Bloom Future – Data Protection Policy

1. Introduction

In the following, we provide information about the processing of personal data when using of the Bloom Future app (mobile or web app).

Personal data is all data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details

The controller pursuant to Art. 4 para. 7 of the EU General Data Protection Regulation (GDPR) is

The Bloom Factory GmbH,
c/o Campus Founders,
Bildungscampus 1,
74076 Heilbronn,
Germany,
e-mail: info@bloom-future.de.

We are legally represented by Kevin Costa, Carlo Mailänder.

Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal bases

The scope of data processing, processing purposes and legal bases are explained in detail below. The following legal bases for data processing are generally considered:

• Art. 6 para. 1 s. 1 lit. a GDPR serves us as the legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.
• Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for cookies that are required for the technical operation of the Bloom Future app.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 GDPR guarantee the security of the data during transfer, insofar as these exist, as is the case, for example, for the UK, Canada and Israel.

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision by the EU Commission if the service provider is also certified under the EU US Data Privacy Framework.

In other cases (e.g. if there is no adequacy decision), the legal basis for data transfer is usually standard contractual clauses, unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they guarantee the security of data transfer. Many of the providers have provided contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies wish to access data.

1.4 Storage period

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5 Rights of the data subjects

Data subjects have the following rights vis-à-vis us with regard to their personal data:

• Right of access,
• Right to rectification or erasure,
• Right to restriction of processing,
• Right to object to the processing,
• Right to data portability,
• Right to withdraw consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

In the context of a business relationship or other relationship, customers, interested parties or third parties must only provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or for the other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automated decision-making in individual cases

In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. If we use these procedures in individual cases, we will provide separate information about this if this is required by law.

1.8 Making contact

When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) in answering inquiries addressed to us. We delete the data arising in this context after storage is no longer necessary or restrict processing if there are statutory retention obligations.

1.9 Competitions

We occasionally offer competitions via the Bloom Future app or in other ways. We process the data requested to determine and notify the winners. We then delete the data. We may also offer competitions only for existing customers. In this case, we only process the name to determine the winners and the contact details to notify the winners. It is in our legitimate interest to offer competitions to attract customers or to interact with our existing customers. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

1.10 Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. We collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used our services or purchased goods about our offers from time to time by email or other means, provided they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time at no additional cost, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for the purpose of sending the newsletter. Registration takes place by selecting the corresponding field in the context of our services, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Consent can be withdrawn at any time, e.g. by clicking on the corresponding link in the newsletter or by sending a message to the email address provided above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click rate of our newsletters in order to understand which content is relevant for our recipients.

We send newsletters using the Pipedrive tool from the provider Pipedrive OÜ, Mustamäe tee 3a, 10615 Tallinn, Estonia. The provider processes content, usage, meta/communication data and contact data in the EU. Further information can be found in the provider's privacy policy at https://www.pipedrive.com/en/privacy.

We send newsletters using the Apollo tool from the provider ZenLeads Inc, 340 S LEMON AVE #4750 WALNUT, CA 91789, USA. The provider processes content, usage, meta/communication data and contact data in the USA. Further information can be found in the provider's privacy policy at https://www.apollo.io/privacy-policy/.

3. Data processing in the context of the Bloom Future App

3.1 Note for users from Germany

The Bloom Future App stores information in the user's terminal equipment (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). The following sections show what information this is in detail.

This storage and access takes place on the basis of the following provisions:

• Insofar as this storage or access is absolutely necessary for us to provide the service expressly requested by users (e.g. to implement a chatbot used by the user or to ensure the IT security of the Bloom Future App), it is carried out on the basis of Section 25 para. 2 no. 2 of the Telecommunications Digital Services Data Protection Act (TDDDG).
• Otherwise, this storage or access is based on the user's consent (Section 25 para. 1 TDDDG).

Downstream data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use

When using the Bloom Future App for informational purposes, i.e. when site visitors do not transmit information to us separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our Bloom Future App. This is our legitimate interest, so the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• browser
• Operating system and its interface
• Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer required, at the latest after 14 days.

3.3 Web hosting and provision of the Bloom Future App

The Bloom Future App is hosted in the EU by the following providers:

• Bubble Group, Inc. 61 Regent Street, Cambridge CB2 1AB, UK;
• Digitalocean LLC, 101 Avenue of the Americas 10th Floor, New York, NY 10013, USA
• Supabase, Inc, 970 Toa Payoh North #07-04, Singapore 318992, Singapore

It is our legitimate interest to provide the Bloom Future App, so the legal basis for the data processing described is Art. 6 para. 1 s. 1 lit. f GDPR.

3.4 Access to functions or data

The app requests the user's access to functions of the end device or to data of the end device in order to be able to execute functions of the app. By allowing access, the user consents to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of the end device. The revocation does not affect the legality of the processing until the revocation.

The data processed or access functions used in this respect are

• Camera,
• microphone,
• location and
• existing photos

3.5 User account

Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded via the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.

3.6 Single sign-on

Users can log in to our app using one or more single sign-on procedures. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. If a user logs in using the single sign-on procedure, we receive information from the provider that the user is logged in with the provider and the provider receives information that the user is using the single sign-on procedure in our app. Depending on the user's settings in their account on the provider's website, the provider may provide us with additional information. The legal basis for this processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.

The providers of the process(es) offered are:

• Apple Inc, Infinite Loop, Cupertino, CA 95014, USA (privacy policy: https://www.apple.com/legal/privacy/de-ww/).
• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Privacy Policy: https://policies.google.com/privacy).

3.7 Contact form

When you contact us via the contact form, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data arising in this context after storage is no longer required, or restrict processing if there are statutory retention obligations.

3.8 Chats & matching

In order to provide users with effective career guidance as part of the "Bloom Future" app, the data actively entered by the user in the chat is processed, such as their hobbies, interests, strengths and, if applicable, other preferences (e.g. desired occupational fields or places of work). This information is used to support the user with career guidance.

The data entered by the user in the chat and the creation of the user's internal profile are processed on the basis of Art. 6 para. 1 s. 1 lit. b GDPR, as these processing steps are necessary for the provision of the contractually agreed service – personalized career guidance and creation of the user profile.

Based on this internal profile, suitable job offers, apprenticeships or internships from potential employers or educational institutions (hereinafter "job providers") can be suggested to the user (matching). No data is passed on to third parties.

3.9 Third-party providers

3.9.1 heyData

We have integrated a data protection seal. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing users with confirmation of our data protection compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative to confirmation.

The data is masked after collection so that there is no longer any personal reference. Further information can be found in the provider's privacy policy at https://heydata.eu/datenschutzerklaerung.

3.9.2 Google Cloud / Vertex AI

We use Google Cloud services, in particular Vertex AI, to provide LLM-based chat responses within our mobile app "Bloom Future". The provider of these services in the EU/EEA is Google Cloud EMEA Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Vertex AI is used to process the information entered in the chat about hobbies and interests and to generate personalized suggestions and career guidance information based on this. This processing is a core component of the functionality of our app in order to be able to make suitable career suggestions. The legal basis for the processing of your data (entered hobbies and interests) by Google Cloud Vertex AI is Art. 6 para. 1 s. 1 lit. b GDPR, as the processing is necessary for the fulfillment of the user contract of our app and the provision of the chat functionality for career guidance.

Further information on data protection at Google Cloud and Vertex AI can be found in Google Cloud's privacy policy at: https://cloud.google.com/terms/data-processing-addendum and https://cloud.google.com/privacy/gdpr.

4. Changes to this privacy policy

We reserve the right to amend this privacy policy with effect for the future. A current version is always available here.

5. Questions and comments

If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details provided above.