Privacy Policy

Last Updated: June 01, 2023


This privacy policy (this “Privacy Policy”) for TBDx. Inc. and its affiliates and subsidiaries (collectively, "Company," “we,” “us," or "our”), describes how and why we might collect, store, use, and/or share ("process") your information in the course of operating our business and supporting our products and features, including when you

  • use our services ("Services”);
  • visit our App named xBloom (“App”), website at, or any website of ours that links to this privacy policy (such websites, the “Sites”);
  • engage with us in other related ways, including any sales, marketing, or events.

Amendments to this Privacy Policy will be posted to the Sites and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment. You should periodically review this Privacy Policy and check the “Last Updated” date at the top of the document to familiarize yourself with the most recent version of this Privacy Policy.

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. By using the Company’s Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, you can also contact our Data Protection Officer by emailing or writing to us by the methods stipulated in the “Contact us.

Consent and Information Collection and Use

When you join us as a user of our Services, we ask for personal information that will be used to activate your account, provide the Services to you, communicate with you about the status of your account, and for other purposes set out in this Privacy Policy. We may collect some or all of the following information from you for providing you with the core business functions:

  • Registration information, such as your name, company name, age, birth date, gender, username and password, address, email or phone number.
  • Profile information, such as your name, social media account information, and profile image.
  • Account Information. If you choose to use this Service of the App, you must log in on the App first. We, therefore, collect information through you filling in the form actively and submitting it on the App for creating an account. The information includes your country, email, and account password so that we can create an account for you, in order to enable you to use the Service.
  • Profile Information. You may also choose to add certain profile information of your account by filling in the form on the App actively and submitting it - such as your birthday and gender - for providing you with a personalized service experience.
  • Recipe Information in Quick Mode.  You may also choose to add certain recipe-related information in Quick Mode. By selecting your choices of the “Grand Size”, “Temperature”, and “Ground: Water” buttons in Quick Mode and submitting, you provide us with the recipe data for the Service of brewing in Quick Mode.
  • Recipe Information in the Get Created Mode.  You may also choose to add certain recipe-related information in the Get Created Mode. By selecting your choices of the “Pour Number”, “Grind Size”, “Ground: Water for each Pour: Water volume”, “Temperature”, “Pattern”, “Pause”, and “Vibration On or Off” buttons in the Get Created Mode and submit, you provide us with the recipe data for the Service of brewing in the Get Created Mode.
  • Payment information, including payment card numbers or other third-party payment information (such as PayPal).
  • Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Services or our app. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
  • Your opt-in choices and communication preferences.
  • Information to verify an account such as proof of identity or age.
  • Information in correspondence you send to us.
  • Information you share through surveys such as your gender, age, likeness, and preferences.
  • Certain other information about you may be required by us to provide the Services or disclosed by you during your use of the Services.

By providing personal information to us and by requesting us to provide you with the Services, you voluntarily consent to the collection, use and disclosure of such personal information as specified in this Privacy Policy.

Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information for providing you with the additional business functions in specific circumstances. Sometimes your consent will be implied through your conduct with us if the purpose of the collection, and our expected use or disclosure of your information, is or should be obvious and you voluntarily provide the information. Please be assured, however, that all collection, use and disclosure of personal information will be in accordance with this Privacy Policy.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our Services, we may use your personal information and other information collected from you for the following purposes:

  • To provide the Services to you and to improve the quality of the Sites and Services,
  • To provide you with newsletters, RSS feeds, or other communications or services which you have signed up for or otherwise agreed to receive,
  • To provide information to you so that you may use the Sites and Services more effectively,
  • To manage and control your account information, and to verify access rights to Services and software,
  • To bill your account,
  • To communicate with you for the purpose of informing you of changes or additions to the Services, or of the availability of any Service we provide,
  • To assess service levels, monitor traffic patterns and gauge popularity of different service options,
  • To understand how you use the Services and our App, such as across your devices,
  • To send promotional materials from us or on behalf of our affiliates and trusted third parties,
  • To improve and develop our Services and conduct product development,
  • Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content,
  • For any other purposes disclosed to you at the time we collect your information or
  • To facilitate sales, promotion, and purchases of goods and services and to provide user support,
  • To communicate with you about products or services that may be of interest to you, either from us or third parties,
  • To enforce this Privacy Policy,
  • To respond to claims of any violation of our rights or those of any third parties,
  • To cooperate with legal, criminal or regulatory investigations or proceedings,
  • To respond to your requests for customer service,
  • To protect the rights, property or personal safety of you, us, our users and the public; and as required or authorized by law, and
  • To combine all the information we collect or receive about you for any of the foregoing purposes.

