Privacy Policy

last updated October 7, 2019

PURPOSE OF POLICY. The Full Bloom Project (“us”, “we”) is committed to respecting the privacy rights of visitors and other users of our website (the “Site”). This privacy policy describes how we collect, use, process and distribute your information, including Personal Data (as defined below) used to access this Website. We will not use or share your information with anyone except as described in this Privacy Policy. This Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.

Use of any personal information or contribution that you provide to us, or which is collected by us on or through our Website or its content is governed by this Privacy Policy. By using our Website or its content, you consent to this Privacy Policy.

UPDATES TO POLICY. Please read this Privacy Policy carefully. We will alert you to any changes to this Policy by changing the “last updated” date at the top of this Policy. Any changes become effective immediately upon publication on our website, and you waive specific notice of any changes to the Policy by continuing to use and access our site(s). We encourage you to review this Privacy Policy periodically when you use our website for any purpose or engage with us on social media. You are deemed to have accepted any changes to any revised Privacy Policy by your continued use of our website after the revised Privacy Policy is posted.

NOTICE CONCERNING CHILDREN. PLEASE NOTE: We are a general audience site directed to individuals who are at least 18 years old or older, and do not direct any of our content specifically at children under 13 years of age pursuant to the Children’s Online Privacy Protection Act of 1998.

WHAT BASIC INFORMATION DO WE COLLECT?

In operating the Site, we may collect personal information from you in the following situations:

  1. We collect your name and email address if and when you choose to join our mailing list in order to receive a free download. You would be affirmatively consenting to this by providing this information to us in our contact forms. You can unsubscribe from emails at any time using the link provided in every email.

  2. We collect your name and email address if and when you choose to join our mailing list via the “join us” page or by submitting a question through a contact form. In doing so, you will provide us with your name and email address so we can deliver our newsletter to you or respond to your question. You can unsubscribe from emails at any time using the link provided in every email.

  3. If you make a purchase, we collect billing information including name, address and credit card information so that we can process payments and returns to deliver our products or services to you under our contractual obligation.

The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business.

Please note that you are giving the information above (“Personal Data”) to us voluntarily, and by providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at info@fullbloomproject.com. You are not required to provide us with information via these methods to use and enjoy the Site. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

WHAT ADDITIONAL INFORMATION DO WE COLLECT?

(a) AUTOMATIC COLLECTION. Our servers automatically collect visitors’ IP addresses (the number assigned to computers on the Internet), browser types, pages you view, and the dates and times that you access our website. No personal information about you is revealed in this process. The Site may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.

(b) COOKIES. From time to time, we may use the standard “cookies” feature of major web browser applications that allows us to store a small piece of data on your computer about your visit to our Site. Cookies help us learn which areas of our Site are useful and which areas need improvement. We may also use cookies from third party social sites and programs including, but not limited to, Facebook. You may choose to disable cookies through your own web browser’s settings. However, disabling this function may diminish your experience on our Website and some features may not work as intended.

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

WHAT DO WE DO WITH COLLECTED INFORMATION?

(a) PERSONAL INFORMATION. We do not disclose personally identifiable information to any third parties other than those that we use to facilitate the functioning of the site such as a hosting company and email program for newsletter mailings. Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage or store that information, or who have a legitimate need to know such Personal Data (i.e., our hosting provider, newsletter provider, payment processors or team members).

(b) ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.

(c) USE OF COOKIES. We use information obtained from cookies to analyze your use of the Site and to make appropriate changes.

(d) DISCLOSURE OF PERSONAL INFORMATION. We may disclose any information we have for you if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or the users of the Site, or (3) act under exigent circumstances to protect the safety of the public or users of the Site.

(e) REMARKETING. You may receive email from us (if you choose to receive it, and you can opt-out anytime using the provided Unsubscribe link), and you may be remarketed to on Facebook and other online platforms.

SHARING YOUR DATA WITH OTHERS

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

(a) We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

(b) We may disclose your personal data, such as your email address, to our advertisers or directory partners insofar as reasonably necessary to resolve disputes.

(c) Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You should review this payment service provider’s Privacy Policy and practices to determine how they use, disclose and protect your financial data. Their policy can be found here: https://stripe.com/us/privacy.

(d) In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

INTERNATIONAL TRANSFER OF DATA

We are based in the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws in Europe. Transfers to these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained here.

RETAINING AND DELETING PERSONAL DATA

We retain personal data as long as it is needed to conduct our legitimate business purposes or to comply with our legal obligations, or until you ask us to delete your data. Data that we gather for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be permanently deleted.

You may request that we delete your data at any time. However, note that we cannot control the retention policies of third parties. If you wish to have any third parties, including those to whom we’ve transmitted your data, delete that data, you will need to contact those third parties directly.

YOUR RIGHTS

In this Section, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your data. In addition, we reserve the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests, the public interest, or the law.

Update Account Information: You have the right to update or change any information you have provided to us.  To update or delete your information, please contact us at info@fullbloomproject.com.

Confirm Personal Data and Its Use: You have the right to request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your data or deliver your data to third party processors, and for what purposes. We will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.

Change Consent: You have the right to change your consent to our use of your information. In such cases, we may require you to delete your account with us, as described above, and you may not have full access to our website.

Request a Copy of Data: You have the right to request a digital copy of the data that we hold about you.

Transfer Your Data: You have the right to request that we gather and transfer your data to another controller, in a commonly used and machine-readable format, unless doing so would cause us an undue burden.

Delete All Data: You have the right to request that we delete all data that we hold about you, and we must delete such data without undue delay. There are exceptions to this right, such as when keeping your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the exercise or defense of legal claims. Such a request may result in a termination of your account with us and you may have limited or no use of our website.

Emails And Communications:  You may opt out of receiving future email correspondence from us by checking the appropriate box when you subscribe to our newsletter or make a purchase. You may change your communication settings by contacting us at info@fullbloomproject.com

Marketing Communications:  You may opt out of receiving any third party marketing communications or having your personal information used for marketing purposes. You may do this by contacting us at info@fullbloomproject.com.

Processing: You may, in some circumstances restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will not pass it on to third-party processors without your consent, or as necessary to comply with legal obligations or protect your rights or those of others or our company. In addition, you may opt-out of any processing of your data altogether. Note however that doing so may result in the termination of your account and loss of access to our website.

Complaints: You have the right to complain to a supervising authority if you believe we are misusing your data or have violated any of your rights under this Privacy Policy or applicable law. You may exercise any of your rights in relation to your personal data by written notice to us: Full Bloom Project, 226 W. 26th St, 8th Floor - Office 6, New York, NY 10001.

7. SECURITY

We take all reasonable steps to protect your personal data and keep your information secure.  We use recognized online secure payment systems and implement generally accepted standards of security to protect against personal data loss or misuse.  However, no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse.  We cannot guarantee complete security of any information you transmit to us.

By consent to this Privacy Policy, you acknowledge that your personal data may be available, via the internet, around the world. We cannot prevent the use or misuse of your data by other parties.

We will notify you of promptly any known breach of our security systems or your data which might expose you to serious risk.

8. THIRD PARTY WEBSITES

The Site contains links to other websites. If you choose to visit those websites, it is important to understand our privacy practices and terms of use do not extend to those sites. It is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their practices.

9. CONTACT INFORMATION

If you have any questions about this Policy or our practices related to this Site, please contact us at info@fullbloomproject.com.