Bloomreach

Structured Summary of Important Changes

1. Major change: website content replaced by cookie-consent language

The diff substantially replaces website navigation, marketing, and product content with a cookie banner and cookie-policy language. The new text states that Bloomreach uses cookies to:

• Help users navigate the website and perform certain functions;
• Personalize the website and browsing experience;
• Analyze website usage and improve functionality;
• Customize text size, fonts, and content;
• Tailor content and show relevant ads based on user interests;
• Support integrations and website functionality.

This appears to be a broad website-content or consent-management change rather than a conventional contractual amendment.

2. Consent and cookie controls

The additions introduce or expand:

• “Accept All,” “Decline Cookies,” “Customize Consent,” and “Save My Preferences” options;
• Separate cookie categories, including “Essential,” “Functional,” and “Analytical” cookies;
• A statement that essential cookies cannot be switched off;
• A statement that users may decide which cookie categories are allowed and which are not processed.

Legal risks

• The consent language may be insufficiently specific about the purposes, providers, retention periods, international transfers, and data collected.
• The statement that analytical cookies may be used to “cater your experience” and show relevant ads could combine analytics, personalization, and advertising purposes in a way that may create transparency or consent concerns.
• The language should clearly distinguish necessary cookies from optional cookies and avoid implying that all processing is covered by one general consent.
• The phrase “which you do not allow to be processed” may be inaccurate where data is collected before consent, processed under another legal basis, or retained after withdrawal.

3. AI products and autonomous agents

The revised content adds or emphasizes:

• “Loomi AI”;
• “Agentic personalization platform”;
• “Marketing Agent” that converts a prompt into a workflow;
• “Shopping Agent 2.0”;
• “Build custom agents and workflows powered by Loomi intelligence”;
• AI-powered personalization, marketing automation, commerce search, and shopping assistance.

These changes expand the apparent scope of AI-related services and automated functionality.

4. AI model training and use of customer data

No express provision was added stating that customer data, prompts, outputs, personal data, or cookie data may be used to train, fine-tune, validate, or improve AI models. The diff also does not expressly prohibit such use.

However, the additions refer broadly to using data to:

• Analyze site usage;
• Improve website functionality;
• Personalize content and advertising;
• Power AI agents, workflows, and recommendations.

Key risk

The absence of explicit AI-training language creates uncertainty. “Improve functionality,” “powered by Loomi intelligence,” or similar wording might be interpreted broadly, but does not clearly establish:

• Whether customer data is used for model training;
• Whether data is aggregated, anonymized, or identifiable;
• Whether prompts and outputs are retained;
• Whether customer data is shared with AI providers or subprocessors;
• Whether customers can opt out of model-improvement uses;
• Whether customer data is segregated from other customers’ data.

A separate data-processing, AI-use, or product terms provision should address these points expressly.

5. Overall assessment

The changes mainly update website, cookie, personalization, and AI-product messaging. They increase transparency around cookie choices but leave significant ambiguity regarding AI data use and training. No clear contractual authorization for training AI models appears in the diff.

Summary

The diff only states that approximately 284 words were added, but does not include the actual added language or identify where it appears in the agreement.

AI Training and Data-Use Changes

• Cannot determine from the provided diff whether the customer’s data may now be:
• Used to train, fine-tune, or improve artificial intelligence or machine-learning models;
• Combined with other customers’ data for model development;
• Reviewed by human personnel for model training or quality assurance;
• Retained after termination for training or model-improvement purposes;
• De-identified, anonymized, or otherwise transformed before use; or
• Shared with affiliates, service providers, or third-party AI vendors.

Other Legal Risks

The available information is insufficient to assess whether the additions change:

• Ownership of customer data, inputs, outputs, or generated content;
• Confidentiality obligations;
• Data-retention or deletion requirements;
• Security commitments;
• Permitted purposes for processing data;
• Regulatory compliance obligations;
• Liability, indemnification, or limitation-of-liability provisions; or
• The customer’s ability to opt out of AI-related data use.

Conclusion

No substantive legal conclusion can be drawn from the supplied material because the actual 284 added words are missing. The added text should be provided in full, including any surrounding provisions, to determine whether it creates new rights to use customer data for AI training or imposes additional obligations or risks on the customer.

Structured Summary of Important Changes

1. Nature of the Changes

The diff appears to replace the original cookie-consent text with extensive Bloomreach website navigation, product-marketing, and footer content. Much of the replacement text is malformed or appears to be accidentally inserted page content rather than a coherent legal notice.

