Bloom Privacy Policy
Version privacy-2026-10-v1 · Effective 1 November 2026
Responsible organisation: Balaji Venkatnarayanan, #02-05, 3 Yishun Avenue 11, Singapore 768859, Individual, no company registration. Privacy contact: [email protected]
1. Who we are
Bloom is an education and clinical-trial search website at bloomstrial.com. It is operated by Balaji Venkatnarayanan, #02-05, 3 Yishun Avenue 11, Singapore 768859, Individual, no company registration ("we"). We are the controller of the personal information described in this policy.
Privacy questions, requests and complaints: [email protected]. Our privacy officer, Balaji Venkatnarayanan, answers them within one month, or sooner where your local law sets a shorter time.
2. The short version
- You can read, learn, search for trials and use Patient Genie without an account.
- An account holds your email address, a one-way hash of your password and a small profile you choose. Your email address and profile are encrypted in our database, on our server in the European Union.
- Eligibility answers, saved studies and searches, checklists and learning progress stay in your browser. They are never sent to us.
- Patient Genie answers the safety questions it recognises in your browser. Other general questions go through our server to an AI service for an answer. We do not save the chat.
- We do not sell personal information, show advertising, use analytics or tracking cookies, or make automated decisions about you.
3. Information we collect, why, and our legal basis
| Information | Why we use it | Legal basis (EU/UK GDPR) | How long we keep it |
|---|---|---|---|
| Email address (encrypted) | Create and secure your account; send account emails: confirm your address, reset your password, tell you your password changed | Contract (Art. 6(1)(b)) | Until you delete the account. An account not confirmed within 7 days is deleted |
| Password, stored only as an Argon2id one-way hash | Sign-in | Contract (Art. 6(1)(b)) | Until you change it or delete the account |
| Role, nickname and optional city, country, learning language and role details (encrypted) | Show the profile you chose | Contract (Art. 6(1)(b)) | Until you change them or delete the account |
| Privacy acknowledgements: notice version, the country or region you selected, your choices, the time | Record what you were shown and agreed to | Legal obligation and legitimate interests (Art. 6(1)(c) and (f)) | Until the account is deleted |
Session cookie (__Host-bloom_session: HttpOnly, Secure, SameSite=Strict) and a list of your signed-in devices (a coarse label such as "Firefox · Android", sign-in and last-active times; no IP address or location) | Keep you signed in safely; let you sign out other devices | Contract, strictly necessary | 2 hours of inactivity and 12 hours at most, or 30 days if you choose "Keep me signed in"; at most 10 devices |
| Email confirmation and password-reset links (only a one-way hash of the link is stored) | Confirm your address; reset your password | Contract (Art. 6(1)(b)) | 48 hours (confirmation) or 30 minutes (reset), and single use |
| Security records: the type and time of account events (for example "password changed"), failed sign-in counters | Protect accounts from guessing and abuse | Legitimate interests (Art. 6(1)(f)) | Account events 90 days; counters up to 24 hours |
| Your IP address (passed to our server by Cloudflare) | Limit repeated requests and sign-in attempts | Legitimate interests (Art. 6(1)(f)) | In memory for about a minute; for sign-in limits only as a keyed one-way hash, up to 24 hours |
| Patient Genie questions (see section 5) | Answer your question | Legitimate interests (Art. 6(1)(f)) | Not stored by us |
| Server logs: route, status code and timing only, with no email addresses, IP addresses, tokens or message content | Keep the service running and fix errors | Legitimate interests (Art. 6(1)(f)) | Until rotated out (at most 50 MB per service, usually a few weeks) |
We do not ask for or store health records, diagnoses, phone numbers, postal addresses or identity documents.
4. What stays on your device
Saved studies, saved searches, trials you marked "I'm interested" (with the site you chose and the progress you recorded), your question checklist, and lesson, primer and training progress are kept only in your browser's storage on that device. Eligibility self-check answers and the Patient Genie conversation stay in the open tab and are cleared when you reload it. The "How you feel" choice is not saved or sent anywhere. None of this reaches our server or your account, and you can clear it at any time under My next steps.
5. Patient Genie
Patient Genie is an educational guide, not a clinician. Questions it recognises as being about emergencies, medical advice, eligibility, personal data, privacy or compliance are answered from fixed answers inside your browser and are never sent anywhere. Other general questions are sent through our server to an AI service, currently Groq, Inc. (United States), together with up to 10 earlier messages from the same conversation so the answer fits the context. The AI service does not receive your IP address, account or any identifier from us, and we do not store the questions or the answers. If we change the AI service, we update this policy first. Please do not type names, contact details or health details into the chat.
6. Who receives information
We use these service providers. They process information only to provide their service to us, under a data processing agreement:
| Provider | What it does for Bloom | What it receives |
|---|---|---|
| Contabo GmbH (Germany) | Our server in the European Union, which runs the account database | Everything in section 3, with email addresses and profiles encrypted |
| Cloudflare, Inc. (United States; global network) | Domain name service, secure delivery of the website and protection against attacks, hosting of the website, forwarding of account requests to our server through an encrypted tunnel, storage of encrypted database backups, a bot check on registration, password reset and repeated failed sign-ins (Turnstile), forwarding of email sent to our addresses | Your IP address and request details for every page you visit; technical information about your browser for the bot check; account requests in transit; our encrypted backups; emails you send to us |
| Resend, Inc. (United States) | Sends account emails | Your email address and the content of the account email |
| Groq, Inc. (United States) | Answers general Patient Genie questions | The question and up to 10 earlier messages (section 5) |
| Have I Been Pwned (Pwned Passwords) | Checks whether a new password appears in known data breaches | Only the first 5 characters of a one-way hash of the password, with padding. Never the password |
Trial searches and maps. When you search, your search terms go to the trial registries you choose: from your browser directly to ClinicalTrials.gov and ISRCTN, and through our server to the EU Clinical Trials Information System, the US National Cancer Institute and Korea's Ministry of Food and Drug Safety. US ZIP-code distance searches use Zippopotam.us. Japanese records come from a copy of the public UMIN-CTR data (University Hospital Medical Information Network, Japan) held on our server, so those searches do not leave it. Some images load from Unsplash and maps from Esri and OpenTopoMap. These services receive your IP address and the request under their own privacy policies. Registry answers are public data; we and Cloudflare keep them for up to an hour so repeated searches are faster, without linking them to you.
