Privacy Policy (Canada)

About This Policy

This Privacy Policy explains how Bloom ("we", "us", or "our") collects, uses, discloses, and protects your personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

Information Collection and Use

What We Collect

Bloom is a local-first menstrual cycle tracking application. All your health data is stored locally on your device by default:

• Menstrual cycle data (period start/end dates, cycle length)
• Symptoms, moods, and physical changes
• Basal body temperature (if logged)
• Notes and custom tracking data
• App preferences and settings

Local Storage

Your personal health information never leaves your device unless you explicitly choose to:

• Share with companions via CloudKit
• Export medical reports for healthcare providers
• Sync with Apple HealthKit (if enabled)

Device Information

We collect minimal technical information stored locally:

• Device identifier (stored in Keychain for audit logging)
• App version and crash reports (anonymous, opt-in only)

Your Rights Under PIPEDA

You have the following rights regarding your personal information:

1. Right of Access

You can request a copy of all personal information we hold about you. Bloom provides instant export in multiple formats:

• FHIR R4 (healthcare standard)
• PDF medical reports
• CSV spreadsheets
• JSON data files

2. Right to Correction

You can edit or correct your cycle data, symptoms, and preferences at any time within the app.

3. Right to Deletion

You can permanently delete all your personal information from the app at any time. This action cannot be undone.

4. Right to Data Portability

You can export your data in industry-standard formats to transfer to other applications or healthcare providers.

5. Right to Withdraw Consent

You can withdraw your consent for specific data uses at any time:

• Revoke companion sharing access
• Disable Apple HealthKit sync
• Turn off notifications
• Opt out of analytics

6. Right to File a Complaint

If you have concerns about how we handle your personal information, you can file a complaint with:

Purpose-Based Consent

We collect and use your personal information only for specific purposes, and we obtain your consent for each purpose:

Core App Functionality (Implied Consent)

• Storing cycle data locally for tracking and predictions
• Generating cycle insights and statistics
• Displaying your health timeline

Companion Sharing (Express Consent Required)

• Sharing specific health data with invited companions
• Requires biometric authentication before each share
• You can revoke access at any time

Medical Export (Express Consent Required)

• Generating medical reports for healthcare providers
• Exporting data in FHIR, PDF, or CSV formats
• Each export requires explicit consent

Apple HealthKit (Express Consent Required)

• Reading cycle data from HealthKit
• Writing cycle data to HealthKit
• You control which data types sync

Analytics (Optional Consent)

• Anonymous app usage statistics
• Crash reports for bug fixes
• Completely optional and disabled by default

Data Security

We implement appropriate technical and organizational measures to protect your personal information:

Encryption

• Sensitive data encrypted in iOS Keychain
• Device-level encryption via iOS File Protection
• End-to-end encryption for CloudKit sharing

Access Controls

• Optional Face ID / Touch ID app lock
• Biometric authentication for data sharing
• Discreet mode to hide app purpose

Audit Logging

We maintain audit logs of:

• All data access events
• Sharing and export activities
• Consent granted and revoked
• Logs retained for 2 years for accountability

No Cloud Storage

Your health data is not uploaded to our servers. All storage is local on your device or in your private iCloud account (if you enable companion sharing).

Data Retention

Your Health Data

We retain your personal health information locally on your device until you choose to delete it. There is no automatic deletion.

Audit Logs

Audit logs of data access and sharing events are retained for 2 years in compliance with PIPEDA best practices, then automatically deleted.

After Account Deletion

When you delete all data from Bloom:

• All health information is immediately and permanently erased
• Audit logs are deleted
• App preferences reset
• This action cannot be undone

Data Sharing and Disclosure

No Third-Party Sharing

We do not sell, rent, or share your personal information with third parties for marketing purposes.

Limited Sharing Scenarios

We may share personal information only in these specific circumstances:

1. With Your Consent: Companion sharing, medical exports to your healthcare providers
2. Legal Obligations: If required by Canadian law or valid legal process
3. Safety: To prevent imminent harm or protect public health

Apple HealthKit

If you enable HealthKit integration, data is shared with Apple's HealthKit framework according to Apple's privacy policies. We do not access your HealthKit data beyond what you explicitly authorize.

Cross-Border Data Transfers

All your health data remains on your device in Canada. We do not transfer your personal information outside Canada unless:

• You explicitly export it to send to a healthcare provider
• You use CloudKit sharing with a companion in another country (in your private iCloud account)

Children's Privacy

Bloom is designed for menstruating individuals of all ages. We do not knowingly collect personal information from children under 13 without parental consent. If you are under 13, please use Bloom with a parent or guardian's supervision.

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes through the app. Your continued use after changes constitutes acceptance of the updated policy.

Contact Us

For privacy questions, concerns, or to exercise your PIPEDA rights:

• Email: [email protected]
• Privacy Inquiries: Subject line "Privacy - Canada"

Response time: Within 30 days per PIPEDA requirements

Your Consent

By using Bloom in Canada, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy and in accordance with PIPEDA.

You can withdraw your consent at any time by:

• Revoking specific permissions in Settings
• Deleting your data
• Uninstalling the app

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Bloom is developed by Ariadne Studio Works
Not a PIPEDA-covered health information custodian
For personal use only - not a medical device