Bloomthrives.com is an insurance services company focused on enabling health plans to increase membership and improve the enrollee experience  (referenced as “Bloom,” “We,” “Us,” “Our”). This Privacy Policy (“Privacy Policy”) is designed to inform users of the content or features within our website, and how they are available as support, resources, or tools.  This Privacy Policy is meant to provide you with some transparency by helping you understand the information we collect, why we collect it, and how you can manage it, so you know what to expect.  In this Privacy Policy, any use of the words “you”, “yours” or similar expressions refers to users of our Services, as well as any other individuals whose information we collect and process. 

This Privacy Policy applies to the website (https://www.bloomthrives.com/) and any of our enrollment platforms (also referenced as “Sites”), mobile applications and emails (“Services”). 

Information that we collect and process includes protected health information or PHI.  The privacy and security of your PHI is protected by the Health Insurance Portability and Accountability Act of 1996, as amended, (“HIPAA”) and its implementing regulations, including its final privacy regulation, at 45 C.F.R. Parts 160 and 164 (known as the “Privacy Rule”), as administered by the federal Department of Health and Human Services. HIPAA places certain restrictions on the use and disclosure of PHI and requires us to protect the privacy and security of your PHI.

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after our Sites, and which are not governed by this Privacy Policy.  We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

By accessing this Website, its content, tools, and/or Services, you agree to abide by this Privacy Policy and Our Terms and Conditions. If you need any additional clarification or have questions on this, please contact us at privacy@bloominsurance.com. 

1. What information do we collect? 

We receive and store any information you enter on our Site or otherwise voluntarily provide to us, including your name, address, email address and your phone number.  Notwithstanding the generality of the foregoing, we collect the information that you provide to us when you sign up for a seminar or other educational event, request a call from us, or otherwise contact us by phone or email. Depending on your use of our Services, the information collected may include: 

• Information you provide to us by completing certain forms on our Sites or when requesting assistance with healthcare plan comparisons.  For example, your first and last name, phone number and e-mail address.  
• Information you provide to us by contacting us when you call or e-mail, such as first and last name, phone number and e-mail address.  We may also request your contact information for the purposes of having someone contact your for additional information or to provide or in response to your request for information from us. 
• Information you provide to us by registering for one of our seminars or our events, or when subscribing to our newsletter.  Information collected may include your first and last name, phone number and e-mail address.  
• Information that may include personal health information (“PHI”), which is protected by HIPAA (see section entitled “Protected Health Information (PHI) and HIPAA” for more information).  If you choose to enroll with a health plan on our Site, your PHI may be transferred through the Site to the health plan you have chosen.
• Log-in information, such as username and password, that you may use in connection with our Services.
• Within our infrastructure, you can provide PII when registering for a seminar or event; requesting assistance with healthcare plan comparisons; downloading content; subscribing to a newsletter; or requesting we contact you. The provided PII can be used on its own or with other information to identify, contact, or locate a single person, or to better identify an individual in context. We house this information in a secured, encrypted database environment/solution. Any of this PII or PHI data is captured to be used for the purpose of helping to facilitate or complete your requests.

We will also collect other demographic and personal information about you, including your PHI which is protected by HIPAA.  If you choose to enroll with a health plan on our site, your PHI is transferred through the Site to the health plan you have chosen.

The Site contains a link to a Medicare quoting and enrollment tool, Ascend and Health Activations (“Health Plan Tools”). Any data that you submit utilizing the Health Plan Tools is sent to the health plan for approval for enrollment into their Medicare Advantage plan.  Health plans are unaffiliated with us, and we are not responsible for the content or privacy practices of health plans.  Health plans have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms. 

From time to time our interactions with you will be conducted over the telephone or via videoconferencing, and such telephone calls and videoconferencing exchanges may be recorded.

1. “Cookies”

The Services may capture some information about you automatically utilizing background local storage and session storage technologies (“Cookies”).  Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services (including certain third-party services and features offered as part of our website). 

