Effective Date: 2/24/2026

Bloom School Pictures (“Bloom,” “we,” “us,” or “our”) respects the privacy of students, families, and school partners and is committed to protecting all personal information entrusted to us. This Privacy & Student Data Protection Policy explains how we collect, use, protect, retain, and disclose information when providing school photography and related services.

This policy applies to information collected through our websites, ordering platforms, online galleries, and in connection with photography services provided to schools and districts.

1. Our Role

When providing services to schools and districts, Bloom School Pictures operates as a School Service Contract Provider and a school official with legitimate educational interest as defined by the Family Educational Rights and Privacy Act (FERPA). Student data is processed solely for the purpose of performing contracted educational photography services.

2. Information We Collect

We may collect only the information necessary to provide school photography services, including:

• Student name

• School, grade, teacher, and/or student ID number (if provided by the school)

• Student photographs

• Parent or guardian contact information for ordering and delivery

• Payment and transaction information for purchases

We do not require students to create accounts.

3. How We Use Information

We use information solely to:

• Provide school portraits, class photos, ID photos, yearbook images, and graduation photography

• Fulfill photo orders and deliver products

• Provide customer support

• Deliver yearbook and administrative image files to schools

• Maintain secure online galleries for parent viewing and purchasing

We do not:

• Sell student or family data

• Use student data for advertising or marketing

• Build student profiles

• Use student data to train artificial intelligence systems

• Conduct targeted advertising

4. Subcontractors and Third Party Services

Bloom School Pictures uses ShootProof as our secure online gallery hosting and ordering platform.

ShootProof may have access to student images solely for secure hosting, viewing, and purchasing functionality. ShootProof is contractually required to maintain industry standard administrative, technical, and physical safeguards.

We do not authorize any other third parties to access student data.

5. Data Security

Bloom School Pictures maintains administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

Security measures include:

• Encrypted data transmission and storage

• Limited internal access based on job role

• Secure password and access controls

• Ongoing monitoring and risk assessment

All on site photographers and staff undergo background checks consistent with district and state requirements.

6. Data Retention and Deletion

Student images and related data are retained for 1 to 5 years based on school or district request to support reorders, retakes, and yearbook needs.

Upon expiration of the retention period or upon district request, data is securely deleted in accordance with industry standards so that it is permanently irretrievable.

7. Parent and Student Rights

Parents and eligible students may request to:

• Review data

• Correct inaccuracies

• Request deletion (subject to district retention requirements)

Requests may be submitted to smile@bloomschoolpictures.com. When Bloom acts as a data processor on behalf of a school, we forward requests to the school or district for direction.

8. Children’s Privacy (COPPA)

Bloom School Pictures collects personal information from children under 13 only as authorized by schools and for educational purposes in accordance with the Children’s Online Privacy Protection Act (COPPA).

9. Legal Compliance

Bloom School Pictures complies with:

• FERPA

• COPPA

• Colorado Student Data Transparency and Security Act

• Colorado Privacy Act

• Applicable federal and state privacy laws

10. Changes to This Policy

We may update this policy periodically. Material changes will be posted on our website with an updated effective date.

11. Contact Information

Bloom School Pictures

Attn: Data Protection

3275 W 32nd Ave

Denver, CO 80211

Email: smile@bloomschoolpictures.com