1. Purpose

1.1 Who are we?

Bloom Media Group designs, markets, and implements customer loyalty and customer relationship management services for its own account or that of its Partners. Its activities include the processing and marketing of data as well as the design of direct marketing campaigns.

Bloom Media Group is also a service provider company specialised in digital marketing brokerage. The services of Bloom Media Group consist of:

• putting users (hereinafter the "User" or "Users", as the case may be), at their request, in search of goods and/or services, in contact with one or more professionals (hereinafter the "Partner(s)", as the case may be) likely to meet their needs.
• soliciting Users by sending communications on services and/or products of Partners for commercial prospecting purposes, on behalf of the latter.

Bloom Media Group invites the Users to consult the said General Conditions of Use to learn more about this subject. The present Privacy Policy details Bloom Media Group's policy regarding the protection of personal data (hereinafter "personal data") of Users when they navigate on the site https://bloommediagroup.co.uk/ (hereinafter the "Site") and/or use the services offered by Bloom Media Group from the pages of the contact interfaces (hereinafter the "Interface(s)", as applicable). It completes the Charter on the Cookies of the Site.

1.2 Personal data processing: what are we talking about?

• What is personal data? This is all information relating to a natural person, allowing him or her to be identified directly or indirectly, either by reference to an element that is specific to him or her (e.g., surname, first name, etc.), or by means of a combination of data (e.g., contact details, loyalty card number, IP address, etc.).
• What is personal data processing? This refers to all operations, automated or not, concerning personal data (e.g., collection, recording, organization, conservation, modification, use, dissemination, deletion, etc.).

2. Identity of the data controller

The company Bloom Media Group SL, 3 Hope Park, Rannoch Road, Crowborough, United Kingdom, TN6 1RB is responsible for the processing. The company has appointed a DPO, whom you can contact by post, to the attention of the DPO, at the above-mentioned address of Bloom Media Group's headquarters.

You can contact the DPO to exercise any of the rights granted to you by the GDPR as well as to obtain additional information regarding the processing of your personal data by Bloom Media Group.

3. The personal data collected

3.1. At the time of your request to be put in contact

When Users access the Interfaces, a questionnaire that varies according to the search must be completed to enable them to be put in contact with one or more Partners, depending on their needs. On this occasion, Bloom Media Group collects the personal data that you provide by filling in the fields of the Interfaces questionnaire. The nature and extent of the personal data collected depends on the purpose of your request for contact and the products and/or services you are looking for.

Bloom Media Group is likely to collect, depending on the situation, the following personal data:

• Identification data: We can collect your name, first name, and title.
• Contact details: We may collect your email address, phone number, and postal address.
• Privacy Policy: We may collect information relating to your lifestyle, family situation, the existence of pets or your consumption habits, the occurrence or absence of a claim, etc.
• Professional life: We may collect information about your job title, your occupation, your business address, your business telephone number, your business e-mail address, etc.
• Economic and financial data: We can collect your income level by range, an estimate of your assets by range, whether you own or rent your home, etc.

The personal data that must be filled in to be put in contact with one of our Partners are systematically indicated by an asterisk. Bloom Media Group may also collect additional personal data about you. You are free to fill in or not the fields of the Interfaces which are not required. If you do not wish to provide this optional information, your decision will not affect your matchmaking request.

3.2 After your request for a connection

Bloom Media Group obtains information from its Partners on the follow-ups given by the Users to the offers which were proposed to them at the end of the contact with the latter. The information obtained is limited to what is strictly necessary to allow the execution of the contract between Bloom Media Group, as intermediary, and the Partners.

3.3 When consulting the Interfaces

When Users access the Interfaces, Bloom Media Group collects the IP address of Users. This personal data is not transferred to our Partners, subject to the information in Article 4.1 "Transfer of personal data to Partners".

4. Transfers of personal data

4.1. Transfer of personal data to Partners

As this is a matchmaking service initiated by Users, their personal data obtained according to the terms of article 3.1 "When requesting a match" is collected with the aim of being transferred to one or more Partners, depending on the User's search, likely to meet their need(s). Once obtained, the relevant Partner(s) is/are responsible for processing the personal data of Users transferred in this way, for example when they decide to contact you or make an appointment with you. The Partner(s) concerned may not use Users' personal data for any purpose other than to contact them in order to meet their needs and, where applicable, to follow up on offers in which Users express an interest.

