Blume Limited (trading as Blume), with company number 10758050 and with a registered address at Little Tufton House, 3 Dean Trench Street, London United Kingdom, SW1P 3HB herein referred to as ‘Blume’ or ‘We’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to Blume when using www.blume.life (the ‘Site’) to access the Services.
We are committed to protecting and respecting your privacy. For the purpose of the General Data Protection Regulation 2016/679, Blume Limited is a Data Controller (ICO registration number: CSN3690216).
In this Statement, references to ‘You’, ‘Your’, ‘Blume Member’, ‘Buyer’ or ‘Blumer’ are references to the person who visits/ uses/ registers on the Site. When You use the Site, You are consenting to the practices set out in this Statement.
Unless otherwise stated, any defined terms in here shall have the meaning set out in the Blume Service Terms.
1. YOUR ACCEPTANCE OF THE STATEMENT
This Statement governs Your use of the Services, including any dispute concerning privacy. By using the Services, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site to access the Services. We reserve the right to make reasonable modifications to this Statement at any time with or without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes. However, if in our view any change significantly affects Blume Members’ rights or obligations, we shall notify you by email of such changes, and such changes shall take effect 30 days after the date of notification.
2. WHAT INFORMATION IS COLLECTED & HOW?
A. PERSONAL DATA
2.1 The Site asks You to provide various types of Personal Data to enhance the quality of the Services We can provide to You and the more accurate the information You provide, the better We are able to respond to Your requirements. In Your specific role as a Buyer or Blumer (each a ‘Blume Member’), You may input Personal Data in respect of yourself or in respect of one or more other individuals for whom You must have the requisite consent.
2.2 Blume reserves the right to remove any user-generated-content (‘UGC’) You post on the Site if in our sole opinion, such content is unlawful or inappropriate.
2.3 As part of the process of using the Site to access the Services, We collect Your Personal Data (and other Data or content of a non-personal nature) in various ways:
- Registration form upon applying to be a Blume Member;
- Via our ‘Contact Us’;
2.5 As a Blumer or a Buyer, the following types of Personal Data input by You shall only be seen by Blume (and Blume Service Providers and any Blume Partners as applicable):last name, D.O.B., gender, and address. If relevant to the task a Blumer’s address will be shared with the Buyer.
2.7 We may also collect the following types of Data about You (as applicable):
Blume agrees that it will adhere to all Data Protection Law and will take appropriate technical and organisational security measures against the unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to Personal Data.
B. FINANCIAL PERSONAL DATA
2.8 Each monetary transaction made on this Site shall be processed by a third-party escrow management payment processing partner Stripe (or any other third party that Blume may use from time to time). You will be required to provide the relevant Blume Service Provider with financial data (i.e. Your banking details) in order to authorise payment from You as a Buyer and to release payment to the Blumer in addition to enabling any Blume Fees to be paid to (or deducted by) Blume in consideration of the Services pursuant to the Blume Service Terms. Payment processing services for Blume Limited on Blume provided by Stripe are subject to the Stripe Connected Account Agreement, which includes the Stripe Terms of Service (collectively, the ‘Stripe Services Agreement’). The terms of the Stripe Services Agreement may be updated from time to time by posting the changes on the Stripe site. You authorize Stripe to provide Your Personal Data and financial data to its associated companies, fraud and screening agencies and other relevant governmental bodies to (i) provide the payment services to you, (ii) comply with legal and regulatory obligations, and (iii) to perform underwriting and risk review. Where required to comply with legal, network, or regulatory obligations, Stripe may provide Your Personal Data to law enforcement, networks, regulators, or other similar authorised third parties (as the case may be).
3. HOW IS THE INFORMATION USED?
3.1 You acknowledge that Your Personal Data may be used by Blume to contact You by post, phone or by Electronic Mail when necessary in connection with Your use of the Site to access the Services e.g. in respect of a change to any of our legal terms and conditions to which You are subject, to provide confirmations, notifications and feedback requests. This is a necessary part of continuing to receive access to the Services and accordingly constitues a legitimate interest of Blume for the purposes of lawfully processing Your Personal Data under the applicable laws.
3.2 If you consent, from time to time, Blume may contact You by Electronic Mail (or by telephone) by way of sending You newsletter or information or offers regarding upcoming promotions, services or surveys (‘Marketing Communications’). You can opt out of receiving direct Marketing Communications from Blume as described below.
3.3 You are under no obligation to provide Your Personal Data to the Site, however, if You choose not to, many of the Services will not be available to You.
3.4 You hereby expressly consent to Your Personal Data being passed on to third party service providers (‘Blume Service Providers’) for the sole purpose of Blume fulfilling the Services only (including making improvements to the Services) in accordance with our instructions and all applicable laws and regulations, and not for the purposes of those third parties sending Marketing Communications to You. For the avoidance of doubt, Blume is the exclusive owner of the Site and the Blume Content.
3.5 Your Personal Data may be shared with Blume Partners to the extent that You have provided Your express consent to this. It is not shared with any person or company without Your consent.
3.6 Any Personal Data that is held with Blume shall be retained in accordance with the Data Protection Law and/ or our retention and destruction policy culminating in its permanent deletion.
