Version 1.0
Last update: 05/20/2024
Bloumer PRIVACY POLICY
General Information
Bloumer Media Services' Privacy Policy (hereinafter 'Bloumer') is
intended to clarify our company's data processing and privacy
practices.
Bloumer is a technology company that provides
retargeting services.
Our retargeting service involves
displaying product and service ads based on a potential customer's
interests.
To provide this service Bloumer uses an
artificial intelligence algorithm that identifies a potential
customer's interests based on their browsing behavior and
consumption patterns (research interests geographic location).
This data is collected without identifying the potential
customer.
By using this data Bloumer's clients
("Advertisers") can offer targeted media to their end customers
based on their browsing behavior. This means that Advertisers can
display ads in banners on internet pages blogs and partner
websites ("Publishers") that their customers usually visit.
When
providing this service Bloumer's algorithm does not collect personally
identifiable data such as full name gender document numbers
mailing address and email address. The data collected by Bloumer is
solely related to user behavior while browsing websites as well as
their preferences. This data is collected by assigning a random
identifier to ensure user anonymity.
A user's
identifier is randomly assigned to identify a user's behavior
pattern while preserving anonymity. Due to the randomness of this
process it is not possible to identify personal data or reverse
the anonymization process.
Additionally the data
collected related to a potential consumer's browsing patterns is
processed only by Bloumer. There is no third party or middleman in
this data processing. Therefore privacy is one of Bloumer's
principles.
This is also why we prioritize transparency
and accessibility. The terms of our relationship are available and
understandable to our customers partners and website visitors.
Service
Bloumer offers a retargeting service to its Advertisers as described
above.
How Our Service Works
Bloumer provides an internet advertising service called retargeting.
For this purpose users' navigation data is collected when they
enter one of our partner's websites. This data collection is
carried out using tags—a set of programming code added to a
partner's website. These tags work in the background without the
user's knowledge. Importantly no personally identifiable data is
collected.
From there the user may be impacted by a partner's ad through
Bloumer's retargeting services. The goal is to nudge the user to
return to a partner's website to purchase the product or service
that they showed interest in on the partner's website.
Data Collection and Use of Personal Data
Bloumer does not collect personally identifiable data when a user
accesses any Publisher's or Advertiser's website. This means Bloumer
does not collect any data that could identify a user while
browsing a website.
Personal data of users will only be
collected by Bloumer with consent except in other cases provided for
in this Privacy Policy and in cases of legal requirements.
Legal Basis: Article 7 Item I of Law No. 13.709/18 The data
collected by Bloumer is considered "anonymized data" by law and during
the processing of such data it is not possible to reverse the
anonymization process meaning it is impossible to identify the
data subject due to the Information Security procedures adopted by
Bloumer and indicated in this Privacy Policy.
User's
personal data will only be collected by Bloumer upon consent, except
for other cases provided for in this Privacy Policy or by legal
requirement.
What Data Do We Collect from Users?
Through tags (set of programming code added to a Publisher or
Advertiser's website background) Bloumer collects data related to a
user's browsing activity such as:
• From which website the user came from;
• For how long the user stays on each page of the partner's
website;
• The last page visited on the partner's website before
abandonment;
• If a user has visited a product the visited product identifiers
(IDs);
• If a user added products to a shopping cart the IDs of such
products; and
• If a user makes a purchase the IDs of the purchased products the
total amount of that sale and the transaction ID.
Why Do We Collect This Data?
The data collected allows us to display highly relevant ads to
users who have shown interest in making a purchase on one of Bloumer's
partner websites. The algorithms used by Bloumer rate each step in a
purchase journey with a different level of importance to perform
the ad display service. The closer the user gets to the end of a
purchase process the more relevant the ad will be to them.
Product
identifiers (IDs) enable Bloumer to link products of interest to a
user with similar products in terms of category and price. This
process aims to offer products with a high probability of interest
to the user through online advertising.
Data Storage Duration and Location
All collected data is stored for 180 days on Bloumer's encrypted
servers provided by AWS (Amazon Web Services) cloud computing
services. Bloumer has no physical servers for data storage. Access to
the servers is only through passwords and protected by encryption.
How Bloumer's Employees Handle Data
User browsing data is used by the artificial intelligence
algorithms of Bloumer's retargeting service. This data is used in an
aggregate way to direct content according to the preferences that
a set of users present through the identifiers randomly assigned
to them by Bloumer's algorithm. Therefore there is no
individualization of users during the retargeting activity.
