Mindbloom Privacy Policy
Last Updated: August 26, 2024
PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES, OUR WEBSITE, OR OUR MOBILE APPLICATION.
I. Policy Purpose & To Whom It Applies
Here at Mindbloom, we deeply respect your privacy and information. We thank you for coming to our website and for trusting us in your journey. This Privacy Policy (“Policy”) describes the privacy practices of Mindbloom, Inc. (“Mindbloom,” “we,” “us” or “our”), the ways we collect, use, and disclose your Personal Information when you visit our website, webpages, and mobile app (“Site”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”). This Policy does not represent the privacy practices of any third-party website or application that may collect information, link to or be accessible on or from the Service. This Policy does not apply to identifiable health information that you provide to Mindbloom’s affiliated medical practitioners (“Affiliated Medical Groups”) as part of their intake, clinical treatment, or medical records related to you. For their privacy practices, please refer to the Privacy Practices of the Affiliated Medical Groups.
Neither Mindbloom nor the Affiliated Medical Groups is a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act and its related regulations and amendments (“HIPAA”). Nevertheless, any Personal Information that you provide may be subject to specific protections under applicable state laws, and Mindbloom and its Affiliated Medical Groups may only use and disclose such information in accordance with such applicable laws.
A. International Users; Use Outside the U.S.
The Service is intended solely for users in the United States. Individuals outside of the United States should not use the Service. If you are outside the United States, information related to your use of our Service may be transferred, processed, or maintained outside your state and country, and may be subject to laws in your location that may have less stringent protections than in the United States.
B. Children’s Privacy
Our Service is only intended for users 18 years of age and older. Our Service does not knowingly collect Personal Information of users who are under 18 years of age (“Minors”). We do not solicit or knowingly collect information from Minors, and if we become aware of any such information being collected, we will take immediate action to delete it. Should you become aware that we have collected Personal Information from a Minor, please contact us at support@mindbloom.com.
II. Personal Information We Collect & How We Collect It
“Personal Information” means any information from or about a person that either identifies a person directly or that is reasonably likely to make a person identifiable when combined with other information from or about that person from any source. We do not consider Personal Information to include information that can no longer be used to identify a specific person – for example, de-identified, pseudonymized, anonymized, or aggregate information about you or our other consumers. Additionally, where we de-identify your Personal Information, we commit to maintaining that data in de-identified format.
A. Information You Provide Us.
Personal Information you may provide us through the Service may include:
- Contact data - such as your first and last name, email address, billing and mailing addresses, and phone number.
- Demographic Information - such as your city, state, zip code, biological sex, and age.
- Profile data - such as the username and password that you set to establish an online account with us, preferences, information about your participation in our surveys, and any other information that you add to your account profile.
- Health-related information - such as information about your mental health conditions or diagnoses, pregnancy status, your use of certain medications, health condition related symptoms, and other information about your health that you choose to provide to us through our website’s initial candidate survey. The responses you provide to the initial candidate survey help us assess if we are available in your state and your eligibility. Your responses are not shared with third-party advertising or marketing programs; however, certain marketing and advertising services are notified automatically when a survey has been completed for business analytics, advertising, and marketing purposes.
- Communications that we exchange with you when you email, call, text, or chat with, or communicate with us directly through social media, or otherwise.
- Transactional data - such as information needed to complete your orders placed through the Service, including order numbers and transaction history. All financial and credit card information is directly processed and stored by our service provider Stripe.
- Marketing data - such as your preferences for receiving our marketing communications and details about your engagement with them.
- Program information - such as information about intentions and sessions that you enter in the mobile app.
B. Information From Automated Data Collection; Cookies and Trackers
We receive certain information about you through companies that provide us with such information as part of their relationship with us, including Meta, Google Analytics, Google Ads, Hotjar, Impact, Microsoft Bing Ads, Stripe, and other tools. These organizations may automatically log device data, online activity data, and geolocation data.
- Performance and Analytics - Our Service works with analytics companies that track online activity (e.g., device information, browser details, geolocation, and how you interact with the Service) to understand the number of unique users visiting the Service and to understand how users are navigating our Services.