Consequently, if the Partner(s) concerned wish(es), once they have presented you with their offer(s) corresponding to your needs, to send you additional advertisements, they must obtain your consent, unless it is not required by law or regulation. In certain cases, when your request for contact is addressed to a single Partner, Bloom Media Group may offer you the opportunity to consent to receive advertising solicitations from this Partner. In this case, Bloom Media Group will only collect your consent and transmit the proof of your agreement to the Partner. Any further use of your personal data for this purpose is carried out by the Partner alone, under its sole responsibility. In no case will Bloom Media Group send you advertising solicitations.

4.2. Transfer of personal data to digital advertising providers

Bloom Media Group may also transfer Users' personal data in encrypted form to other digital advertising providers. During this transfer, to protect this data, Bloom Media Group uses a single-channel encryption algorithm (SHA 256) to ensure its integrity. This algorithm creates a unique fingerprint of the encrypted data; if the provider to whom the data is transferred:

• holds the data relating to the User concerned, it can recognize it by comparing the fingerprint that Bloom Media Group has transferred to it with the fingerprint of the data that it has generated itself;

does not hold the data relating to the User concerned, it will not obtain access to the personal data transferred.

• In the latter case, the recipient provider is not able to identify you because he does not know you.

4.3. Transfer of personal data to our service providers

4.3.1 General information

Bloom Media Group may transfer Users' personal data to some of its service providers, for the execution of their services (e.g.: advertising agencies, management tools, hosts, etc.). In such cases, only the personal data required by the recipients to perform their services is transferred to them. The transfer of this personal data is always governed by the clauses of the contracts concluded with the latter, adapted according to their quality. 

4.3.2 Specific information about transfers of your personal data outside the European Economic Area

Bloom Media Group limits as much as possible the use of service providers located outside the European Union or the European Economic Area. Nevertheless, the geographical location of some of these service providers, which are necessary for the operation of Bloom Media Group and the provision of the services offered, may result in such a transfer. In this case, Bloom Media Group accompanies the transfer of your personal data with the Standard Contractual Clauses of the European Commission, or with any other appropriate guarantee.

Please be aware that some of our service providers may transfer your personal data outside the European Union or the European Economic Area to perform their services. In this case, Bloom Media Group requires that such transfers are carried out in compliance with the applicable legislation on the protection of personal data.

5. The use of personal data collected without transfer in the framework of the commercial activity of Bloom Media Group

5.1. Data processing in the context of the communication of commercial offers from Partners.

The personal data obtained according to the terms of article 3.1 "At the time of the request for contact" are also processed directly by Bloom Media Group within the framework of their use for commercial solicitation of the User, by Partners of Bloom Media Group. The purpose of this processing is:

• To send communications about products and services for marketing purposes. These communications may take the form of an e-mail or postal mail, a text message, a telephone call or targeted online advertising.
• Once data has been collected in connection with the provision of a service or inquiry, information on similar or targeted services or inquiries based on previous requests may be sent, unless the data subject requests to stop receiving such marketing communications or chooses not to receive them.

In this context, Bloom Media Group assists its partners in the construction and optimization of their marketing campaigns, customer loyalty, customer relations, communication and information, studies and surveys. Each time an electronic communication for commercial prospecting purposes is sent, the recipient has the possibility to choose not to receive it in the future by means of an unsubscribe link. In addition, it is possible, at any time, to send an e-mail to the Sender's e-mail address in order to request that we stop sending these commercial communications.

5.2. No transfer of data in the context of commercial solicitation directly by Bloom Media Group.

In this case, Bloom Media Group is responsible for the processing of Users' personal data insofar as it alone defines the purposes and means of said processing. Bloom Media Group undertakes to collect and process only the personal data that are strictly necessary. Personal data is not transferred to the Partners. They are processed solely by Bloom Media Group, on behalf of its Partners, in compliance with the provisions of the legislation in force.