OPTING OUT FROM RECEIVING MARKETING COMMUNICATIONS FROM BLUME:
When You register as a Blume Member, You may consent to receiving Marketing Communications via one or more methods. Where You do, You can change Your mind about any consents you give and revoke them or grant them at any time. For example, You may choose to receive Marketing Communications by just one method e.g. email or choose all methods available. You can change Your receipt preferences in Your Account. Where You do not wish to be sent future Marketing Communications, We will give You the opportunity to unsubscribe in every Electronic Mail communication that is sent to You (or shall procure that any of our Blume Service Providers such as Mailchimp shall do the same). Alternatively, and additionally, You can contact Blume by sending an email to firstname.lastname@example.org with “UNSUBSCRIBE REQUEST” in the subject line or send Your request by post to Little Tufton House, 3 Dean Trench Street, London SW1P 3HB.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
4.1 To minimise the risk of unauthorised access to Your Personal Data, We use some of Your Personal Data to authenticate Your identity when You use the Site to access the Services.
4.2 For our daily operations, We may use the services of Blume Service Providers to provide some of our business and operational functions as referred to at Clause 3.1. Consequently, some of the Services are provided by Blume Service Providers and We need to disclose Your information to them.
4.3 We may provide Your information to one or more Blume Partners where such exist and You have given Your consent.
4.4 Disclosure of Your Personal Data in Compliance with Laws
You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with Blume or a Blume Member via the Site or otherwise, or to protect the rights, property or safety of Blume, a Blume Member or other third parties.
4.5 Transfer of Your Personal Data outside of the EEA/ UK
From time to time, We may transfer Your Personal Data to a related company, agent or contractor in order to improve our Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA/ UK and You consent to the transfer of Your Personal Data to such companies for the purposes set out here in accordance with this Statement and as permitted by Data Protection Law from time to time. A Blume Member agrees and warrants that it shall pay due regard to all Data Protection Law when effecting, if any, intra-transfer processing of Personal Data that may be carried out within and between Blume and either its subsidiaries, affiliates or third party partners. You should be aware that in territories outside the EEA/ UK, laws and practices relating to the protection of Personal Data are likely to be different and in some cases may be weaker than those within the EEA/ UK. We comply with the safeguards to protect Your Personal Data required by law
4.6 Transfer of Personal Data in the Event of the Sale of Blume Limited or its Assets
In the event that Blume is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of Blume.
4.7 Other Sites and their Privacy Policies and Cookie Policies
The Site may contain links to other websites or applications. Blume is not responsible for the privacy practices or the content of such websites or applications or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those policies independently.
5. HOW WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG
5.1 The privacy and protection of Your Personal Data is important to us. Any Blume Member statistics that We may collect and may provide to prospective Blume Service Providers or prospective Blume Partners regarding Your usage of the Services are provided in anonymised and aggregate form and do not include any individually identifiable data. It is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning and to draw conclusions upon demographic information.
5.2 You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any Personal Data You transmit to Blume or any of our Blume Partners (or other Blume Members) via, to, or from the Site.
5.3 Unfortunately, the transmission of Personal Data or information via the internet is not completely secure. Although We will do our best to protect Your Personal Data, We cannot guarantee the security of Your data transmitted to the Site; any transmission is at Your own risk. Once We have received Your information, We will use procedures and security features to try to prevent unauthorised access. How long We keep Your Personal Data collected through the Site depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. We may send You direct Marketing Communications for as long as You do not opt-out from receiving the same from Blume.
5.4 Telephone calls: If You call any of the service telephone numbers We provide, We may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our service standards.
5.5 We may disclose Your Personal Data to any Subscriber of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
7. ACCESS TO YOUR PERSONAL DATA
Blume tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if We hold any Personal Data by making a ‘Subject Access Request’ under the General Data Protection Regulation 2016/697 If We do hold Personal Data about You, We will let You have a copy of that Personal Data. To make a request to Blume for any Personal Data that We may hold, You need to put the request in writing addressing it to the postal address provided below. We will have one (1) month to comply with Your request and may charge an administrative fee if your request is manifestly unfounded or excessive.. In order to make a Subject Access Request to any Blume Partner, You will need to contact them directly
You also have the right to require us to correct errors in the Personal Data that We hold about You if it is inaccurate or incomplete.
8. RIGHT TO BE FORGOTTEN
You have a legal and personal “right of erasure” which is also known as the “right to be forgotten”. Upon Your request, We will close Your Account and remove Your Personal Data as soon as reasonably possible from all of our records unless a lawful reason exists for Blume to retain some or all of it. Blume reserves the right, in its sole discretion, to delete Your Personal Data if your Account is inactive for six (6) months or more.
9. COMPLAINTS OR QUERIES
Blume tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously and We encourage You to bring it to our attention. We would also welcome any suggestions for improving our procedures. This Statement does not provide exhaustive detail of all aspects of Blume’s collection and use of Personal Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the postal address below. If You are not happy with the way in which Your Personal Data is being handled by us, please contact us you can contact the supervisory authority, the Information Commissioner, see www.ico.org.uk.
10. HOW TO CONTACT US
Requests for information about our Statement or a ‘Subject Access Request’ can be emailed to email@example.com or requested in writing to: Little Tufton House, 3 Dean Trench Street, London SW1P 3HB
11. DEFINITIONS & INTERPRETATIONS
Blume Content: the content including all Intellectual Property Rights therein residing on the Site (which may or may not include Personal Data).
Blume Partners: refers to any third party with whom We partner with in respect of the provision of the Services
Blume Service Providers: refers to the third parties with whom We work with from time to time as a necessary part of providing the Services to You.
Data Protection Law: refers to the General Data Protection Regulation 2016/697 together with any other applicable regulations, orders, code of practice and guidance.
Electronic Mail: includes email, text, video, voicemail, picture and answerphone messages (including push notifications and in-app notifications).
Subject Access Request: refers to a written request made in accordance with General Data Protection Regulation 2016/697.
12. CHANGES TO THIS STATEMENT
We keep our Statement under regular review. This Statement was last updated on May 25th, 2018.