INTRODUCTION

Last Updated: 09/22/2024

Welcome to the GWBLOOMFIELD Privacy Policy (“Privacy Policy”). By visiting our Privacy Policy, you’ve taken the first step in educating yourself about advertising businesses such as ours that contribute to the Internet’s ability to remain largely an ecosystem of free content, as well as to provide a better user experience for consumers.

At GWBLOOMFIELD INC, or any of its subsidiaries, including Bloomclicks, a GWBloomfield Company (“Bloomclicks,” “we,” “us,” or “our”), we provide online advertising services. To do this, we follow information usage practices based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, Bloomclicks creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.

If you have questions or concerns regarding this statement, please contact us: support@bloomclicks.com.

By visiting any of GWBLOOMFIELD website or mobile application, or any website or mobile application of one of its subsidiaries or affiliates (collectively, “Site” or “Sites”) or sharing any information with us, you agree to be bound by this Privacy Policy.
To start, it is important for you to know two definitions that are key to understanding our programs and privacy practices:
Personally Identifiable Information (“PII”): Information that can be linked to an identifiable individual person. This type of data includes things like full name, home address, telephone number, or email address.

Non-Personally Identifiable Information (“Non-PII”): Information that cannot identify an individual person, such as IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

Please take some time to read about what our business does, learn how we ensure that data you share with us is collected and used safely, and visit resources that provide more depth on our industry.

CONTENTS

• Short Form Privacy Policy
• Scope
• What Bloomclicks Does
• Privacy by Design
• Information Collection & Use
• Self-Regulation & Voluntary Compliance
• Your Choices
• Use of the Bloomclicks Sites as a Visitor or Client
• Contact Us
• Your Representations
• Modifications to this Privacy Policy

SHORT FORM PRIVACY POLICY

We have included a table summarizing our practices solely for your convenience and reference purposes. This table is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of this Privacy Policy. As a result, we urge you to read the entire Privacy Policy:

Information Collection: PII

We do not collect PII except as expressly provided for herein. For example, PII may be collected should a consumer contact Bloomclicks on his/her own initiative, register with a publisher to download a mobile app, or as part of our lead generation business.

Bloomclicks may collect the following categories of personal information:

• Contact Information: Name, email address, phone number, mailing address.
• Account Information: Login credentials, authentication tokens, account preferences.
• Transaction Information: Billing details, invoices, and payment records.
• Usage Data: Information about how you use our website, platform, or SMS services.
• SMS-Specific Data: Mobile phone numbers, opt-in status, opt-out requests, message logs (limited metadata such as date/time and carrier information).
• Technical Information: IP addresses, browser type, device identifiers, cookies, and similar technologies.

We collect information directly from you when you sign up, interact with our platform, respond to marketing campaigns, or opt in to SMS services. We may also collect limited information from trusted service providers, affiliates, and publicly available sources in compliance with applicable laws.

Information Collection: Non-PII

The Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity.
How Information is Used We may use your Non-PII for purposes such as enhancement of our services, marketing, and to more effectively match advertisements, applications, and website content to your interests.

Security

We use reasonable and appropriate security measures to protect your data. Retention We retain Non-PII we collect or receive online for no more than eighteen (18) months for advertising purposes. Aggregate Non-PII data for reporting and analytics may be retained for a longer period.
Changes We may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.

SCOPE
This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use the information to deliver advertising across the Internet. For more on how we handle information collected from clients and publishers or visitors to our Sites, please see “Use of the Bloomclicks Sites as a Visitor or Client” below.

We do not collect PII from any person of whom we have actual knowledge is under the age of 13. By using our website, the website of any of our publishers in our networks or submitting information to us, you consent to our use and sharing of the information collected or submitted as described in this Privacy Policy.

Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements and any third-party websites linked to one of our Sites, may also collect information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and mobile applications and their affiliated or third-party partners may include Non-PII through the use of cookies and other technologies. It may also include any PII you choose to provide in registering and transacting with such websites and mobile applications.