When you search, use, or access our Services, we and our service providers may collect anonymous data (Non-PII) to help us understand our visitor actions (content searches, U.S. region, inquiries, etc.) in order to provide better or more personalized services and experiences for you. Similar to most websites you may access, https://www.bloomthrives.com/ may capture generic online data using “cookies” or similar generic data capture technologies.  Anonymous Information we collect from visitors of our Site and other social media or search channels includes:  

• IP addresses
• Source channel that drives visitors to our website and/or referral destination information
• Browser (which search engine) and device-type details (laptop, tablet, mobile phone) 
• Number of visits, return visits, page views, time on our website, time of visit
• Internet Service Provider
• Region or geographic location
• And other similar generic metrics that do not refer to you individually

When we use Cookies, we may use “session” Cookies that last until you close your browser or “persistent” cookies that last until you or your browser delete them. We may also use other tracking technologies such as web beacons, embedded scripts and entity tags.  Some Cookies are “strictly necessary” for system administration, fraud prevention, and improvement of our Services.  We will also use Cookies or other tracking technologies to assess the performance of the Services, as part of our analytics practices, and to improve the content, products, and Services we offer through the mobile application, website, and Services. 

Analytics Cookies: We use Google Analytics, a web analytics service of Google Inc. (“Google”) which uses cookies to identify the frequency of use of certain areas of our Services and to identify preferences.  For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/.  The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with the Sites and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here:  https://tools.google.com/dlpage/gaoptout?hl=en.

Facebook Insights: We use the Facebook Insights function in connection with the operation of our Facebook Page and, on the basis of the GDPR, in order to obtain anonymized statistical data about our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services. For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation.

LinkedIn: We use functions of the LinkedIn network when posting career opportunities, when maintaining our Linkedin page and in order to obtain anonymized statistical data about our users.  For these and other purpose, LinkedIn places a Cookie on the device of the user visiting our LinkedIn Page.  LinkedIn uses two types of cookies, persistent cookies and session cookies, to recognize you when you visit LinkedIn, customize your experience and enable the functionality of certain LinkedIn services. These Cookies allow LinkedIn to gather information about you.  LinkedIn also allows third parties, such as customers, partners and service providers to use Cookies in connection with LinkedIn’s services.  For more information about LinkedIn’s privacy practices, please visit LinkedIn Privacy Policy here: https://www.linkedin.com/legal/privacy-policy.  For more information about LinkedIn’s Cookie practices, please visit LinkedIn’s Cookie Policy here: https://www.linkedin.com/legal/cookie-policy?trk=content_footer-cookie-policy. 

Other Social Media: If you use other Social Media, we may receive your information from the organizations offering those services.  Their sharing with us of such information is subject to their privacy practices, likely found in their privacy policies.  We are not responsible for the privacy practices of third parties.  Please read any applicable third-party privacy policies carefully. You may be able to limit the sharing of your information via their privacy policies. 

Controlling Cookies: Most web browsers automatically accept “cookies,” but if you prefer, you can edit your browser options to block or remove them in the future. The “Help” tab on the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, however, certain features on our Sites may not be available or function properly.

If you turn off any cookies, please be aware that you may lose some of the functionality of our websites. For more information about cookies and how to disable them please check one or more of the following resources: http://www.allaboutcookies.org/.

Consent to Use Cookies: The first time you visit our websites, a cookie notice may be displayed describing our use of cookies, and linking to this Cookie Policy. As described in that notice, the cookie choices you make the first time you visit our Sites will be used for your future use of the Sites.

2. How do we use your information?

Any of the information we collect from you may be used to personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested, to improve your user experience of our Services, and to allow us to better service you in responding to your questions and comments.  Specifically, we use the personal data we collect to respond to your inquiries, provide or enhance the Services you request, perform our contractual obligations, provide updates and other important information related to your activity on and with the Services, improve the Services,  inform you of new Services or changes in Services, administer the Services, enter into contracts for services, fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes. 

We may also use your information to troubleshoot problems, comply with a legal obligation such as court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law, and to respond as required for a corporate transaction, such as a divestiture, investment, merger, consolidation, or asset sale, or other significant matter.

Notwithstanding the generality of the foregoing, we may contact you via email or phone, if you requested, or gave us permission to give you a call-back. 

We use and share deidentified data with a third-party vendor to develop target modelling which is used to enhance our Services to you.  We also share your mailing information with third party printing vendors when you opt in to receive direct mailings from us through the Site.  

The information that is collected with the tools on this Site may be used to assist your enrollment in the health plan you have chosen.  When you interact with those tools, You consent to have that information provided to the Site and then transferred to that health plan.

You will have the opportunity through your user settings to opt out of any electronic marketing communications you may receive from us.  

1. Protected Health Information (PHI) and HIPAA

Our organization is dedicated to assisting people with aspects of healthcare insurance services, Medicare, and other topics related to general health needs. Through those efforts, you may provide us with some general contact information (personally identifiable – PII) as you explore Medicare Plans comparison options, resources, etc. 