- Advertising and Marketing - We also work with advertising networks that may track you to measure the effectiveness of the advertisements so that personalized advertisements or offers may be made for you. These third parties may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and of other website and mobile apps – that information may include your IP address, web browser, mobile network information, pages viewed, actions completed on the website and in our mobile app, time spent on pages or in mobile apps, links clicked, and conversion information. This information allows us to determine whether you have visited the Service previously, remembers preferences that you have set, statistically monitors how many people are using our Service and for what purposes, and allows delivery of advertising targeted to your interests. When you create an account or purchase a service from the Mindbloom website, web beacons, pixels, or API from our service providers’, advertising providers’, and marketing providers’ analytics tools may capture and transmit the conversion data to help assess the efficacy of advertising campaigns and inform future advertising.
- Session replay technologies - We may use software code to track users’ interactions with the Service; the replays include users’ clicks, mobile app touches, mouse movements, and scrolls during those sessions. These help us with website optimization to understand how users are engaging with the website.
III. How We Use Your Information
A. Service delivery. We may use your Personal Information to:
- provide, operate, protect, update, analyze, and improve the Service and our business
- establish and maintain your user profile on the Service
- process the purchase of services that are placed through the portal
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages
- understand your needs and interests, and personalize your experience with the Service and our communications
- provide support for the Service and respond to your requests, questions, and feedback
- develop and operate AI tools, as described in more detail below in section VIII.
B. Marketing, advertising, and analytics.
We and our advertising providers may collect and use your Personal Information for marketing, advertising, and analytics purposes:
Interest-based advertising. We engage advertising companies and social media companies that use cookies and similar technologies to collect information about your interactions over time across the Service and other websites, and use that information to serve online ads that they think will interest you. These include, but are not limited to:
- Meta Platforms. We use Meta Platforms (including, Facebook and Instagram) (collectively, “Meta”), a web analytics and advertising service provided by Meta, on our website. The data from Meta is also saved and processed by Meta. Meta may connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Meta’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can control the information disclosed through your Meta accounts by visiting https://www.facebook.com/about/ads, and you can exercise your privacy rights by visiting https://www.facebook.com/help/contact/784491318687824.
- Google Analytics and Google Ads. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our website. We also use Google Ads, an internet-based advertising service, to advertise our services and analyze the performance of our advertising campaigns. You can find out more about how Google uses data by visiting “How Google Uses Data When You Use Our Partners’ Site or Apps” located at www.google.com/policies/privacy/partners/. For information on Google Analytics, please visit www.google.com/analytics/learn/privacy.html. You can control information disclosed via Google Ads by visiting http://www.google.com/settings/ads and also by installing Google Ads Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. You can delete your activity by visiting https://support.google.com/accounts/answer/465?hl=en.
- Microsoft Bing Ads. We use Bing Ads, an internet-based advertising service, to advertise our services and analyze the performance of our advertising campaigns. You can find out more about how Bing uses data by visiting the “Microsoft Privacy Statement” located at https://privacy.microsoft.com/en-us/privacystatement. You can control information disclosed via Bing Ads and opt out of personalized Bing advertising by visiting https://account.microsoft.com/privacy/ad-settings and https://account.microsoft.com/privacy/third-party-ads. To request that your data be deleted, please visit https://www.microsoft.com/en-us/concern/privacy. For more information, you can access Microsoft’s Privacy Dashboard at https://account.microsoft.com/account/privacy.
- Impact Radius. We use Impact Radius, a web analytics and affiliate advertising service, on our website. For more information about the privacy practices of Impact Radius, please refer to: https://impact.com/privacy-policy/.
- AddShoppers. We use AddShoppers, a social commerce and marketing platform designed to enhance user engagement, personalize marketing, and provide performance analytics. For more information on the privacy practices of AddShoppers, please refer to: https://www.addshoppers.com/privacy.
- X (formerly Twitter). We use X to advertise our services, understand user browsing and purchasing behavior, and analyze the performance of our advertising campaigns. X collects various data, which may be used for analytics and advertising purposes. You can review X's data practices and manage your privacy settings by visiting X's Privacy Policy.
