Last updated June 3rd, 2021
Blooming Health, Inc. a Delaware corporation (“us”, “we”, “BH” or “our”) is committed to ensuring that your privacy is protected and that your data stays safe.
COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION
“Personally Identifiable Information” is data that can be used to uniquely identify you, like your full name or home address. During your use of BH Services you may be asked to provide Personally Identifiable Information, including but not limited to names, ages, phone numbers, email addresses, contact preferences, contact or authentication data, program interests, gender, preferred language, check-in information such as social activity, social related needs, loneliness measures, food security, and other similar information. We need these pieces of information in order to deliver our service to you.
We may also collect information that your browser sends whenever you use our BH Services or when you access the BH Services by or through a mobile device. This usage data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Website by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our BH Services, to improve and customize our BH Services. You can enable or disable location services when you use our BH Services at any time, through your device settings.
PURPOSES FOR PROCESSING DATA
Our lawful purposes for processing your data include consent (where you have given consent), contract (where processing is necessary to deliver the Services you enrolled to receive), protecting your vital interests, performing tasks carried out in the public interest, and the legitimate interests of BH (namely, to help older adults like you to stay safe and healthy by addressing their needs). In short, we collect information so we can provide you and others like you with better Services, helping more older adults to build strong social connections.
While we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time by contacting the site staff at your designated community center.
WHAT PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our services, enroll to receive our Services via text, phone call or other means, when you participate in activities on our platform, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the platform, the choices you make and the services and features you use. The personal information we collect may include the following:
The only Personally Identifiable Information that we collect from you through the Services are the information you voluntarily provide to us. Some of the types of Personally Identifiable Information that we may request that you disclose to us may include but not limited to: names, ages, phone numbers, email addresses, contact preferences, contact or authentication data, program interests, gender, preferred language, check-in information such as social activity, social related needs, loneliness measures, food security, and other similar information.
Additionally, if you choose to take a survey on our website or via a link sent to you following your conversation through our Services, we may ask you about your feedback and satisfaction about our services. You can also choose to keep your responses anonymous per your choice.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
HOW WE USE YOUR PERSONALLY IDENTIFIABLE INFORMATION
We operate the Services in conjunction with your community centers’ site staff. Any information, including Personally Identifiable Information, that you share with the Services may be reviewed by BH staff, its contractors and associates for quality control, to contact your community centers’ site staff, or to better assist you with your needs. We may use and share the Personally Identifiable Information that we collect via the Services amongst our employees, your caregiver, your community centers’ site staff, agents, contractors, and service providers in order to help us operate, analyze, research, develop, deliver, audit, maintain, and improve our products, content, advertising, communications, and the Services. If you provide feedback (such as through a survey or audio recording), that feedback may also be shared with BH staff and community partners. We may also ask for your consent to share your feedback anonymously (with your name edited out) with the public, because your message may inspire other older adults, community partners, and investors to join or support BH. We will use your feedback mainly to improve our service quality.
In addition, please note that we never sell your information to any third party. BH may use your collected data for various purposes general purposes, including, but not limited to:
- To provide and maintain our BH Services
- To notify you about changes to our BH Services
- To provide customer support
- To gather analysis or valuable information so that we can improve our BH Services
- To monitor the usage of our BH Services
- To detect, prevent and address technical issues
TRACKING & COOKIES DATA
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Website.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
DISCLOSURES TO THIRD PARTIES
Please remember that BH cannot serve as your emergency contact. However, we still care about your safety. It is our goal to support you in staying safe and healthy and to do so in the least invasive way possible. In rare cases, this means we might contact your caregivers, your community centers’ site staff, law enforcement, state authorities, or emergency services if your messages or phone calls indicate that you are at imminent risk of death or serious injury, or if we reasonably believe that disclosure is necessary to prevent a person’s death or serious injury. We understand that this can be disruptive, and it won’t happen unless we think it’s necessary. We will first try to work with you and request you to call 911 or other emergency services directly. We will attempt to alert other emergency responders ourselves only if we think it is important to assure your safety and you are not in a capacity to contact them on your own.