Study teams and sponsors receive nothing from us. Authorities receive information only where the law requires it.
7. Where information is stored and international transfers
Our server and database are in the European Union, rented from Contabo GmbH (Germany). Cloudflare, Resend and Groq are based in the United States, and Cloudflare's network handles each request in the data centre nearest to you. Information therefore leaves the country you are in. Where the law of your country restricts that (for example the EU, the UK, Australia, Japan, Korea and India), we protect it with each provider's data processing agreement, which includes the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum. Cloudflare is also certified under the EU-U.S. Data Privacy Framework. The information on our server is also protected by European Union data protection law. You can ask us for a copy of the safeguards.
8. How we protect information
- HTTPS everywhere, a strict Content Security Policy, and no third-party scripts except the Turnstile bot check.
- Email addresses and profiles encrypted in the database; the key is held only on our server and offline, never in code or logs.
- Passwords hashed with Argon2id; limits on sign-in attempts per account and per connection; messages that do not reveal whether an email address has an account.
- Automatic sign-out after inactivity, a list of signed-in devices with "sign out everywhere else", and all sessions ended when the password changes.
- Our server accepts no connections from the internet except administrator SSH with keys; Bloom traffic reaches it only through Cloudflare's encrypted tunnel, with a secret only our website holds. The software runs in read-only containers without administrator rights.
- Continuous encrypted backups with 7 days of history, a copy taken before each software update (the last five are kept), and tested restores. Deleted information can remain in backups until they expire.
No system is perfectly secure. If a breach is likely to put you at risk, we will tell you and the regulator as the law requires (for example within 72 hours under the GDPR, and within 3 calendar days to Singapore's Personal Data Protection Commission).
9. Your rights
Depending on where you live you can:
- see your information and download a copy: My Profile → Review & export;
- correct it: My Profile → edit;
- delete your account: My Profile → Delete account (after confirming your password). Files you downloaded stay on your device;
- object to or restrict processing, and withdraw a choice at any time (this does not affect what happened before);
- nominate someone to act for you where your law allows it (India);
- complain to us first at [email protected], and to your data protection authority:
| Where you live | Authority |
|---|---|
| European Union / EEA | The data protection authority of your country (listed at edpb.europa.eu) |
| United Kingdom | Information Commissioner's Office (ico.org.uk) |
| Australia | Office of the Australian Information Commissioner (oaic.gov.au) |
| Singapore | Personal Data Protection Commission (pdpc.gov.sg) |
| India | Data Protection Board of India, after our grievance process |
| Japan | Personal Information Protection Commission (ppc.go.jp) |
| South Korea | Personal Information Protection Commission (pipc.go.kr) |
10. Health information and HIPAA
Bloom is designed not to collect health records, and its eligibility self-check answers stay in your browser. We are not a HIPAA covered entity or business associate and Bloom does not receive protected health information from one, so HIPAA does not apply to this site. Bloom is not described as "HIPAA compliant": there is no official HIPAA certification.
11. Country-specific information
- Singapore: our Data Protection Officer is Balaji Venkatnarayanan, at [email protected].
- South Korea: our Chief Privacy Officer is Balaji Venkatnarayanan, at [email protected]. Overseas transfer: the information in section 3 (email address, profile, account and security records) is transferred over encrypted connections, when you use the service, to Contabo (server in the European Union), Cloudflare and Resend (United States), and general Patient Genie questions to Groq (United States), for the purposes and periods in sections 3 and 6. You can refuse by not creating an account; reading, trial search and Patient Genie work without one.
- Japan: information is transferred to the European Union and the United States. The European Union protects personal data under the GDPR, which Japan recognises as giving an adequate level of protection; the United States has no comprehensive federal privacy law, so each recipient is bound by a data processing agreement with measures equivalent to the Act on the Protection of Personal Information.
- India: our grievance officer is Balaji Venkatnarayanan, at [email protected]. You can use our grievance process before complaining to the Data Protection Board of India.
- Australia: we disclose personal information to recipients in the European Union and the United States (section 6) and take reasonable steps, by contract, to make sure they handle it consistently with the Australian Privacy Principles.
- Mainland China: Bloom does not offer accounts to residents of mainland China.
12. Children
Bloom has no minimum age, and anyone can read the education pages without an account. Where the law of your country requires a parent's or guardian's permission for a child to use an online service (for example under 18 in India, under 14 in South Korea, or between 13 and 16 depending on the country in the EU), a child needs that permission before creating an account, and the parent or guardian can contact us to see or delete the child's information.
13. Changes
We publish every change on this page with a new version and date. If a change affects what you agreed to, Bloom shows you the new notice before you can edit your profile again.