C. Compliance and protection.
We may use your Personal Information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; to verify or enforce our agreements, terms of use, or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Mindbloom, visitors to our Service, or the public, as required or permitted by law
- audit our internal processes for compliance with legal and contractual requirements and enforce the terms and conditions that govern the Service
- prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft
D. Creating anonymized, pseudonymized, aggregated, or de-identified information. Your Personal Information may be anonymized, pseudonymized, aggregated or de-identified by removing data components (such as your name, email address, or linkable tracking identifier) that makes the data personally identifiable to you. We do this for our business operations, to disclose to other parties for our lawful business purposes, and for research and development of new products or services.
IV. To Whom We Disclose Your Information
We may disclose your Personal Information to the following parties and as otherwise described in this Policy:
Healthcare parties. This includes the Affiliated Medical Groups (Mindbloom Provider Group, P.A., Mindbloom Medical, P.C., Mindbloom Medical KS, P.A., Mindbloom Medical NJ, P.C., and Mindbloom Medical Group of CA, P.C.) and other entities that assist with treatment, payment, and other operations so that they can deliver healthcare services to you and conduct related processing and billing functions.
Service providers. We work with organizations that provide services on our behalf or help us operate the Service or our business (such as hosting, maintaining, and improving our information systems, customer support, fulfilling orders, payment processors, email delivery, and website analytics). Mindbloom’s service providers include organizations that may process data that we collect or that is collected for us at our request. When contracting with our service providers and implementing their services, we take reasonable steps to help ensure that these service providers are not permitted to disclose, use, or share any identifiable data except as necessary to support our processing activities or as otherwise permitted or required under law.
Advertising and marketing providers. Advertising and marketing companies for the interest-based advertising purposes described above as well as print or other forms of advertising.
Business partners. Parties with whom we collaborate on joint activities, with whom we have entered into marketing relationships or affiliate relationships who may offer, recommend, or advertise our Service to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement and government authorities that are necessary or appropriate for the compliance purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Mindbloom or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Authorized or Requested by You. We may also disclose your Personal Information to entities or individuals you authorize us to share certain information with.
Selling Personal Information. Mindbloom does not sell, in the traditional sense (i.e., exchange for money) any Personal Information provided to us. Mindbloom works with third parties to deliver interest-based advertising, which may be considered a “sale” of Personal Information under some state laws. For more information about this practice, including options you may have to control how third-party advertising platforms use your Personal Information, please see “Marketing, advertising, and analytics” in the section “How We Use Your Information” above.
V. Summary Chart - How We Use and Share Your Personal Information
The following chart provides a summary of how Mindbloom may use and disclose your Personal Information as described in fuller detail above. Please note that Mindbloom may also disclose some or all of your Personal Information to business transferees, law enforcement and other authorities, business partners, and as otherwise authorized or requested by you, as described in more detail above. Additionally, please note that the Personal Information disclosed to third parties may vary by state according to the terms of this Privacy Policy.
| Category of Personal Information | Categories of Third Parties to Which We Disclose | Categories of Purposes for Use/Disclosure |
|---|---|---|
| Contact information (e.g., name, address, email address) | Service providers; healthcare parties; professional advisors; advertising and marketing providers | Service delivery; marketing, advertising and analytics; compliance and protection; creating anonymized or similar data |
| Demographic information (e.g., city, state, zip code, biological sex, and age) | Service providers; healthcare parties; advertising and marketing providers; professional advisors | Service delivery; marketing, advertising, and analytics; compliance and protection; creating anonymized or similar data |
| Profile data (e.g., username, login, preferences) | Service providers; professional advisors | Service delivery; compliance and protection; creating anonymized or similar data |
| Health-related information (e.g., responses to the initial candidate survey on the website) | Service providers; healthcare parties; professional advisors | Service delivery; compliance and protection; analytics; creating anonymized or similar data |
| Contents of communications made in connection with the Services (e.g., customer service communications, communications with providers) | Service providers; healthcare parties; professional advisors | Service delivery; compliance and protection; creating anonymized or similar data |
| Transactional information (e.g., information about your purchase of a service) | Service providers; healthcare parties; professional advisors; advertising and marketing providers | Service delivery; compliance and protection; creating anonymized or similar data; marketing, advertising, and analytics |
| Financial information (e.g., payment information collected by payment processors) | Service providers; professional advisors | Service delivery; compliance and protection; creating anonymized or similar data |
| Internet activity (e.g., IP address, browsing activity, actions taken on the website, mobile app activity) | Service providers; professional advisors; advertising and marketing providers | Service delivery; marketing, advertising and analytics; compliance and protection; creating anonymized or similar data |
VI. Your Choices
You have the following choices with respect to your Personal Information:
Access, update, or delete your information. If you have registered for an account with us through the Service, you can contact us using the information provided below to request changes to the account.
