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Privacy Policy

This Privacy Policy describes the policies and procedures of Bloom Credit Inc. (“Bloom Credit”, “we”, “our” or “us”) on the collection, use and disclosure of your information in connection with your use of the services, features, content or applications we offer (collectively, the “Services”), including without limitation through our website at bloomcred.it (the “Site”). We receive information about you from various sources, including without limitation: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (each a “Third Party Service”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Information You Provide to Us:

When you create an account on the Services (“Account”), you will provide information that could be Personal Information, such as your name, phone number, email address and social security number, and non-personal information, such as income and net worth, which may be combined with Personal Information. If we combine non-personal information with Personal Information, we will treat such combined information as Personal Information. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. Additionally, if you register for or access the Services using a Third Party Service (such as a financial institution), we may receive Personal Information that you allow such Third Party Service to share with us. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services. You may unsubscribe from some of these messages by emailing us at [email protected], although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Information From Third Parties:

As mentioned above, you may be able to register for or access the Services using a Third Party Service, such as a financial institution. You acknowledge that some account information from your account on the applicable Third Party Service may be transmitted into your Account with us, and that such information is covered by this Privacy Policy. Some of your information from the Services may also be shared with the Third Party Service and others, pursuant to the privacy policies of such Third Party Services. Therefore, we encourage you to read the privacy policies and other policies of any Third Party Services you use in connection with the Services.

Our Services also rely on information about you that we collect from third parties, such as credit scores we request on your behalf from TransUnion and Equifax. We may also work with different third party data partners to supplement the Personal Information and other information we collect directly from you.

Additionally, we may collect and receive your third party account login credentials in connection with providing you with the Services, but only if you expressly provide us with such information. We will only use such login information as set forth in this Privacy Policy or as otherwise expressly authorized by you.

Location Information:

Some of our Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services. Additionally, we may also collect and/or receive location information from your use of the Services generally, which can come from a variety of sources, depending on how you use or access the Services.

IP Address Information and Other Information Collected Automatically:

  • Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site and users of the Services. We may use this data in aggregate form, that is, as a statistical measure, or in other anonymous forms, but not in a manner that would identify you personally. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
  • We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
  • We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.

Email, Text, and Push Notification Communications:

We may communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification. We use this information to improve our Services, including without limitation our customer service.

Information Collected Using Cookies:

  • Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services.
  • Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.
  • Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link

Information Related to Advertising and the Use of Web Beacons:

To support and enhance the Services, we may serve advertisements, and also allow third parties advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age); (ii) Services usage patterns or (iii) user activity on Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

Aggregate Information:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.

How, and With Whom, Is My Information Shared?

How We Use Personal Information Provided to Us:

  • To allow you to register for our Services and to administer and process the registration.
  • To communicate with you about our Services and related issues.
  • To evaluate the quality of our Services, and to enhance your experience with the Services.
  • To maintain and administer our Site and comply with our legal or internal obligations and policies.
  • To transfer information to others as described in this policy (for example, with our business partners or other third parties we collaborate with in connection with providing or improving our Services), or to satisfy our legal, regulatory, compliance, or auditing requirements, including to disclose information to law enforcement authorities upon validly served legal process or a valid judicial instruction (for example, pursuant to a court order).

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

We may give you opportunities to interact with Third Party Services through our Services (for example, referring you to a lender for a loan application). In these situations, we will either tell you we’ll be sending your information, including Personal Information, before we do so or we will send you to the Third Party Service’s site or platform for you to provide the information directly to them. You hereby consent to our sharing of your Personal Information with these partners. As a reminder, any information you provide to the Third Party Service, whether through us or on your own, will be subject to the terms and conditions and privacy policies of the Third Party Service.

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within our Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate and Non-Personally Identifiable Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business (“Business Partners”). We may also share information with our Business Partners that is (i) not Personal Information or (ii) derived from Personal Information but has been anonymized so that it is no longer personally identifiable (collectively with Aggregate Information, “Non-Personal Information”). We use and share this type of data so that we and our Business Partners can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Business Partners may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Is Information About Me Secure?

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your Personal Information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Additionally, you are responsible for preventing unauthorized access to your Account and Personal Information by protecting your Account credentials.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by contacting us at [email protected]. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:  20 North Wacker Drive, Suite 1000, Chicago, IL 60606.

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by contacting us at [email protected]. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

What Choices Do I Have Regarding My Information?

  • You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.
  • You can always opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our features.
  • You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
  • You can choose to opt out of certain communications or communication methods; however, if you do so, you may not be able to take advantage of some of our Services’ best features.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email protected]. We will make every effort to resolve your concerns.

Effective Date: 05/04/2017