Although we choose our business partners and clients carefully, Bloomclicks is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.

WHAT BLOOMCLICKS DOES?
While you may only visit certain websites and mobile applications, there are other companies working behind the scenes to help provide you with a great digital experience. These third-party companies provide vital services such as analytics, advertising and fraud prevention for retailers, publishers, and other organizations. These services enable these third-party companies to, among other things, provide the advertising that keeps your favourite blogs free, your favourite stores in business, and your advertising experience more relevant.

We help companies provide digital advertising, both in browsers and mobile applications, and we do it in a variety of ways, from banner ads to coupon codes. To make some of these things possible, we need to utilize information to provide smarter decision making. Technologies such as cookies and mobile device IDs enable companies like ours to provide more relevant advertising while keeping your identity anonymous to Bloomclicks.

PRIVACY BY DESIGN
Our philosophy on privacy follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We set the tone for privacy protection early and often, proactively working to keep PII out of Bloomclicks’ systems, and building technologies that are effective without the use of PII. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are careful to protect privacy as data is collected, used, and destroyed responsibly.

We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet, and utilize AdChoices on each banner advertisement tailored to consumers’ interests.
Bloomclicks has developed a strong privacy foundation and has a company culture aimed at the prevention of the receipt and use of PII. We respect consumer privacy and give consumers the ability to opt-out of interest-based advertising (“IBA”).

INFORMATION COLLECTION AND USE
Information Collected by Bloomclicks

How We Use Your Information

Your personal information is used for the following purposes:

• Service Delivery: To provide digital advertising, performance marketing, and partnership services.
• SMS Marketing & Communication: To send recurring SMS messages, including promotional offers, partnership opportunities, account alerts, and transactional notifications.
• Authentication & Security: To verify identity, prevent fraud, and protect accounts.
• Customer Support: To respond to inquiries, provide support, and resolve issues.
• Analytics & Improvement: To analyze trends, optimize user experiences, and improve our services.
• Legal & Compliance: To comply with laws, enforce agreements, and protect Bloomclicks’ rights.

Bloomclicks only collects Non-PII from you (unless PII is provided by you voluntarily), and may collect this in a variety of ways. We may use technologies such as cookies, log files, pixel tags or other similar technologies to collect Non-PII about the browser or device you are using, including browsing activity, online transactions, and IP addresses. We may also receive Non-PII from third parties. Some clients contribute PII such as your name, address, email address, and associated transactional information directly to a third party with whom Bloomclicks has a contractual relationship.

This third party removes the PII data points and provides Bloomclicks only the Non-PII for our use in providing advertising to you. All Non-PII received and collected by Bloomclicks from the various sources may be combined and used to provide you advertising, and for other purposes as determined by Bloomclicks.

We may also conduct surveys by serving interactive ads that ask you to provide information such as your gender and age range, which information may be associated with a device ID or a cookie ID. If you decide to respond, your demographic information will also be associated with a device ID or cookie ID and used only for the purposes described in this Privacy Policy.

Cookies: are files that are stored on your web-enabled device and are used to improve your experience when seeing web and mobile advertisements. We may use cookies to estimate the total reach of an advertising campaign, as well as the frequency of display, and to serve advertisements which are relevant to you. This allows advertisers to determine with greater accuracy the composition of the audience they reach and attempt to reach an audience that is interested in their products or services. There are many misconceptions about cookies. Cookies cannot erase your hard drive, install programs, or collect PII from your browser or device.
Device IDs: are unique identifiers associated with your mobile device to be used for advertising. These identifiers are assigned by your mobile device operating systems, such as Apple’s iOS and Google’s Play Services for Android, and do not reveal your identity. Device IDs can be reset in your mobile device settings.

Log files: track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.
“Web beacons” are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user’s navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behaviour.