Additionally, we may disclose Personally Identifiable Information we collect from you to third parties if we believe such disclosure is necessary: (A) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (B) to protect the interests, rights, safety, or property of BH, its affiliates, employees, agents, or volunteers, including but not limited to staff; (C) to enforce our Terms; (D) in connection with a sale, merger, or change of control of BH or its affiliates, or (E) to address fraud, security, technical issues, or to operate the Services or its infrastructure systems properly.
Note that BH’s staff and community partners are located across the United States, and may not be licensed in your state or trained in your state’s law. Other state laws may apply to your communications, and those state laws may not protect your communications to the same degree, or in the same way, as the laws of your state.
NON-PERSONALLY IDENTIFIABLE INFORMATION
When you text with us, in addition to collecting personally-identifiable data described above, we also collect certain kinds of anonymous non-identifiable data such as the date and time of day you texted in. We may anonymize personal data that we collect from you so that it cannot be used to identify you or to contact you, by redacting — or “scrubbing” — personally-identifiable details from it, such as name, age, or address that you provide. We may use and share anonymous and anonymized data with third parties for any reason, including but not limited to improving our Services, generating support for BH, or as required by law.
RETENTION OF INFORMATION
We will use commercially acceptable means to keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We may retain non personally identifiable data — including the data we scrub — indefinitely, so that we may continue to use it to improve our Services.
HOW WE PROTECT YOUR PERSONALLY IDENTIFIABLE INFORMATION
YOU SHOULD ALSO PROTECT YOURSELF
Always be careful and responsible regarding your Personally Identifiable Information. We are not responsible for, and cannot control, what others not affiliated with BH do with information you provide to them. You may also choose to delete BH conversations from your phone or make sure to use appropriate screen lock settings to prevent others from accessing your text messages with us.
We may employ third party companies and individuals to facilitate our Website and BH Services (“Service Providers”), to provide the Website and BH Services on our behalf, to perform Website and BH-related services or to assist us in analyzing how our Website and BH Services are used. These third parties may have access to some of your basic Personal Data only to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.
LINKS TO OTHER SITES
ACCESS/CHANGES TO PERSONALLY IDENTIFIABLE INFORMATION
You may request access to or changes to Personally Identifiable Information of yours which we have stored by emailing email@example.com. You will be asked to verify your identity in order for us to grant you access to or process changes to your Personally Identifiable Information.
You may request that we delete your Personally Identifiable Information, such as names, ages, phone numbers, email addresses, contact preferences, contact or authentication data, program interests, gender, preferred language, check-in information such as social activity, social related needs, loneliness measures, food security, and other similar information, and texts/message transcripts by contacting the site staff at your designated community center. We will make reasonable efforts to process requests promptly, but may decline to process requests that are unreasonably repetitive, require unreasonable technical effort, jeopardize the privacy of you or others, are otherwise impractical, or which would conflict with a law enforcement matter. Additionally, we will decline to process requests if we believe preservation of your Personally Identifiable Information is necessary: (A) to comply with the law or in response to a subpoena, court order, government request, or other legal obligations; (B) to protect the interests, rights, safety, or property of BH, its employees, agents, or volunteers, including but not limited to community partners; (C) to enforce our Terms; (D) in connection with a sale, merger, or change of control of BH or its affiliates, or (E) to address fraud, security, technical issues, or to operate the Services or their infrastructure systems properly.
GOVERNING LAW; INTERNATIONAL USERS
CHILDREN UNDER THE AGE OF 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, use any of the interactive or communications features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use, when applicable. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. In addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
Blooming Health seeks to support older adults in strengthening their social connections, and is not a substitute for professional health care, mental health treatment, psychiatric care, or therapy of any kind. All information presented in this service is for informational purposes only and is not intended as professional medical advice, diagnosis, or treatment. Our Services are not intended to diagnose, treat, cure, or prevent any disease. Blooming Health Platform Services is not intended to be used for any purpose or in any manner for communicating or otherwise managing Protected Health Information, as defined by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). We do not offer such a product or service at this time.