In addition to the collection of PII, we have outlined above, you should know that we collect and process information that also includes protected health information (“PHI”).  The privacy and security of your PHI is protected by the Health Insurance Portability and Accountability Act of 1996, as amended, (“HIPAA”) and its implementing regulations, including its final privacy regulation, at 45 C.F.R. Parts 160 and 164 (known as the “Privacy Rule”), as administered by the federal Department of Health and Human Services. 

HIPAA places certain restrictions on the use and disclosure of PHI and requires any entities who retain any of your personal health information to protect the privacy and security of it through its business practices, processes, and systems. Given those regulations, organizations with access to this data can only provide or disclose PHI as permitted or required under the Health Insurance Portability and Accountability Act regulations. 

Individual states may have supplemental protection policies as well. Please consult with your state’s healthcare departments for those additional requirements or guidelines.

B. Email and Mobile Device Notifications

We try to keep email communications to a minimum, and give you the ability to opt-in/opt-out to any marketing communications we may send. For example, we may send you email relating to the Services we offer or requesting you to sign up our seminars. You may also elect to receive certain marketing communications in accordance with your preferences, and from which you may opt-out at any time. 

You can always opt-out of receiving marketing emails or mobile device notifications from Bloom (other than certain required communications, such as messages notifying you of any privacy policy updates), by logging into the app and adjusting your user preferences in your account profile, or by sending us an email at privacy@bloominsurance.com or by phone at (855) 405-7619 stating your request. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future optional notices. 

3. How Information may be Shared

In connection with the provision of our Services, we may share your information with internal personnel and our affiliates located in difference geographic locations in order to perform our Services.  We may also share your personal data with certain trusted third-party services who perform services on our behalf to help us provide, improve, promote, or protect our Services, including without limitation our online store hosting provider, print vendors, payment processors, email delivery provider, customer service tools, cloud hosting provider and professional advisors. Whenever we share data with third-party services, we seek written commitments from such third parties that that they will protect the data with safeguards that are substantially equivalent to those used by Bloom.

When you utilize Health Plan Tools, we will share information with health plans you choose.

We may disclose information if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.  

Your information may be transferred to another company in connection with a merger or in the event that our business is acquired in whole or part by another company. 

We may share aggregated and de-identified information with third parties for analytical, research or other similar purposes. 

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.  

4. How do we protect your information?

We take the security of your personal information seriously.  While no website can guarantee complete security, we use industry-standard practices to protect the data we collect and process. Bloom uses commercially reasonable efforts to protect your information, including maintaining reasonable physical, procedural and technical security with respect to its offices and information storage systems so as to prevent any loss, misuse, unauthorized access, disclosure or modification of your information under our control.  

No Internet or e-mail transmission is ever fully secure or error free, however.  We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control.  Users assume the risk of security breaches and the consequences resulting from them.  Please be careful in deciding what information you send to us via email or over the Internet.

5. How do we store and encrypt your data?

Your data is stored at secure locations that use encryption to protect your data when stored on these computer servers or when storing it with a third party. Your data is also encrypted while it is being transmitted.

6. Access to other data

None of our technologies will request access to other device data or applications, such as your phone’s camera, photos or contacts.

7. COPPA (Children Online Privacy Protection Act)

We do not offer subscriptions or services to individuals under 18 years of age.  No one under the age of 18 may provide any information to or on the Site. We do not knowingly collect personally identifiable information or PHI from individuals under 18.  If you are under 18, do not use or provide any information on this Site or on or through any of its features, do not register on this Site, use any of the features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. By using the Site, you represent that you are at least 18 years old. You also represent, by accessing or using the Site, that you are of legal age to enter into legal agreements.

8. Your Privacy Rights, Choices and Disclosures 

General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to make a request, please contact us using the contact information set forth at the end of this policy. 

Consent to be Contacted or Unsubscribe. When you visit our website(s) and/or online solutions, complete online forms, or request to receive electronic communications, SMS (mobile) texts or emails from us, you are offered the “right to be contacted” should you choose to be contacted further or communicated to by us for webinar notifications, new resources, news, technical support requests, etc. At any time following your initial request, you can update and/or consent to be included in any additional outreach efforts by contacting us directly at (855) 405-7619 or submitting an online request. 

You also can UNSUBSCRIBE or request to have your information removed to no longer participate in any communications by Bloom Insurance Agency LLC and its businesses or associations by clicking on our unsubscribe link here.