We may occasionally communicate with you regarding our products, services, news and events. You have the option to not receive marketing e-mails from us. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. The only kind of these communications that you may not “opt-out” of are those required to communicate announcements related to the Services, including information specific to your account (such as confirmation emails), planned Services suspensions and outages. We will attempt to minimize this type of communication to you.

Information automatically collecting.

We and our service providers may automatically collect certain technical information from your computer or mobile device once you have downloaded the App or use the Services, such as your Internet Protocol address, your geographic location, battery level, your browser type, your operating system, App and file names and types, model of your device, time zone setting, unique device identifiers, language, the pages you view immediately before and after you access the Services, geolocation-related data (as described below), unique device identifiers, browsing and search history (including content you have viewed in the Platform), and Cookies (as defined below) and the search terms you enter on the Services, network type. This information allows us to recognize you and personalize your experience if you return to the Services, and to improve the Services.

Please note that since the customer's account in APP and web cannot be linked, when you want to withdraw such consent by deleting your account, you need to follow the specific actions on the APP side and the web side according to the following requirements.

If the customer has registered an account through the APP side, the customer can withdraw such consent by deleting the APP account, then the individual customer profiles in the APP system background will be deleted simultaneously, and we will not continue to collect and use your information, nor can we provide you with personalized experience and improved services.

If the customer has registered an account through the web side, the customer cannot delete individual customer profiles in the web background system by deleting the web account by themselves, the customer must contact our customer service to delete the account, but in the following cases, the customer profiles can't be deleted.

  • the customer has an order history
  • the customer has pending redaction because of a GDPR erasure request
  • the customer has an active subscription now. or if the customer ever had a subscription in the past

If customer attempt to delete multiple profiles in bulk, then only the profiles that can be deleted are deleted.

If the customer insists on deleting the foregoing content, the any  consequences arising from this shall be borne by the customer. 

When the customer completes the account deletion using the preceding methods, we will not continue to collect and use customer information, and will not provide customer with personalized experience and improved services.

Device Information

We collect certain information about the device you use to access our App automatically when you use the Service, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, App and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the App. 

As it is in our legitimate interests to process your data to provide effective services and useful content to you, we collect this information in order to:

  • personalize our Service to ensure content is presented in the most effective manner for you and your device;
  • monitor and analyze trends, usage and activity in connection with our Service to improve the Service;
  • keep the Service safe and secure;
  • administer the Service, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
  • measure and understand the effectiveness of the content we serve to you and others.

Location Information

We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

Do we collect information from minors?

We do not knowingly solicit data from or market to children under eighteen (18) years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependents use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our
records. If you become aware of any data we may have collected from children under age 18, please contact us at .

Sharing Your Information

We may disclose your personal and non-personal information to our agents, contractors and service providers who are engaged to perform functions based on our instructions (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics). These third-party contractors and service providers (i) shall be permitted to obtain only the personal information they need to provide the service, and (ii) must protect personal information to the same extent as the Company, including not using it for any improper purpose.

We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

We may share your information with our business partners to offer you certain products, services, or promotions.

We may also disclose your personal information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply our Terms of Service, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or cooperate with a law enforcement or regulatory investigation, (c) protect the rights, property or safety of TBDx, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.

We may share or transfer your information in connection with, or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which case personal information would be transferred as one of the business assets of the company.

We may also disclose non-personally identifiable information on an aggregated, anonymous basis (see “Aggregated Data” section below) to our business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

We will share your personal and non-personal information for other purposes with third parties pursuant to your consent or at your direction, or as necessary to provide you with a specific Service or otherwise in accordance with applicable privacy laws. For example, if you indicate an interest in a certain launch by providing us with your email address, we will share your email address with that website owner, who may use it to contact you.

Storing Your Information

We retain your personal information for as long as necessary for processing in accordance with applicable law. The exact retention period will therefore depend upon the type of the personal information and the purpose for which it is processed. In some cases, we may be required by law to retain your personal information for a certain period of time. Once this period has expired and the processing of the personal information no longer satisfies any purpose, we will delete or anonymize the information in accordance with our data protection obligations.

Aggregated Data

We may also use your personal information and information about your Sites activity to generate Aggregated Data for internal use and for sharing with others. “Aggregated Data” means records which have been stripped of information potentially identifying Sites users, and which have been manipulated or combined to provide generalized, anonymous information. Aggregated Data will not disclose you as the source or subject of the information. Aggregated or de-identified data is not subject to this Privacy Policy.