6. The purposes of the processing and the associated legal bases

The processing of Users' personal data by Bloom Media Group is carried out for the following purposes, the legal bases associated with this processing being indicated for each of them:

• The collection and transfer of personal data of the Users must be filled in during the request for contact: Put Users in touch with Partner(s) likely to meet their needs. The execution of the contract concluded between the Users and Bloom Media Group (art. 6, paragraph 1, b) of the GDPR).
• Sending a confirmation code: Confirm contact information for Users. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.
• The collection and transfer of personal data of the Users that can optionally be filled in during the request for contact: To allow Bloom Media Group and/or our Partners to better know the Users. Users' consent (art. 6, paragraph 1, a) of the GDPR).
• The collection of your consent to receive advertising solicitations from a Partner: To authorise directly (with data transfer) or indirectly through Bloom Media Group (without data transfer) a Partner to send you advertising solicitations. Users' consent (art. 6, paragraph 1, a) of the GDPR).
• Obtaining information on the follow-up given by Users to offers proposed by Partners: To execute the contract between Bloom Media Group and the partner(s) to whom the personal data of the Users have been transmitted. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.

• The collection of the IP address of Users: To evaluate and reinforce the security of the Site and/or the Interfaces; To carry out statistics relating to visits to the Site and the Interfaces. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the RGPD), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.
• The transfer to Partners of the IP address of Users: To allow the Partners to ensure that Bloom Media Group has carried out the request for contact. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.
• The transfer of Users' personal data to digital advertising providers: Search for new audiences likely to be interested in the brokerage services offered by Bloom Media Group. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.
• The transfer of Users' personal data to service providers: Use the tools and services necessary to operate Bloom Media Group. The legitimate interest of Bloom Media Group (art. 6, paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact information provided by Users is accurate.

6. Retention periods for personal data

Bloom Media Group keeps the Users' personal data for as long as it is necessary for the purposes of the treatment pursued, namely:

• The personal data that must be filled in to be put in contact with our Partners and the personal data obtained as a result of the contact with the Partners: Your personal data is in principle kept for a period of 2 years in an active base as from the last active contact with you. At the end of this period, this data is kept as archives for a further period of 3 years, in the event that a complaint or a dispute is lodged by the Users and/or our Partners relating to the execution of the contracts which bind Bloom Media Group to the latter.
• The personal data that can optionally be filled in to be put in contact with our Partners: In principle, your personal data will be retained until you withdraw your consent. If you withdraw your consent, your personal data will be deleted within one month of receiving this request; If you do not withdraw your consent, your personal data will be deleted within a maximum of 5 years; In case of a claim or dispute, Bloom Media Group has a legitimate interest in keeping your personal data until the end of their term, for the sole purpose of defending itself.
• The personal data communicated during the use of the Interface and collected and processed directly by Bloom Media Group: In principle, your personal data will be stored for a period of 3 years in an active database, starting from the last active contact with you.
• The IP address: Your IP address is kept for a period of 1 year.

If you request the modification and/or deletion of your personal data, these are modified and/or deleted within one month of receiving this request, according to the methods set out in article 8 "Users' rights"; In the event of a claim or dispute, Bloom Media Group has a legitimate interest in keeping your personal data until the end of the period, for the sole purpose of defending itself.

7. Security measures for personal data

Bloom Media Group takes the necessary precautions to preserve the integrity, confidentiality, and security of the personal data of the Users collected and processed in order to prevent their alteration, loss, destruction, or unauthorized access by third parties, whether accidental or illicit. Bloom Media Group has put in place technical and organizational security measures in accordance with the current rules of the art. In particular, be aware that:

• Your personal data is only accessible in clear text to our employees who have an effective need to access it to carry out their missions, according to a strictly controlled access protocol.
• Your personal data are, for the various treatments carried out, made as anonymous as possible.
• Our networks and servers are secured to limit as much as possible any access by third parties.
• The security of our information systems is ensured by our own employees.

Nevertheless, you should know that Bloom Media Group cannot control all the risks linked to the functioning of the internet. Bloom Media Group draws your attention to the existence of risks inherent to the use and operation of the Internet, and recommends that you take measures to protect your privacy.