Location Data: recognizes a consumer’s location while they are on their device which is utilized by Bloomclicks to deliver advertisements. As with all data Bloomclicks collects, this is limited to non-precise as defined by the Network Advertising Initiative’s current definition of imprecise location data unless the consumer has opted in to allow their precise location to be used for IBA.

The Non-PII collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match ads, mobile application and website content to your interests assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding the use of Bloomclicks’s services. Bloomclicks may also act as a delivery agent when its products and services are used directly by a client to facilitate advertisements and other communications.

Bloomclicks supports the NAI Code of Conduct’s obligations around the collection and use of health information for interest-based advertising. This health-related information, when collected and/or used for relevant advertising, is non-sensitive and consumers may exercise choice through an opt-out basis.
When a consumer responds to or views an Internet advertisement served by Bloomclicks (such as through third-party websites or email solicitations) or visits a Bloomclicks site, we may assign an anonymous, unique identifier to the end user’s Internet browser or device, often via a cookie.

One function of these technologies is to provide Bloomclicks with information for the purpose of paying third-parties affiliate commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser’s website. If the Internet user re-visits the advertiser’s site directly, Bloomclicks is able to continue to track the user’s activities (excluding PII) on the advertiser’s site and credit the third-party website that referred the user.

We also may use Internet browsing, cross-mobile application browsing and online purchase data associated with a user, on a Non-PII level, across multiple devices to develop a predictive statistical user profile of the end user’s needs and interests for the purpose of sending them relevant advertisements on multiple browsers and devices. This is called cross-device IBA.

To opt-out of Bloomclicks IBA, please follow the opt-out instructions below in the “Your Choices” and “Mobile Device Choices” sections of our Privacy Policy. Upon opt-out, we will no longer collect behavioural data on your browser and will also no longer send behavioural data to other browsers or devices associated with you. However, data that was collected on your browser or device prior to you opting-out may still impact the advertisements you see on other browsers and devices associated with you. To opt-out of interest-based advertising on all browsers and devices, you will need to follow the instructions below for each browser and device.

SMS Marketing Program

Bloomclicks offers an SMS messaging program that allows subscribers to receive promotional updates, campaign news, transactional alerts, and service notifications.

• Opt-In: By subscribing to Bloomclicks SMS services through our website, partner forms, or other channels, you consent to receive recurring text messages.
• Message Frequency: Typical frequency is 4–8 messages per month, but may vary depending on campaigns, alerts, and user activity.
• Opt-Out: You can cancel at any time by replying STOP to any Bloomclicks SMS. After sending STOP, you will receive a final confirmation message, and no further messages will be sent.
• Help: For assistance, reply HELP to any Bloomclicks SMS or contact support@bloomclicks.com.
• Costs: Message and data rates may apply depending on your carrier and plan.
• Data Sharing: Bloomclicks does not sell, rent, or disclose mobile phone numbers or SMS opt-in data to third parties for marketing or promotional purposes. SMS data is used solely for delivering the services described in this policy.

INFORMATION SHARING BY BLOOMCLICKS
Bloomclicks will only share your information for limited purposes such as those provided in this Privacy Policy. This may include sharing information

Bloomclicks will only share your personal information under limited and lawful circumstances:

1. Service Providers: With trusted third-party providers who assist in delivering our services (e.g., hosting, analytics, SMS delivery).
2. Affiliates & Subsidiaries: With Bloomclicks group companies as necessary for integrated operations.
3. Legal Obligations: To comply with laws, regulations, subpoenas, and lawful requests.
4. Security & Enforcement: To protect rights, prevent fraud, enforce agreements, and safeguard our users.
5. Business Transfers: In connection with a merger, acquisition, restructuring, or sale of assets, subject to privacy safeguards.
6. Consent-Based Sharing: With your explicit consent for any other purposes.

Importantly: Mobile opt-in data and SMS-specific information are never shared with third parties for their own marketing purposes.