Opt-out of email marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of any marketing emails sent to you from us, or by contacting us. Please note that opting out of marketing emails still allows us to send you service-related, non-marketing emails.
Text marketing. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. You may also text STOP to 628-333-3371.
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Advertising choices. You can limit use of your information for interest-based advertising by:
- Blocking third-party cookies in your browser settings.
- Using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
- Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Instructions for managing your advertising ID differ depending on your mobile device manufacturer, so please refer to your manufacturer or device settings for more information.
- You will need to apply these opt-out settings on each device from which you wish to opt-out.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. However, our Site may recognize certain opt-out preference signals, such as the Global Privacy Control. You may set such a signal through your browser or browser extension.
Logins via Third-Party Platforms. If you choose to connect to the Service through your Google account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
VII. Your Privacy Rights
In addition to the above choices, you may have the rights listed below (“Data Subject Rights”) with respect to the Personal Information that we collect or process about you; however, these rights differ depending on your state of residency, including California, Colorado, Nevada, Oregon, Texas, Utah, Virginia, and Washington. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.
- Right to Confirm Processing, Access, and/or Obtain a Copy: If you ask us, we will confirm whether we are processing your Personal Information. Additionally, upon request, we will provide you with a copy of all Personal Information you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
- Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you may request that we correct it.
- Right to Delete: You may request that we delete your Personal Information.
- Right of Portability: You may request that we move, copy, or transfer the electronic personal data that we hold about you to another organization.
- Right to Withdraw Consent and/or Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your Personal Information. This includes general requests and requests in specific contexts, such as if we process Personal Information that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
- Right to Opt Out of Targeted Advertising: Targeted advertising, also referred to as interest-based advertising or cross-context behavioral advertising, is the practice of serving you tailored advertisements based on your Personal Information gathered over time and across other businesses, websites, applications, or services. You have the right to opt out of this practice. Additionally, third-party advertising platforms may offer options to further control or limit this practice. Please see “Marketing, advertising, and analytics” in the section “How We Use Your Information” above for these options.
- Right to Opt Out of Sales: Some states may consider targeted advertising a “sale” of Personal Information. You may request that we not “sell” your Personal Information.
- Right to Non-Discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your Personal Information.
- Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination.
- Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the jurisdiction in which you live if you have any concerns about our processing of your Personal Information.
If you or your authorized agents would like to exercise a Data Subject Right, you may do so by following the instructions in “Contact Us” below. Please note that you may also login to your account to access and correct your account information at any time.
In order to process your request to exercise a Data Subject Right, we will ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as your last interaction with us, if applicable.
VIII. Artificial Intelligence-Enabled Tools
Mindbloom’s website, mobile app, and services may feature tools enabled by artificial intelligence (“AI”) that are designed to enhance and support users’ experiences (“AI Tools”). Their function is limited to providing general information and assistance based on available data, and they do not provide medical advice. Use of these AI Tools is governed by Mindbloom’s Terms of Use and AI Tool Addendum.
AI Tools:
Mindbloom’s Site, App, and Services may provide the following AI Tools:
- Intercom Fin AI-Powered Chatbot: This is a natural language chatbot on our website that is used to address customer support inquiries.
- BloomBuddy: This is a set of features in the mobile app that provides suggestions and summaries to aid users in session preparation and integration.
- Fireflies.ai: This is an AI tool used to transcribe video meetings for purposes of creating notes and quality assurance.
- Upheal: Upheal provides automated notes and analytics. You can learn more about Upheal and its privacy practices at www.upheal.io/privacy.
- Zoom: Transcription, recording and analytics.
- OpenAI: Transcription and analytics.
