENCY

This Policy and process will be reviewed every two (2) years, or more frequently if required.

Policies, practices, and procedures may be reviewed, added, amended, or deleted by Bloom, in its sole discretion, from time to time, as it considers appropriate based on operational needs or in accordance with applicable laws.  Significant updates to policies, practices, and procedures will be communicated to employees.  Employees bear the responsibility of reading, understanding, and abiding by updated policies, procedures, and practices.  Policies and procedures are subject to minimum legislated/statutory requirements, as applicable.

 

Last Updated: 7/28/22