While Bloomclicks strongly encourages clients and partners to adopt responsible approaches to online marketing, Bloomclicks is not responsible for the information practices of such clients and partners. With respect to IBA, Bloomclicks and other third-parties may use Non-PII collected or shared with respect to your visits to websites with whom we have relationships for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you.

In the event that Bloomclicks is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

Service-specific Provisions for Information Collection and Use:

International Data Transfers

As a global company, Bloomclicks may transfer your information across borders. If your data is transferred outside your country, including outside the European Economic Area (EEA), the United Kingdom, or jurisdictions with equivalent protections, we ensure lawful safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Data Processing Agreements (DPAs) with partners and vendors.
• Appropriate security measures to protect data integrity and confidentiality.

Some products and services offered by Bloomclicks have privacy considerations unique to those offerings.

These considerations are covered here:

Lead Generation:
Bloomclicks provides lead generation services to clients where we work with website publishers who utilize their display, search and email distribution channels to generate consumer interest or inquiry into advertiser products and services. The co-registration component refers to the process in which Bloomclicks facilitates the exchange of consumer information (typically PII held by website publisher in accordance with their Privacy Policy) from website publishers to advertisers.

We may receive PII that our clients have collected in connection with our services for our clients or that clients have collected for access or transmittal purposes to other clients. We may hold such information and/or transmit or allow access to such information to the intended recipients or categories of recipients as requested by our clients.

As part of the Lead Gen services, online forms hosted by us, our clients, or third parties acting on the behalf of us or our clients may collect PII that a consumer has voluntarily provided. This information may be used for the same purposes listed in “Information Sharing by Bloomclicks,” above. This information may also be used to verify any information submitted to us or any of our clients, and for any suppression or opt-out purposes.

Bloomclicks may serve advertisements to you based, in part, on the demographic and geographic information you submitted to our clients during the website registration process, and lifestyle information about you that we obtain from them and other Bloomclicks entities and third parties.

SECURITY
The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure or destruction of data.

No transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of Bloomclicks to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. Bloomclicks cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with Bloomclicks.

Retention
We retain Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.

SELF-REGULATION & VOLUNTARY COMPLIANCE
Our industry has a rigorous voluntary self-regulatory regime, and we are active members of industry groups such as the Network Advertising Initiative(NAI), Interactive Advertising Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising Alliance of Canada (DAAC) who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA and require regular audits of member privacy practices.
Bloomclicks is an active member of these and other groups, and where Bloomclicks engages in activities regulated by these programs, we comply with the NAI Codes of Conduct. We also support the DAA Self-Regulatory Principles and the DAAC Self-Regulatory Principles.

YOUR CHOICES
We hope that after reading through this Privacy Policy that you feel comfortable we are collecting and using data responsibly and that the cumulative benefits of our work are valuable to the Internet as a whole and your individual browsing experience. As part of our commitment to consumer privacy, we give consumers the ability to opt-out of IBA provided by Bloomclicks. If you would like to opt-out of IBA, please click here to learn more and opt-out.
You will need to make this selection on each browser or device on which you do not want to receive IBA from Bloomclicks. If you or your privacy software deletes the opt-out cookies from your computer, you will need to repeat the process.

USE OF THE BLOOMCLICKS SITES AS A VISITOR OR CLIENT
You can browse the Bloomclicks Sites without providing any PII. You may choose to provide PII to us voluntarily if you interact with our Site in certain ways, such as applying for employment with Bloomclicks, responding to an advertisement for Bloomclicks, or using one of our contact forms. This information is used only for the reasons it was collected, such as responding to your communication, and is not shared with third parties other than to fulfil the purpose for which it was collected.

Bloomclicks may also collect Non-PII, through the use of technologies such as cookies, including IP address, browser type, operating system, domain name, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity. We may use this Non-PII for purposes including enhancement of our services, marketing, IBA, and to more effectively match website content to your interests. We may share your information with our third-party service providers, Bloomclicks and its subsidiaries and affiliates, third-party marketing partners, our clients and publishers, and as expressly provided for herein.