Data sharing and protection: Information provided by you while interacting with the AI Tools is retained by Mindbloom to analyze and improve the Services, and may be used to shape the tool's future output calculation (also known as “fine-tuning”). Information that you provide while interacting with the AI Tools may be transmitted to third-party APIs for the purpose of AI-enabled response generation in order to process user inquiries. Data shared with third-party APIs is governed by data sharing and privacy agreements with the recipients, including:
- Intercom Fin AI-Powered Chatbot: Intercom’s Data Processing Addendum
- BloomBuddy: OpenAI’s Data Processing Addendum and enterprise privacy commitments; DeepGram’s Data Processing Agreement (not publicly available)
- Fireflies.ai: Fireflies.ai Data Processing Agreement
- Upheal: Client Privacy Policy
Consent and opt-out: Interacting with our AI-enabled tools implies that you consent to this use and sharing of your data. If you prefer not to share your information with third-party APIs for the purpose of AI-enabled response generation, please use alternative communication methods and tools available on our site and within our mobile app. Please contact support@mindbloom.com for more information.
Policy updates: We reserve the right to modify these practices, and will update this Policy accordingly.
IX. Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us but are available through our affiliate marketing providers. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. The privacy policies of those third parties would apply with regard to any information they collect, use, or disclose about the activities you perform on their webpages once you clink on those third-party links. We encourage you to read the privacy policies of the other websites, applications, and online services that you use.
X. State Specific Notices
A. Notice to Washington and Nevada Residents
If you reside in Washington or Nevada, please refer to our Consumer Health Data Privacy Policy for additional information about how we collect, use, and disclose Consumer Health Data, defined below, under the Washington My Health My Data Act and Nevada Consumer Health Privacy Law.
B. Notice to California Residents
If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act, as amended (or “CCPA”) (California Civil Code Section 1798.100 et seq.).
- Categories of Personal Information Collected: In the previous 12 months, we may have collected the personal data listed in “Personal Information We Collect & How We Collect It” above. This information falls into the following categories under the CCPA: identifiers; categories of Personal Information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories. Additionally, we collect the following “sensitive” Personal Information: Personal Information collected and analyzed concerning your health, characteristics of protected classifications under state or federal law, precise geolocation, account credentials, and contents of messages that you send to our customer service providers.
- Sensitive Personal Information Uses or Disclosures: You have a right to limit our use of “sensitive” Personal Information to purposes specified in the CCPA.
- Business or Commercial Purpose for Collecting and Selling Information: We collect Personal Information for the business and commercial purposes described in “How We Use Your Information” and summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Categories of Sources of Personal Information: We collect personal data from and about you as described in “Personal Information We Collect & How We Collect It” above.
- Categories of Third Parties with Whom We Disclose Information: We may disclose your personal data with third parties as described in “To Whom We Disclose Your Information” and as summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Categories of Personal Information Disclosed: In the preceding 12 months, we may have disclosed the categories of Personal Information listed in “Personal Information We Collect & How We Collect It” for the reasons described in “To Whom We Disclose Your Information” above. This may be summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Sale or Share of Personal Information: Because we engage in the practice of cross context behavioral advertising, we may “sell” and/or “share” your Personal Information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks. For more information about these third parties, including choices you may have to control your Personal Information, please see “Marketing, advertising, and analytics” in the section “How We Use Your Information” above.
Under California’s “Shine the Light” law, California residents are entitled to request and obtain from us once per calendar year information about the categories of Personal Information we have shared with third parties for their own direct marketing purposes. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us using the information provided in the Contact Us section below.
XI. Security
We’ve incorporated technical, organizational, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all web-based and information technologies and we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to get through our security, and improperly collect, access, steal, or modify your Personal Information. Sharing and disclosing information over the internet is not completely secure. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Service, in your operating system, or mobile device. Accordingly, it is your responsibility to protect the security of your login information, including your username and password.
XII. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Policy, we will notify you by updating the Policy date and posting it on the Service or as otherwise required by law. Modifications to our Privacy Policy are effective as of the date on the Policy. Your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the information contained in the modified Privacy Policy. We encourage you to periodically review this page for the latest information.