Due
to this process Bloumer's employees do not have access to specific
user browsing data nor perform any analysis on such data. The
browsing data is used by the artificial intelligence algorithm to
perform a classification process and then assign each product
identifier to the identifier of a user who has shown interest in
that product.
Data Storage
All collected data is stored on encrypted servers protected by
passwords and accessed only by Bloumer's technical responsible (CTO)
or Bloumer professionals with a technical clearance level whose access
is also controlled by the company's CTO. All servers are stored in
the cloud and are used as a service offered by AWS (Amazon Web
Services).
The data remains stored for a maximum of 180
days. After this period the data is permanently deleted from the
servers. Once data is deleted from the servers Bloumer's retargeting
service cannot target new ads to a user unless that user returns
to one of Bloumer's Advertiser partner's websites. If a user returns
to an Advertiser's website the storage process is renewed and
follows the same pattern described in this paragraph all over
again.
Bloumer only retains data required by law or by any
authority competent to make such a request.
Adherence to the IAB Transparency & Consent Framework
We hereby inform you that Bloumer is a participant in the IAB Europe
Transparency & Consent Framework. In this capacity, we adhere
to the Policies and Specifications outlined in the Transparency
& Consent Framework. Additionally, our assigned Vendor ID is
1105. Users may reference this Vendor ID to obtain further
information regarding our compliance with these requirements, if
needed, by visiting
https://iabeurope.eu/vendor-list-tcf/
International Data Transfer
The servers used by Bloumer are distributed in four regions of the
world: Brazil the United States Germany and Singapore. All servers
in each location have identical corresponding servers for
redundancy. Information exchange occurs only within the server
environment ensuring that no data processing occurs in
jurisdictions outside of Brazil.
This structure ensures
that information frequently used remains in the location of the
service provided minimizing latency in response to requests made
by any user to these servers.
Data Security
All collected information is stored and treated in a maximum
security environment. The entire environment is encrypted
password-protected and controlled directly by the company's
technical responsible (CTO). Additionally these servers have
redundancy features to prevent data loss in case of collapse or
other threat situations.
The browsing data collected
during the retargeting process is stored on our servers with
strict encryption control. Only the technician responsible for the
company (CTO) has access to these servers. The data remains stored
for a maximum of 180 days.
Access to any of the
databases mentioned above is password-protected and managed by a
person responsible for each of the information storage and
processing platforms.
Rules for Advertisers and Publishers
We only accept Advertisers/Publishers who commit to a minimum
standard of privacy. This means that our Advertisers or
Publishers:
(i) Must have a privacy policy, which is
requested whenever Bloumer enters into a contract with an Advertiser
or Publisher.
(ii) May not use any Bloumer product or
service to violate users' privacy rights.
(iii) May not
use or process personal or sensitive data without the prior
consent of the holders of such personal data or without any other
legal basis that legitimizes such action.
Cookie Policy
We use some internal cookies to address assign an identifier and
store a user's browsing data in our environment such as:
ckid:
This cookie is an identifier (ID) provided by the user's internet
browser and is used to pair the user with relevant products in
marketing campaigns.
hash: An
identifier (ID) generated in a randomized process to ensure the
impossibility of identifying a user maintaining anonymity. The ID
is generated through the ckid.
BloumerID:
An identifier (ID) generated to ensure that a user does not
receive an ID more than once avoiding duplication in the system,
even if the user leaves the internet browser and starts another
browsing session.
Benefits of Using Cookies
Cookies save certain browsing information. Thus when a user visits
a Bloumer partner website again it will recognize the user's browser
and maintain previously set options and preferences especially
regarding their preferences when searching for products and
services on the internet.
What Happens if Cookies Are Not Accepted?
Once we place our tags within a partner website's environment the
partner is responsible for notifying users about the use of
cookies. If the user rejects the use of cookies our tags will not
be triggered and anonymous information about that user will not be
collected. Thus our retargeting service will not work for that
user in terms of their browsing behavior on the partner's website.
Consequently the user will no longer receive ads related to their
buying behavior.
OPT-OUT
If you do not want ads targeted by Bloumer to appear during your
internet browsing you can access the link
https://www.bloumer.com/optout
to disable the service and prevent cookies from targeting your
browsing information.