8. Users' rights

8.1. List of rights

• The right to object: In accordance with the terms of Article 21, paragraph 1 of the GDPR, you have the right, at any time, to object to the processing of your personal data, when such processing is carried out on the legal basis of legitimate interest. When you object to the processing of your personal data by us: for advertising purposes, you may object without giving us any reason(s) justifying your request; for all other purposes, you must give us the compelling reason(s) for your request to exercise your right to object. Your objection to the processing of your personal data is valid for the future.
• The right to withdraw your consent: In accordance with the terms of Article 7, paragraph 3 of the GDPR, you have the right at any time to withdraw your consent to the processing of your personal data, where such processing is carried out on the lawful basis of such consent. You may withdraw your consent without giving us any reason(s) justifying your request. The withdrawal of your consent to the processing of your personal data is valid for the future.
• The right of access: In accordance with Article 15 of the GDPR, you have the right to: ask us about the nature and manner of the processing of your personal data that we carry out; obtain a copy of your personal data.
• The right of rectification: In accordance with Article 16 of the GDPR, you have the right to ask us to correct your personal data that is incorrect or to complete it.
• The right to erasure: In accordance with Article 17 of the GDPR, you have the right to request us to delete your personal data. In this context, we will delete the relevant personal data as far as possible. Nevertheless, please be aware that such a request cannot affect our right to retain your personal data necessary to meet our legal obligations.
• The right to limitation: In accordance with Article 18 of the GDPR, you have the right to ask us to restrict the processing of your personal data, in any of the following cases: when you dispute the accuracy of such personal data or consider that we would process them in contravention of our obligations, but you do not wish, in the immediate future, their deletion; in either case, we must suspend the processing of your personal data, while we carry out the necessary verifications; when we no longer need such data but you need them to claim, exercise or/and defend your rights; in this case, we must retain your personal data that are necessary for you.
• The right to portability: In accordance with Article 20 of the GDPR, you have the right to ask us to transmit your personal data to you and/or to a third party of your choice, in a format that is technically usable by you or by the third party
• The fate of personal data: In accordance with Article 85 I. of the LIL, you have the right to give us instructions concerning the fate of your personal data after your death.
• The right to refer to a supervisory authority: You have the right to lodge a complaint with any competent control authority.

8.2. Terms of exercise

If you wish to exercise any of these rights, you may send your request:

• By post, to the attention of the DPO, at the above-mentioned address of Bloom Media Group's headquarters.

No payment will be required for the exercise of your rights, other than the possible costs of sending your requests, except in the case of repetitive and obviously unfounded requests. Please be aware that Bloom Media Group may ask you for additional information to confirm your identity.

8.3. Processing your request

8.3.1. In the context of data transfer for matchmaking.

Once we have received your request to exercise your right(s), if applicable, Bloom Media Group will inform the Partner(s) to whom your personal data has been transferred, so that they can process your request. Indeed, once your personal data obtained for the purpose of being put in contact with our Partners has been transferred to them, Bloom Media Group does not contact you directly. Thus, it is possible that there is a certain delay between the moment when Bloom Media Group confirms that it has processed your request, and the moment when this request is also processed by the Partner(s) concerned.

Bloom Media Group stores your personal data transmitted on the occasion of your request to exercise your rights as well as our subsequent correspondence. The legal basis for the processing of this personal data is Article 6, paragraph 1 f) of the GDPR, namely our legitimate interest. The legitimacy of this processing is to be able to prove that we have processed your request to exercise your right(s), within the time limit set. These personal data are kept in the form of archives, for a period of 5 years from the final processing of your request, with the exception of the copy of your identity card which will be deleted as soon as your identity is confirmed. Only a referent and the DPO have access to this archive.

8.3.2. In the context of data processing directly by Bloom Media Group.

Bloom Media Group undertakes to provide the data subject with information on the measures taken, following a request made pursuant to Articles 15 to 22 of the GDPR, as soon as possible and in any event within one month of receiving the request. If necessary, this period may be extended by two months, taking into account the complexity and number of requests. Bloom Media Group will inform the person concerned of this extension and the reasons for the postponement within one month of receiving the request. Where the data subject submits his or her request in electronic form, the information shall be provided electronically where possible, unless the data subject requests otherwise. If the controller does not comply with the request made by the data subject, it shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for its inaction and of the possibility of lodging a complaint with a supervisory authority and of bringing a legal action.

Bloom Media Group keeps a register of requests for access, rectification, and opposition for legitimate reasons. Bloom Media Group may share certain personal data with:

• Subcontractors who process certain services in relation to personal data for the sole purpose of providing technical assistance to Bloom Media Group, such as hosting providers.
• Competent authorities to whom Bloom Media Group may be required to disclose information in the context of legal proceedings or to detect technical and/or security problems.

8.4. Advertising solicitations sent by our Partners

In the event that you wish to withdraw your consent to receive advertising solicitations from one of our Partners, Bloom Media Group invites you to make your request directly to the latter.