We also use cookies to simplify login and to facilitate secure navigation through the password-protected areas of the Site. Visitors who choose to reject all cookies may have difficulty navigating the password-protected areas of the Site depending on the nature of their connection (dynamic IP, proxy server, etc.).

We may also partner with third parties who collect information on our Sites, and we may maintain links to other websites on our Sites. This Privacy Policy does not apply to the privacy practices of other websites or of third parties who collect information on our Sites.

For Clients and Publishers:
The Bloomclicks network includes our clients and publishers involved in advertising campaign transactions. Information collected from clients and publishers includes PII that is necessary to conduct business, such as name, phone number, and email address. Payments made to and from Bloomclicks require the collection of PII that may include credit card numbers and bank account information. Phone numbers may be used for sales or inventory acquisition purposes. This information is collected, modified and stored in a password-protected environment and is used for purposes including service, media delivery, contact, billing and accounts payable. We will not sell or rent this information to non-Bloomclicks entities. All client and publisher information collected for these purposes are explicit, voluntary, manually entered, and can be opted-out.

Security:
See “Security” under Information Collection and Use, above.

Log Files:
We record the IP address of new clients and publishers at sign-up. This can assist in administering the Site and client or publisher accounts, including features designed to enhance the Client experience. This information is part of the secure member database and is password protected.

Our Communications:
We send all new clients and publishers a welcoming email to verify password and user name and may communicate with you about the program or other information at the contact information you provide. We may also email individuals that have provided us with their contact info so that we can communicate information about Bloomclicks’s services. You can request to opt-out of this email: support@bloomclicks.com

Site and Service Updates:
We may send Site and service announcement updates by email. Because these announcements contain important information about services, it is not possible to unsubscribe. We also communicate with clients and publishers to provide requested services and in regards to issues relating to their account via email or phone.

Interest-Based Advertising
We may work with third-party advertisers, search providers, and ad networks (“Ad Networks”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Ad Networks may also append other data to the data collected by Ad Networks to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Ad Network may collect from you except when the Ad Network acts as our service provider. Advertisements may be shown via our Sites or on third-party websites. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (DAA)

Consumer Choice Page. 

The DAA website allows you to opt-out of one or more interest-based advertising networks. Opt-outs are device and browser specific; therefore, you must set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA’s Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising.

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates, influencers, creators, publishers, etc (“Service Providers”), including for:

• Provision of the Sites and Services;
• Facilitating marketing, non-marketing, and internal communications;
• Business analytics (both marketing and non-marketing related);
• Project management and collaboration;
• IT and network administration such as data storage and management, website hosting, data security, mobile application development;
• Day-to-day business operations such as courier services, facilities management, electronic signatures, and document destruction.

We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf. You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified or permitted by us.

We may share any of the types of Personal Information collected with one or more Service Providers.

Children’s Privacy

Bloomclicks services, including SMS programs, are not directed at children under 16 (or the age of majority in your jurisdiction). We do not knowingly collect data from minors. If you believe we have inadvertently collected such data, please contact us immediately.

ADDITIONAL STATE LAW CONSUMER RIGHTS

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have additional rights to access and control your Personal Information. Exemptions may apply.

Submitting a Request

If you are a resident of a state that provides privacy rights and you would like to exercise your rights, you may submit a request by email to compliance@bloomclicks.com. After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not be able to process certain requests without verifying your identity, so please respond promptly to our request.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

DO NOT TRACK SIGNALS

Because there is not yet a consensus on how companies should respond to web browser-based or other “Do Not Track” mechanisms, we currently do not respond to web browser Do Not Track signals that provide a method to opt out of the collection of information about online activities over time and across third party websites or online services. We may revisit our policy on responding to these signals, in which case we will post a revised Privacy Policy on the Sites.