Some non-marketing communications may not be subject to a general opt-out, such as communications about events you have registered for, disclosures to comply with legal requirements, and other support-related information.   

While we work to ensure “unsubscribe” requests are completed promptly, should we encounter any potential technical or other business issues, we respectfully commit that your change will be implemented within 10 business days or less. Again, please contact us with any concerns or questions about this process.

As noted in greater detail in Section 1(A) above, You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Site.  

California Disclosures.  

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed.  If you are a California resident and want such a list, please send us a written request by email to privacy@bloominsurance.com with “California Shine The Light Rights” in the subject line.  

California Do Not Track Disclosure: We do not respond to Do Not Track browser settings.  At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, our Online Services are unable to respond to Do Not Track Signals.

California Consumer Privacy Act (CCPA) Disclosures. Under CCPA, California residents have the right to request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose of collecting or selling personal information;
• The categories of third parties with whom we share or sell personal information;
• The categories of personal information about you that we have sold; and
• The specific pieces of personal information we have collected about you.

Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information (if applicable) and the right not to be discriminated against for exercising any of your CCPA rights.

Please see the chart below regarding the categories of data we have collected or received in the 12 months preceding the effective date of this Privacy Policy, from consumers in connection with providing our Site and to whom we may have disclosed the information. 

Personal Information Category	Source of Personal Information	Purpose for Collecting the Personal Information	To whom we disclose the Personal Information
Identifiers such as a name, address, unique personal identifier, email, phone number	Information you provide to us; Information we collect automatically	See Sections 1 and 2 above	See Section 3 above
Protected Classifications under California and federal law, including gender, age and citizenship.	Information you provide to us; Information we receive from third parties	See Sections 1 and 2 above	See Section 3 above
Commercial information such as records of products or services purchased, obtained, or considered	Information you provide to us; Information we collect automatically	See Sections 1 and 2 above	See Section 3 above
Biometric information	We do not collect this information
Internet or other electronic network activity information, including browsing history and search history.	Information you provide to us; Information we collect automatically	See Sections 1 and 2 above	See Section 3 above
Geolocation data that is sufficient to identify a precise physical location.	Information you provide to us; Information we collect automatically	See Sections 1 and 2 above	See Section 3 above
Sensory data, such as audio, electronic, visual, or other similar information.	Information you provide to us. Information we collect automatically	See Sections 1 and 2 above	See Section 3 above
Professional; Professional or employment-related information	Information you provide to us; information received from third parties	See Sections 1 and 2 above	See Section 3 above
Education Information	Information you provide to us; information received from third parties	See Sections 1 and 2 above	See Section 3 above
Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Information you provide to us; Information we collect automatically	See Sections 1 and 2 above	See Section 3 above

We do not sell your personal information for monetary consideration, and personal information may be provided to service providers, including the Applicant Provider and health plans, under Section 1798.140(t)(2)(A) of the CCPA. In the event that the use of third-party cookies constitutes a “sale” under CCPA, you may opt out of the use of such cookies.  Please see Section 1(A) above for more information.

Our contact information is listed at the bottom of this policy. If you would like to make a CCPA request, we will ask for your name and email address. If your name and email address are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information.  You may also designate an authorized agent to make a CCPA privacy request.

9. Users Outside the United States

The Site is controlled and operated from the United States and is directed to users in the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities.    

10.  Links to Other Sites

Our Site may contain links to other websites for your convenience or information, including if you utilize the Health Tools.  These websites may be operated by companies unaffiliated with us, and we are not responsible for the content or privacy practices of those websites.  Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.  

11. Retention

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. We may also be required to hold some types of information to fulfill legal purposes. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable. 

12. Changes to our Privacy Policy

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Site after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.  Please review this Privacy Policy periodically and especially before you provide personal data to us.  The date of the last update of the Privacy Policy is indicated at the bottom of this Privacy Policy. If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below.

Please note that none of our technologies will request access to other device data or applications, such as your phone’s camera, photos, or contacts. None of our technologies share any data with your social media accounts, like Facebook. If you receive any correspondence that appears to be us and asking for that information, please contact us immediately at privacy@bloominsurance.com or by phone at (855) 405-7619.

13. Contact Us

If you have any questions regarding this privacy policy, you may contact us using the information below.

Bloom Insurance Agency LLC
1801 S. Liberty Dr.
Bloomington, IN 47403

Email: privacy@bloominsurance.com