Last Updated: February 4th, 2022
Effective: February 4th, 2022
Who we are:
Bloom Investment Advisors LLC. (“Bloom,” “we”, “our”, or “us”), a subsidiary of Contour Labs Inc., is a financial services company. Our platform provides improved transparency about how our customers invest and manage their money, as well as the necessary tools to help improve one’s financial well-being. When you use these services, you’ll share some information with us that could be used to identify you or that is associated with information that identifies you (“Personal Information”).
The categories of Personal Information we collect include:
● Identification information you provide to us
● Communication information you share when you voluntarily reach out to us
● Technical information we automatically collect
● Third party Personal Information IdentificationInformation you provide to us
When you interact with our Site or mobile app, we collect identification information that you choose to share with us. For example, when you set up an account with us, we need to collect a few important details about you, such as your name, address, Social Security number, your phone number, your email address, your date of birth. We may also collect location data you choose to share with us, so we can help protect against fraud. When you use the Service, we may prompt you to share information about contacts you have on your phone, and that is optional to provide. We may also collect other information such as a copy of your government-issued identification or a photograph for verification purposes. Please ensure that you only send us an image of yourself. Do not include any images of others.Communication InformationWhen you contact customer support or communicate with us in any other way, including by voluntarily responding to questionnaires, surveys or requests for market research seeking your opinion and feedback, we’ll collect whatever information you volunteer, in addition to your name and email address.Technical InformationWhen you visit our Site or use our Services, we collect information about which of the Services you’ve used and how you’ve used them.
Examples of this information include:
● Usage information on our Site or mobile app (e.g., pages you visit on the Site, webpage from which you linked to our Site);
● Time and date of your activities;
● Your IP address;
● Location Information:
● When you browse the Site, we collect an estimate of your location through your IP address
● When you use the app, we collect your Location Information through your device IP address, WiFi, Bluetooth, and, when you have enabled geolocation tracking, GPS coordinates (e.g. latitude/longitude) of your mobile device in order to detect and prevent fraud.
If you have given the app permission to access your location, we will collect your device’s location as permitted by the settings you choose, and store your location history.
If you want to opt out of the collection of your Location Information, please adjust your settings in your mobile device to limit the app’s access to your Location Information.
● Device ID;
● The kind of browser and computer you use;
● Name of your internet service provider; and
● Operating system version.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law, as follows:
1. Identity Verification Information.We may collect Personal Information from third party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.
2. Social Media Information.We have pages on social media sites like Instagram, Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
● To provide the Services: Bloom may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
● Manage individual information and accounts;
● Respond to questions, comments, and other requests;
● Verify an individual’s identity by comparing your photograph against your government-issued identification;
● Process payment for products or Services purchased;
● Process applications and transactions;
● Provide access to certain areas, functionalities, and features of our Services; and
● Allow you to register for events.
For internal business purposes: Bloom may use Personal Information for its internal business purposes, including to:
● Measure interest in Bloom’s Services;
● Develop new products and Services or improve existing products and Services;
● Ensure internal quality control;
● Communicate about individual accounts and activities on Bloom’s Services and systems, and, in Bloom’s discretion, changes to any Bloom policy;
● Comply with regulatory requirements;
● Prevent potentially prohibited or illegal activities;
● Protect the safety of any person, to address fraud, security or technical issues, or to protect the Company’s rights or property;
● Comply with applicable laws, rules and regulations or court orders; and
● For any other purpose for which you have given express permission or consent to Bloom.
For marketing purposes: Bloom may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Bloom may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:
● To tailor content, advertisements, and offers;
● To notify you about offers, products, and services that may be of interest to you;
● To provide Services to you and our sponsors;
● For other purposes disclosed at the time you provide Personal Information; and
● Otherwise with your consent.
How we share information
We may share Personal Information about you in the following ways:
● To verify your identity. We may share your information with vendors who help us verify your identity by performing biometric or other analyses to help us detect and prevent fraud.
● With vendors and service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities; (v) know-your customer services and fraud and anti-money laundering prevention; (vi) analytics services; and (vii) in connection with the provision of the Services. These service providers have contracted with us to only use the Personal Information for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
● Business partners. We may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. For example, we partner with Alpaca Securities, LLC (“Alpaca”) to provide you with the Services. We may share your Personal Information with Alpaca to enable Alpaca to provide banking services to you in connection with our Services. We may also share Personal Information with business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.
● With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
● comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
● investigate, remedy, or enforce potential Terms of Service violations;
● protect the rights, property, and safety of us, our users, or others; or
● detect and resolve any fraud or security concerns.
Clear GIFs (Web Beacons)
We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements and actions of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Online Tracking and "Do Not Track" Signals
How long we keep your information
We will retain your information for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws or regulations.
Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them Bloom does not endorse, approve or make any representations about third party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.
Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
Bloom takes commercially-reasonable steps to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Site or Services, please keep in mind these risks and know that you do so at your own risk.Your Choices
We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.
If you wish to terminate your Bloom account or delete your data, you can contact us as set forth in this policy or initiate a request within our app.
Use of The Service By Children
We take precautions to protect the privacy of children. Where we determine that a user attempting to set up a Bloom account is under 13, we will ask for a parent or guardian’s contact information in order to obtain verifiable consent before allowing that child to use our Services.
What Information Does Bloom Collect from Children and How Is It Used?