The Sites may contain links to other sites and we are not responsible for the privacy or security practices or the content of such sites. We encourage you to read the privacy policies of linked sites. Their privacy policies and practices differ from our policies and practices.

Cookies and Other Information-Gathering Technologies

We use cookies to track user activity. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive.

We use operational cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to gauge popularity of service options. We will use this information to deliver relevant content and services to you. This also allows us to make sure that visitors see the landing page they expect to see if they return to the same web URL, and it allows us to tell you how many people click on our clients’ landing pages. 

If you do not wish to accept cookies, you can usually set your browser to decline them, and if you wish to delete or disable cookies previously placed on your computer, the “help” portion of the toolbar on most browsers will tell you how to do so. Please note, however, that if you choose to set your browser to decline, delete or disable cookies, you may not be able to access certain areas or features of our Sites. 

In addition to cookies, we or our service providers may use web beacons, pixels and similar technologies on our Sites and in email messages or newsletters. These tiny electronic images can be used to assist us in determining how many users have visited certain pages or opened messages or newsletters. However, we do NOT use these images to collect personal information.

This Website Uses Google AdWords

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Your Postings

We may provide areas on our Sites where you can post information about yourself, communicate with others, post reviews or upload content. Whenever you disclose personal information publicly (such as on publicly viewable web pages), that information becomes public and can be collected and used by others, including for the sending of unsolicited messages. We can’t control who reads your posting or what others may do with information you voluntarily post, so we encourage you to use your discretion with respect to posting personal information.

Your General Privacy Rights

You may request to access or delete the information we have collected about you by sending your request to us at the email ( ). You may be entitled, in accordance with applicable law, to submit a request through an
authorized agent. To nominate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request within applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account. We do not discriminate based on the exercise of any privacy rights that you might have.

Your California Privacy Rights

If you are a California resident, this Privacy Policy will also apply consistent with California law. California law requires that a business provide in its privacy policy a list of the categories of personal information it has in the preceding 12
months (1) disclosed for a business purpose, and (2) disclosed in exchange for valuable consideration (considered a “sale” under California law), as well as the categories of third parties to whom each category of personal information was disclosed or sold.

 Categories of personal information that may be disclosed for our business purposes Categories of third parties to whom this information may be disclosed
Affiliates, Service providers, Business
Demographic information Affiliates, Service providers, Business
Protected characteristics Affiliates, Service providers, Business
Commercial information Affiliates, Service providers, Business
Financial information Affiliates, Service providers, Business
Internet or other electronic network activity information Affiliates, Service providers, Business
Geolocation data Affiliates, Service providers, Business
Inferences drawn from the above categories Affiliates, Service providers, Business


California law also grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:

  • Right to know.
    You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.
  • Right to delete. 
    You have the right to request the deletion of the personal information we have collected from you, subject to certain exceptions. If you are a California resident and would like to exercise the delete right, please submit your request to us at the contact information listed below: .
  • Right to opt-out.
    You have the right to opt out of certain disclosers of your personal information for valuable consideration. However, we do not “sell” personal information as that term is defined under relevant California law.
  • Right to non-discrimination.
    You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

If you are a California resident and would like to exercise any of the above rights, please send an email to us at . When we receive your request, we will attempt to verify the authenticity of your request through normal account authentication practices unless we are concerned with fraud or you are seeking sensitive personal information in which case we may require additional verification steps.

Please note that we may require additional information from you in order to fulfill your request, and there may be circumstances where we will not be able to fulfill your request. For example, if you request deletion, we may need to
retain certain personal information in order to comply with our legal obligations or for other permitted purposes. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

If you are submitting a request through an authorized agent, the authorized agent should use the process described above. However, the agent must also provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also require that you verify your identity with us and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

Accessing Your Information. We will provide you with the means to ensure that the personally identifiable information that we collect and maintain about you is correct and current. You may review this information by contacting us by sending an email to .

A Record of Data Transfer. We will provide the right to request and receive, once a year and free of charge, information about third parties to whom we have disclosed certain types of personal information (if any) about you for our direct marketing purposes in the prior calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to  and please include the phrase "Personal Information Privacy Request" in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.