DATA RETENTION

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes but is not limited to retention to comply with our legal, regulatory, tax, and/or accounting obligations. SMS opt-in records, opt-out confirmations, and related metadata are retained as required for compliance and audit purposes.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your Personal Information. While we have taken reasonable steps to secure the Personal Information you provide to us, please be aware that despite our efforts no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide Personal Information to us, and we encourage you to exercise discretion regarding the Personal Information you choose to disclose.

Consent and opt-out

Recruit participants ethically with Bloomclicks.com informed consent management. Our platform empowers researchers to obtain clear consent through customizable forms, while giving participants full control over their data with easy unsubscribe and opt-out options.

Right to be forgotten

At Bloomclicks.com, we prioritize user privacy and empower you to control your data. We adhere to the “Right to Be Forgotten” principle, allowing you to request the complete removal of your personal information from our systems and those of our sub-processors. For a straightforward data deletion process, simply email our compliance team at compliance@bloomclicks.com.

We never sell any data

Bloomclicks.com prioritizes data privacy and adheres to the General Data Protection Regulation (GDPR). We never sell user data and have a Data Processing Agreement (DPA) in place for our customers in the European Economic Area (EEA). This ensures your data is protected by the strictest global privacy standards.

Your Privacy Rights

Depending on where you live, you may have rights under GDPR, CCPA/CPRA, or other applicable laws. These include:

• Right of Access: Request confirmation and a copy of the personal information we hold about you.
• Right of Rectification: Request correction of inaccurate or incomplete data.
• Right to Deletion (“Right to be Forgotten”): Request deletion of personal data, subject to legal exceptions.
• Right to Restriction: Request that processing of your data be limited in certain circumstances.
• Right to Object: Object to processing based on legitimate interests or direct marketing.
• Right to Data Portability: Request a copy of your personal data in a machine-readable format.
• Right to Withdraw Consent: Withdraw consent at any time when processing is based on consent.
• Right to Opt-Out of Sale/Sharing (U.S.): If you are a California resident, you may opt out of the “sale” or “sharing” of personal data as defined by law. Bloomclicks does not sell mobile numbers or SMS opt-in data.
• Right to Lodge a Complaint: Contact your local data protection authority if you believe your rights are being violated.

How to Exercise Your Rights

You can exercise your privacy rights by contacting us:

• Email: privacy@bloomclicks.com
• Mail: Bloomclicks, 187 East Warm Springs Road, Las Vegas, NV 89123, USA
• Phone: +1 702 909 2771

For SMS-specific requests:

• Reply STOP to unsubscribe.
• Reply HELP for assistance.

We will verify your identity before fulfilling requests to protect your data. We aim to respond within 30 days under GDPR and 45 days under CCPA/CPRA.

Security

Bloomclicks uses administrative, technical, and organizational safeguards to protect your data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or via SMS is 100% secure, and we cannot guarantee absolute security.

Changes to This Policy

We may update this Global Privacy Rights & SMS Privacy Policy from time to time to reflect legal, regulatory, or business changes. Updates will be posted on this page, and material changes will be notified via email or SMS (where applicable).

Request by sending email to support@bloomclicks.com
Or contact your account manager.
All requests to remove a client or publisher from our system will be verified prior to removal to ensure the proper identity of the requester.

CONTACT US
If you have any questions about our Sites, Services, or this Privacy Policy, please contact us using the information below: info@bloomclicks.com

YOUR REPRESENTATIONS
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third-party individuals whose information you supply to us with regard to (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.
MODIFICATIONS TO THIS PRIVACY POLICY.

We may occasionally make changes to this Privacy Policy. If we do, we will update the “Last Modified” date above. If we make a material change, such as the ways in which we use PII, we will notify you via prominent notice on our Site.

Contact Information

If you have questions about this Privacy Policy, your data, or SMS rights, you may contact us at:

Bloomclicks Privacy Office
187 East Warm Springs Road
Las Vegas, NV 89123, USA
privacy@bloomclicks.com
+1 702 909 2771