XIII. Contact Us
If you’d like to receive additional information about our privacy practices, have questions, or would like to make a request, you may contact us at the below addresses:
By Email: privacy@mindbloom.com
Postal Mail:
Mindbloom
Attn: Privacy
1317 Edgewater Dr #1583
Orlando, FL 32804
If you would like to request to exercise a Data Subject Right, you may also use the following links:
Please note that these Rights relate to information collected by Mindbloom, Inc., but not to information that you provide to the Affiliated Medical Groups. If you would like to request a copy of your medical records from the Affiliated Medical Groups, please contact support@mindbloom.com.
Additional Information for Job Applicants
This section supplements the information provided above and describes the additional Personal Information we collect when you apply for a position with us. We may collect the Personal Information in the below list in the following ways: directly from you; from publicly available sources, such as government entities, public records systems, and social media networks; data analytics providers and data brokers; or as you may otherwise authorize, such as former employers or references.
Please note if you use our Services in the job application process, additional information is collected, as described above. We may collect the Personal Information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) in addition to the categories of personal information listed below. Items with an asterisk (*) may be considered “sensitive” Personal Information according to the CCPA.
- Identifiers*: Government-issued identification numbers, including your Social Security, driver’s license, passport, state identification card, or military identification card numbers.
- Demographics and Protected Classifications*: citizenship, gender, data of birth, age, and other traditionally protected classifications that you chose to disclose, such as race and ethnicity, marital status, sexual orientation, veteran or military status, disability, and medical status.
- Professional or Employment Related Information: professional associations and employment history, including name of employer, position, employer contact information, and associated employment records.
- Educational Information: educational institutions attended, degrees and certifications attained, and other educational or student records, which may include details about attendance, grades, and academic and disciplinary history.
We generally collect this Personal Information in order to evaluate your application for employment. For more details about how we use and disclose the personal data listed here, please refer to “How We Use Your Information” and “To Whom We Disclose Your Information” above.
VI. Your Choices
You have the following choices with respect to your Personal Information:
Access, update, or delete your information. If you have registered for an account with us through the Service, you can contact us using the information provided below to request changes to the account.
Opt-out of email marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of any marketing emails sent to you from us, or by contacting us. Please note that opting out of marketing emails still allows us to send you service-related, non-marketing emails.
Text marketing. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. You may also text STOP to 628-333-3371.
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Advertising choices. You can limit use of your information for interest-based advertising by:
- Blocking third-party cookies in your browser settings.
- Using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
- Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Instructions for managing your advertising ID differ depending on your mobile device manufacturer, so please refer to your manufacturer or device settings for more information.
- You will need to apply these opt-out settings on each device from which you wish to opt-out.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. However, our Site may recognize certain opt-out preference signals, such as the Global Privacy Control. You may set such a signal through your browser or browser extension.
Logins via Third-Party Platforms. If you choose to connect to the Service through your Google account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
VII. Your Privacy Rights
In addition to the above choices, you may have the rights listed below (“Data Subject Rights”) with respect to the Personal Information that we collect or process about you; however, these rights differ depending on your state of residency, including California, Colorado, Nevada, Oregon, Texas, Utah, Virginia, and Washington. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.
- Right to Confirm Processing, Access, and/or Obtain a Copy: If you ask us, we will confirm whether we are processing your Personal Information. Additionally, upon request, we will provide you with a copy of all Personal Information you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
- Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you may request that we correct it.
- Right to Delete: You may request that we delete your Personal Information.
- Right of Portability: You may request that we move, copy, or transfer the electronic personal data that we hold about you to another organization.
- Right to Withdraw Consent and/or Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your Personal Information. This includes general requests and requests in specific contexts, such as if we process Personal Information that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
- Right to Opt Out of Targeted Advertising: Targeted advertising, also referred to as interest-based advertising or cross-context behavioral advertising, is the practice of serving you tailored advertisements based on your Personal Information gathered over time and across other businesses, websites, applications, or services. You have the right to opt out of this practice. Additionally, third-party advertising platforms may offer options to further control or limit this practice. Please see “Marketing, advertising, and analytics” in the section “How We Use Your Information” above for these options.
- Right to Opt Out of Sales: Some states may consider targeted advertising a “sale” of Personal Information. You may request that we not “sell” your Personal Information.
- Right to Non-Discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your Personal Information.
- Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination.
- Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the jurisdiction in which you live if you have any concerns about our processing of your Personal Information.
If you or your authorized agents would like to exercise a Data Subject Right, you may do so by following the instructions in “Contact Us” below. Please note that you may also login to your account to access and correct your account information at any time.
In order to process your request to exercise a Data Subject Right, we will ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as your last interaction with us, if applicable.
VIII. Artificial Intelligence-Enabled Tools
Mindbloom’s website, mobile app, and services may feature tools enabled by artificial intelligence (“AI”) that are designed to enhance and support users’ experiences (“AI Tools”). Their function is limited to providing general information and assistance based on available data, and they do not provide medical advice. Use of these AI Tools is governed by Mindbloom’s Terms of Use and AI Tool Addendum.
AI Tools:
Mindbloom’s Site, App, and Services may provide the following AI Tools:
- Intercom Fin AI-Powered Chatbot: This is a natural language chatbot on our website that is used to address customer support inquiries.
- BloomBuddy: This is a set of features in the mobile app that provides suggestions and summaries to aid users in session preparation and integration.
- Fireflies.ai: This is an AI tool used to transcribe video meetings for purposes of creating notes and quality assurance.
Data sharing and protection: Information provided by you while interacting with the AI Tools is retained by Mindbloom to analyze and improve the Services, and may be used to shape the tool's future output calculation (also known as “fine-tuning”). Information that you provide while interacting with the AI Tools may be transmitted to third-party APIs for the purpose of AI-enabled response generation in order to process user inquiries. Data shared with third-party APIs is governed by data sharing and privacy agreements with the recipients, including:
- Intercom Fin AI-Powered Chatbot: Intercom’s Data Processing Addendum
- BloomBuddy: OpenAI’s Data Processing Addendum and enterprise privacy commitments; DeepGram’s Data Processing Agreement (not publicly available)
- Fireflies.ai: Fireflies.ai Data Processing Agreement
Consent and opt-out: Interacting with our AI-enabled tools implies that you consent to this use and sharing of your data. If you prefer not to share your information with third-party APIs for the purpose of AI-enabled response generation, please use alternative communication methods and tools available on our site and within our mobile app. Please contact support@mindbloom.com for more information.
Policy updates: We reserve the right to modify these practices, and will update this Policy accordingly.
IX. Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us but are available through our affiliate marketing providers. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. The privacy policies of those third parties would apply with regard to any information they collect, use, or disclose about the activities you perform on their webpages once you clink on those third-party links. We encourage you to read the privacy policies of the other websites, applications, and online services that you use.
X. State Specific Notices
A. Notice to Washington and Nevada Residents
If you reside in Washington or Nevada, please read this section for additional information about how we collect, use, and disclose Consumer Health Data, defined below, under the Washington My Health My Data Act and Nevada Consumer Health Privacy Law.
Depending on your relationship with us, some of the Personal Information that we collect about you may identify your past, present, or future physical or mental health status (“Consumer Health Data”). Please note that some uses of the Service may be subject to other state laws, as discussed above in “Policy Purpose & To Whom It Applies.”
- Some of the information we collect listed above in “Personal Information We Collect & How We Collect It” may be considered Consumer Health Data, such as the information described in “Health-related information,” “Program information,” and “Profile data.”
- We use Consumer Health Data for the purposes described in “How We Use Your Information” above.
- We may disclose Consumer Health Data to the following categories of third parties, as described above in “To Whom We Disclose Your Information” in more detail: healthcare parties, service providers, business partners, professional advisors, authorities and others, business transferees, and other parties at your authorization or request.
- We do not “sell” Consumer Health Data or permit third parties to collect Consumer Health Data over time and across different internet websites or online services, unless we obtain your valid authorization.
Mindbloom does not sell, rent, or lease your Personal Information to third parties according to 2019 Nev. L. 211. However, if you are a resident of Nevada and would like to submit a request not to sell your Personal Information, you may do so by contacting us at: privacy@mindbloom.com.
B. Notice to California Residents
If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act, as amended (or “CCPA”) (California Civil Code Section 1798.100 et seq.).