Erase Personal Data
Data deletion will only occur when there is an explicit request
from a personal data subject provided Bloumer has collected their
personal data. As a business rule due to a privacy by design
principle Bloumer does not collect personal data. The data stored from
internet users is anonymized by the process explained at the
beginning of this policy.
Therefore, no identifiable
data is stored by Bloumer and it is not possible to identify a user by
using Bloumer's services. Therefore the rules of the Brazilian General
Data Protection Law do not apply to users who provide anonymous
data to Bloumer.
Legal Basis: Section 12 in Brazilian Law No. 13.709/1
If a personal data subject wants to make any request check their
personal data or request changes or deletion of personal data they
may request such access directly from an Advertiser or Publisher
who is a Bloumer customer. The holder of personal data may also
request Bloumer to confirm the existence of the collection and
processing of personal data and if confirmed the corresponding
change and/or deletion.
Any personal data request made
directly to Bloumer must be made through the following link:
https://www.bloumer.com/dataremoval. Personal data collection and processing will not be performed
due to the use of Bloumer's retargeting product but for any other
business reason that leads to the collection and processing of a
subject's personal data.
Amendments
Bloumer may change this Privacy Policy at any time. Each version of
the Privacy Policy will contain the effective date and version at
the beginning of the document to ease user identification. You can
also request an old version of the privacy policy for
consultation.
Any changes to the Privacy Policy will be
communicated to users and to continue using the services provided
by Bloumer this Policy must be accepted by users.
Personal Data Requests
Any situation regarding personal data should be communicated to
[email protected]Responsible (DPO):Salma Homenick
[email protected]
Disputes
This Privacy Policy is governed by the laws of the Federative
Republic of Brazil. Any dispute arising from this Privacy Policy
or Bloumer's service will be resolved under the jurisdiction of the
Court of the District of São Paulo State of São Paulo Brazil. Any
other jurisdiction is deemed excluded regardless of any privilege
it may have or acquire. Any dispute will be resolved in Portuguese
and in São Paulo State of São Paulo Brazil.
Privacy and Data Protection Policy
Overview
This document provides an overview of the personal information we may collect, how we utilize and protect that information, and the rights you have under the GDPR. We are committed to safeguarding your privacy and managing your data responsibly.
- 1. Information We Collect: We may collect various types of personal information, including:
- Identity Information: Such as your name, title, date of birth, and gender.
- Contact Information: Including your email address, phone number, and postal address.
- Technical Data: Such as your IP address, browser type, operating system, and platform.
- Usage Data: Information about your interactions with our website and services.
- Marketing Preferences: Details about your preferences for receiving marketing communications.
- 2. How We Use Your Data: We may use your personal information for various purposes, including:
- Service Provision: To manage your requests, administer your account, and provide support.
- Website Enhancement: To evaluate user interactions and improve the functionality and experience of our website.
- Marketing: To send you promotional materials you have opted to receive.
- Legal Compliance: To fulfill legal and regulatory requirements.
- 3. Data Sharing: We may disclose your personal information to:
- Service Providers: Third parties who assist with operating our website and delivering services.
- Regulatory Authorities: When required by law or to protect our legal interests.
- Business Transactions: In the event of business transfers such as mergers, acquisitions, or asset sales.
- 4. Data Security: We implement measures to protect your personal information, but no online system can offer complete security.
- 5. Your Rights: Under GDPR, you are entitled to the following rights regarding your personal data:
- Access: Request access to the personal data we hold about you.
- Correction: Ask for corrections to any incorrect or incomplete data.
- Deletion: Request the removal of your data under certain conditions.
- Restriction: Ask for limitations on the processing of your data in specific cases.
- Objection: Object to the processing of your data for marketing purposes.
- Portability: Request your data in a structured, commonly used format.
- 6. Data Retention: We will keep your personal information only as long as necessary to achieve the purposes for which it was collected, including for legal and reporting purposes.
- 7. Cookies: Our website uses cookies to improve your browsing experience. You can configure your browser to reject cookies if you prefer.
- 8. Policy Updates: This policy may be updated from time to time, so please review it periodically to stay informed.
- 9. Contact Information: If you have any questions about this policy or our handling of your personal data, please get in touch with us.
Contact Details:
Design Energy Engineering, LLC
Addres: 11508 Hwy 238,
Afton, WY, 83110,
USA
CFO: Dee J Rammell
Phone: +1 256-555-5698