California Online Privacy Protection Act. As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Services about individual consumers who use our Services or visit our website and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal. org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

Your Choices

  • Revocation of consent: If you have agreed to any personal data processing activity, you can revoke your consent at any time, and this revocation is effective for all subsequent personal data processing activities. Such revocation does not affect the legitimacy of our processing before you revoke your consent or on a different legal basis than the consent.
  • Access right: You have the right to confirm to us whether your personal data has been processed, and if so, you have the right to request access to this personal data. Access information mainly includes processing purposes, categories of relevant personal data, and categories of recipients or recipients to whom personal data has been or will be disclosed. However, this is not an absolute right, and the rights and interests of others may limit your access. You have the right to request a copy of the personal data being processed. If you request additional copies, we may charge a reasonable management fee.
  • Right to correct: You have the right to require us to correct your inaccurate personal data. According to the processing purpose, you have the right to improve incomplete personal data, including by providing supplementary instructions. But you may not be able to modify certain of the initial registration information and verification information provided at the time of registration.
  • Right to be forgotten: In some cases (such as the following), you have the right to ask us to delete your personal data, and we are obliged to delete such personal data. You are also able to close your account. We verify account closure requests using information that we maintain about you. Please note that the closing of your account may be irreversible. Also, please note that your deletion of our Appfrom your mobile device will not necessarily delete your account and closing your account will not automatically result in the deletion of your information.
  • Restricted processing right: Under certain circumstances, you have the right to require us to restrict the processing of your personal data. In this case, the corresponding data will be marked and can only be processed for specific purposes.
  • Right to object: You have the right to object to our processing of your personal data at any time based on your specific circumstances, or you can ask us to stop processing your personal data.
  • Data migration right: In some cases, you have the right to receive the personal data related to you provided to us in a structured, common and machine-readable format, and you have the right to transfer these data to other entities without our restrictions.
  • Right to file a complaint: If you believe that our handling of your personal data violates the GDPR provisions, you have the right to file a complaint with the European Union or EEA member state where you live or work, or the regulatory authority where the infringement occurs. If you are located in a country or region other than the EU or EEA member state, you may also have the right to file a complaint with the local regulatory authority according to your location.

Furthermore, you also have the following rights to change the corresponding functions of your device:

  • You may be able to decide whether you see certain types of interest-based advertising in our Appby visiting your in-App
  • You may be able to manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available in the in-App
  • Your device may have controls that determine what information we collect or how we can use that information. For example, you can control whether we can use your mobile advertising identifier for advertising through settings on your Apple and Android devices.  
  • You can opt-out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.
  • If you previously chose to share precise location information, you can prevent your device from sharing precise location information (e.g. GPS location information) at any time through your device’s operating system settings. 
  • Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, we currently do not act in response to these signals.

Visiting Our Sites from Outside the United States

This Sites is operated and hosted in the United States. If you are visiting the Sites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and privacy laws of the United States may not be as comprehensive as those in your country. By using the Sites and the services available on the Sites, which are provided exclusively from the United States, You hereby consent to the transfer of your information to the United States and its collection, storage, sharing and use as described in this Privacy Policy. You further agree that all transactions relating to the Sites and our Services shall be deemed to have occurred in the United States.

International Transfers

Where we store or transfer personal information outside the European Union or European Economic Area, we have robust procedures and security measures in place to ensure the security, confidentiality and integrity of the data. For countries/regions whose data protection policies are judged to be fully competent, we are trying to implement relevant systems and processes to assist in continuous review. For countries/regions whose policies are judged to be incomplete, we are adopting relevant provisions to enforce the implementation of enterprise regulations, standard data protection provisions or approved codes of conduct. We will conduct strict due diligence on all recipients of personal data to evaluate and verify whether they have implemented appropriate security measures to protect information and ensure enforceable data subject rights, and whether they have developed effective legal remedies against data subjects (if applicable).


We will strive to prevent unauthorized access to your personal information, including:

We work to protect the security of your personal information during transmission by using Encryption Protocols And Software.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal customer information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you.

Our devices offer security features to protect them against unauthorized access and loss of data.

However, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We will continue to enhance security procedures as new technologies and procedures become available.

We strongly recommend that you do not disclose your password to anyone. If you forget your password, we will ask you for your ID and send you an email containing a link that will allow you to reset your password.

Please remember that you control what personal information you provide while using the Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them, and you should use caution in selecting the personal information you provide to others through the Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Services, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.

Contact us

If you have any questions about our privacy policy or privacy practices, please contact our Data Protection Officer by emailing

Our business changes constantly and our Privacy Notice will change also. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.