- Categories of Personal Information Collected: In the previous 12 months, we may have collected the personal data listed in “Personal Information We Collect & How We Collect It” above. This information falls into the following categories under the CCPA: identifiers; categories of Personal Information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories. Additionally, we collect the following “sensitive” Personal Information: Personal Information collected and analyzed concerning your health, characteristics of protected classifications under state or federal law, precise geolocation, account credentials, and contents of messages that you send to our customer service providers.
- Sensitive Personal Information Uses or Disclosures: You have a right to limit our use of “sensitive” Personal Information to purposes specified in the CCPA.
- Business or Commercial Purpose for Collecting and Selling Information: We collect Personal Information for the business and commercial purposes described in “How We Use Your Information” and summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Categories of Sources of Personal Information: We collect personal data from and about you as described in “Personal Information We Collect & How We Collect It” above.
- Categories of Third Parties with Whom We Disclose Information: We may disclose your personal data with third parties as described in “To Whom We Disclose Your Information” and as summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Categories of Personal Information Disclosed: In the preceding 12 months, we may have disclosed the categories of Personal Information listed in “Personal Information We Collect & How We Collect It” for the reasons described in “To Whom We Disclose Your Information” above. This may be summarized in “Summary Chart – How We Use and Share Your Personal Information” above.
- Sale or Share of Personal Information: Because we engage in the practice of cross context behavioral advertising, we may “sell” and/or “share” your Personal Information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks. For more information about these third parties, including choices you may have to control your Personal Information, please see “Marketing, advertising, and analytics” in the section “How We Use Your Information” above.
Under California’s “Shine the Light” law, California residents are entitled to request and obtain from us once per calendar year information about the categories of Personal Information we have shared with third parties for their own direct marketing purposes. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us using the information provided in the Contact Us section below.
XI. Security
We’ve incorporated technical, organizational, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all web-based and information technologies and we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to get through our security, and improperly collect, access, steal, or modify your Personal Information. Sharing and disclosing information over the internet is not completely secure. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Service, in your operating system, or mobile device. Accordingly, it is your responsibility to protect the security of your login information, including your username and password.
XII. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Policy, we will notify you by updating the Policy date and posting it on the Service or as otherwise required by law. Modifications to our Privacy Policy are effective as of the date on the Policy. Your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the information contained in the modified Privacy Policy. We encourage you to periodically review this page for the latest information.
XIII. Contact Us
If you’d like to receive additional information about our privacy practices, have questions, or would like to make a request, you may contact us at the below addresses:
By Email: privacy@mindbloom.com
Postal Mail:
Mindbloom
Attn: Privacy
1317 Edgewater Dr #1583
Orlando, FL 32804
If you would like to request to exercise a Data Subject Right, you may also use the following links:
Please note that these Rights relate to information collected by Mindbloom, Inc., but not to information that you provide to the Affiliated Medical Groups. If you would like to request a copy of your medical records from the Affiliated Medical Groups, please contact support@mindbloom.com.
Additional Information for Job Applicants
This section supplements the information provided above and describes the additional Personal Information we collect when you apply for a position with us. We may collect the Personal Information in the below list in the following ways: directly from you; from publicly available sources, such as government entities, public records systems, and social media networks; data analytics providers and data brokers; or as you may otherwise authorize, such as former employers or references.
Please note if you use our Services in the job application process, additional information is collected, as described above. We may collect the Personal Information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) in addition to the categories of personal information listed below. Items with an asterisk (*) may be considered “sensitive” Personal Information according to the CCPA.
- Identifiers*: Government-issued identification numbers, including your Social Security, driver’s license, passport, state identification card, or military identification card numbers.
- Demographics and Protected Classifications*: citizenship, gender, data of birth, age, and other traditionally protected classifications that you chose to disclose, such as race and ethnicity, marital status, sexual orientation, veteran or military status, disability, and medical status.
- Professional or Employment Related Information: professional associations and employment history, including name of employer, position, employer contact information, and associated employment records.
- Educational Information: educational institutions attended, degrees and certifications attained, and other educational or student records, which may include details about attendance, grades, and academic and disciplinary history.
We generally collect this Personal Information in order to evaluate your application for employment. For more details about how we use and disclose the personal data listed here, please refer to “How We Use Your Information” and “To Whom We Disclose Your Information” above.