1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via Account.
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process your information included in your personal profile on our website («profile data»). The profile data may include your name, physical address, passport number, state or national ID card number, social security number, driver’s license number, other ID card number, information about your tax residence, telephone number, email address, profile pictures, gender, date of birth, interests and hobbies, educational details and employment details. For identity verification purposes in some cases, Bloomio may collect a visually scanned or photographed image of your face and/or your identification card, passport, utility bill, bank account statement, driver’s license, and other documents. This image may include your photograph and other information from the imaged document. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include information submitted by you in the course of using our service, communication data and notes provided by you, date and time of the requests. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3.1 We do not use your personal data for the purposes of automated decision-making.
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to any countries outside European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in Switzerland and Malta.
5.3 The hosting facilities for our website are situated in Frankfurt, Deutschland. Copy of data are stored in Maltese data center as required by supervised authorities.
6.1 Bloomio takes the security of your personal data seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.
6.3 We also use Secure Sockets Layer (SSL) encryption on all our web sites and services. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure, so we can’t guarantee the absolute security of any information.
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain and delete your personal data as follows:
(a) normally, profile data containing personal data will be retained for two years following your last login, if you have not logged in for more than two years, we will delete your profile data;
(b) for compliance with a legal obligation in some cases, personal data’s may be retained for a period up to 10 years following the date of receipt of the data’s. At the end of this period, those data’s will be deleted from our systems.
7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based on the current practice in the industry.
7.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
9.1 You may instruct us to provide you with any personal information we hold about you:
(a) report preparation may take up to 60 days and it is free of charge;
(b) optional 7 business days expedited report is a subject of the payment of a fee (currently fixed at CHF 80);
(c) you must supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.1 Our website and full services are targeted at persons over the age of 18.
11.2 Teenagers (16-17 y/o) can use free services only, with no access to paid services.
11.3 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.1 In respect of data's held in our database, we do not act as a data controller; instead, we act as a data processor.
13.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
(a) session - we use cookie to determine if you are logged into and then identify you when you visit our website and as you navigate our website (cookie used for this purpose is: PHPSESSID);
(b) invitation - we use cookie to determine if you are came to our web-site using special invitation link distributed by one of our existing user (cookies used for this purpose are: early-code).
Cookies that the web-site sets when you log in:
(a) initials - two-letters initials of your name to display in menu;
(b) isEmailConfirm - this is an indication of whether email is confirmed;
(c) userType - indication of account type you have selected when registered in our platform.
(d) recentlyAuthorized - indication of whether you have been authorised in our platform.
16.3 We use Yandex.Metrica to analyse the use of our website. Yandex.Metrica gathers information about website use. The information gathered relating to our website is used to create reports about the use of our website. Yandex.Metrica’s Data Processing Agreement is available at: https://yandex.com/legal/metrica_agreement/.
17.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
17.2 Blocking all cookies will have a negative impact upon the usability of many websites.
17.3 If you block cookies, you will not be able to use all the features on our website.
18.1 This website is owned and operated by Bloomio MT Ltd.
18.2 The website operator is registered at The Registry of Companies in Malta as Bloomio MT Ltd under the company registration number C 89991 and our registered office is at Dragonara Business Centre, Dragonara Road, St. Julians, STJ 3141 Malta.
18.3 The registered office is at Dragonara Business Centre, Dragonara Road, St. Julians, STJ 3141 Malta.
18.4 You can contact us:
(a) by post, using the postal address Bloomio MT Ltd, 5th Floor Dragonara Business Centre, Dragonara Road, St. Julians, STJ 3141 Malta;
(b) by telephone, the contact number published on our website; or
(c) by email, using email@example.com