To participate in our services your child must create an account using the Bloom mobile application. We ask all children to provide us with the phone number of the adult they would like to parent their account (“Parent”), so we can notify the Parent of their child’s interest in Bloom, request consent for the child to use our Services and provide us with their personal information, and authorize the Parent to oversee the child’s account. We request personal information from children that is reasonably necessary for their use of the Services, including their name, date of birth, phone number, email address, and mailing address. We also collect Technical Information and utilize Cookies and Analytics Technologies when children engage with our online platforms. When we collect personal information from a child, we will retain that information only as long as reasonably necessary to fulfill the purpose for which it was provided, ensure the security of our users and our Services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with applicable law, we will either delete the information or promptly seek parental consent.Parents or legal guardians can contact us at email@example.com to access and review the personal information we have collected about their child, update their child’s information, request deletion of their child’s information, or restrict further collection or use of their child’s information. Please note that our deletion of your child’s information means that they will no longer be able to have a Bloom account or otherwise use our Services.
California Privacy Rights Disclosures
Under California Civil Code Section 1798 (California's “Shine the Light” law), California residents with an established business relationship with us can annually request that we provide them with information about whether we have shared their personal information with third parties for those third parties' own direct marketing purposes. If you would like to request more information under California’s “Shine the Light” law, you can contact us as detailed in the “Contact Us” section below.The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). These disclosures apply to individuals who reside in the State of California and supplement any other privacy notice provided by Bloom. Any terms defined in the CCPA have the same meaning in this notice.The below chart reflects the categories of personal information we have collected from California residents both online and offline during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom we shared that information.
Categories of Personal InformationCollected Categories of Sources of CollectionBusiness/Commercial Purpose for CollectionCategories of Third Parties Receiving Personal Information
Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, phone number, legal name, social security number, driver's license number, passport number, or other similar identifiers.You; Your Parent; Third party sources, including credit and background check or credit check providers; Publicly available information, Devices you use to access the Services.Provide products and services to you; Respond to questions; Provide you with information about our services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; Conduct hiring and/or other human resources activities; For research, analysis, and product development; To evaluate or process a commercial transaction; As required by applicable law or government regulation.Your Parent; Advertising networks; Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Social networks; Technology services; Background check or credit check providers.Personal information categories listed in Cal. Civ. Code § 1798.80 such as 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.You; Your Parent; Third party sources, including credit and background check or credit check providers; Publicly available information, Devices you use to access the Services.Provide products and services to you; Respond to questions; Provide you with information about our services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; Conduct hiring and/or other human resources activities; To evaluate or process a commercial transaction; As required by applicable law or government regulation.Your Parent; Advertising networks; Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Social networks; Technology services; Background check or credit check providers
Protected classification characteristics under California or federal law such as age, race, national origin, citizenship, marital status, sex, gender identity, sexual orientation, medical conditions (including pregnancy or childbirth, physical or mental disability or related medical conditions), parental status, veteran or military status.You; Your Parent; background check or credit check providers.To provide you with our products and services and respond to your questions; To understand the products and services considered by our customers and to make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services; To collect and process applications for accounts or for employment.Your Parent; Background check or credit check providers; financial institutions.
Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.You; Your ParentTo provide our services; To provide advertising/marketing services, analytic services, or similar services; For research, analysis, and product development; To evaluate or process commercial transactions; As required by applicable law or government regulationYour Parent; Users of our Services who you authorize to view this information.
Internet or other similar network activity such as browsing history, search history, information on interactions with an internet website, application, or advertisement.You; Devices you use to access the Services.To provide you with our products and services and respond to your questions; To understand the products and services considered by our customers and to make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services; To identify repair errors that impair existing or intended functionality; To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity; To collect and process applications for employment.Advertising networks. Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Social networks; Technology services.
Geolocation data such as physical location or movementsYou; Devices you use to access the Services.To provide you with our products and services and respond to your questions; To understand the products and services considered by our customers and to make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services on behalf of the CompanyYour Parent; Advertising networks; Affiliates; Data analytics providers; Marketing platforms; Social networks; Technology services.
Professional or employment-related information such as current and prior employment, performance evaluations, and results of background checksYou; Background check providers; Publicly available information.Conduct hiring and/or other human resources activities.Affiliates; Recruitment platforms; Technology services.
Inferences drawn from other Personal Information to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitude, intelligence, ability, aptitude, and any other inferences drawn from your personal information.You; Devices you use to access the Services; Credit and background check providers.To understand the products and services considered by our customers and to make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services.Advertising networks; Affiliates; Marketing platforms; Data analytics providers; Social networks; Technology services; Video hosting, sharing, and streaming platformsIn the past twelve months we have disclosed personal information to third parties for business purposes. The categories of personal information we have disclosed to third parties for business purposes are identified in the “Categories of Personal Information Collected” column above. We have disclosed those categories of personal information to the categories of third parties identified in the “Categories of Third Parties Receiving Personal Information” column above. In the past twelve months, we have not sold personal information, and we have no actual knowledge of selling the personal information of minors under 16 years of age. California residents have the right to opt out of the sale of their personal information, but because we do not sell personal information, we do not offer an opt out.
Right to Know California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information.
Right to Delete California residents have the right to request deletion of the personal information we have collected from them.
Request Submission California residents or their authorized agent can submit a request by emailing us at firstname.lastname@example.org or by calling us at (323) 879-7385. You will need to provide us with your name, phone number, and mailing address for us to match with information we have on file in order to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purpose.
Right to Non-Discrimination California residents have the right to not receive discriminatory treatment for exercising their CCPA privacy rights. We do not discriminate against California residents who exercise their CCPA privacy rights.