This creates a significant risk that the revised notice is incomplete, misleading, or unusable as a legally valid cookie disclosure.

2. Cookie Consent and Tracking Changes

Original position

The original language stated that:

• Cookies are used to optimize communications, improve customer experience, and personalize advertising.
• By selecting “Accept All,” the user agrees to cookie collection and use.
• Users may customize preferences or decline cookies.
• Cookies are categorized as strictly necessary, functional, analytical, and marketing.
• Analytical cookies may be used to analyze site usage and improve functionality.
• Marketing cookies may involve partnering with companies to serve relevant advertising.

Revised position

The replacement largely removes those substantive explanations and substitutes product-navigation content, including references to:

• AI-powered personalization
• Marketing automation
• Ecommerce search
• Shopping agents
• Loomi AI
• Ads and retargeting
• Product recommendations
• A/B testing
• Integrations and customer data platforms

The revised text does not clearly explain which cookies are used, what data is collected, the purposes of processing, legal bases, retention periods, third parties, or how consent can be withdrawn.

Risk

The revised wording may fail transparency and informed-consent requirements under laws such as the GDPR, UK GDPR, ePrivacy rules, and similar cookie laws. It may also make “Accept All,” “Customize,” and “Decline” controls unclear or ineffective because the supporting disclosures are missing.

3. Customer Data Used to Train AI Models

No express language was identified stating that customer data, cookie data, personal data, prompts, outputs, or customer content may be used to train, fine-tune, evaluate, or improve AI models.

However, the revised content introduces numerous AI-related services and concepts, including:

• “Loomi AI”
• “AI-powered personalization”
• “AI-native commerce search”
• “Build custom agents and workflows powered by Loomi intelligence”
• Autonomous marketing and shopping agents
• Personalization and recommendations

These references may imply extensive processing of customer or visitor data, but they do not explain whether such data is used for model training or product improvement.

AI-related risk

The absence of a clear AI-training statement creates ambiguity rather than confirming that training is prohibited. The privacy notice, customer agreement, or data-processing terms should expressly state:

• Whether customer data is used to train or improve general-purpose or shared AI models;
• Whether data is isolated to the customer’s environment;
• Whether opt-out rights are available;
• How prompts, outputs, telemetry, and derived data are handled; and
• Whether human review or third-party AI providers are involved.

4. Overall Legal and Operational Risk

The diff appears to be a major content-integrity error. Before publication, the company should restore coherent cookie disclosures, verify consent mechanics, and add a specific AI-data-use provision.

Summary of Important Changes

1. Cookie-consent language substantially removed

The prior text contained a detailed cookie notice explaining that cookies were used to:

• Optimize communications and customer experience;
• Personalize advertisements;
• Perform site functions;
• Analyze website usage and improve functionality;
• Tailor the customer experience; and
• Partner with companies to provide interest-based advertising.

It also described cookie categories—strictly necessary, functional, analytical, and marketing—and stated that users could choose which categories to allow.

The replacement removes this explanatory consent text and replaces it largely with Bloomreach marketing navigation and product descriptions. The replacement no longer clearly states:

• What data is collected through cookies;
• The purposes for each cookie category;
• That users can refuse non-essential cookies;
• How cookie choices affect processing; or
• The legal basis for processing.

Risk: This may weaken transparency and make it harder to demonstrate valid consent under privacy laws such as the GDPR, ePrivacy rules, and similar regimes. The visible “Cookie Settings” and privacy links remain in the replacement, but the diff does not show whether they provide equivalent detail.

2. Expansion and repositioning of AI-related products

The replacement adds or emphasizes:

• The “Loomi AI platform”;
• Agentic personalization;
• Marketing Agent LIVE;
• Shopping Agent 2.0;
• AI-powered email, SMS, and WhatsApp personalization;
• AI-native commerce search;
• Custom agents and workflows;
• Integrations with more than 175 systems; and
• CustomerLake and Databricks-related offerings.

The language describes autonomous agents that convert prompts into workflows and shopping companions that operate end-to-end.

Risk: These descriptions may imply increased processing of customer, behavioral, transactional, marketing, and integrated-platform data. The diff does not identify data ownership, permitted purposes, retention periods, security controls, human oversight, or responsibility for AI-generated decisions.

3. Customer data used to train AI models

There is no express new statement in the diff authorizing or prohibiting the use of customer data to train, fine-tune, evaluate, or improve AI models.

The replacement promotes AI products and intelligence but does not clarify whether:

• Customer content, prompts, campaign data, profiles, or behavioral data are used for model training;
• Data is aggregated, anonymized, or kept isolated by customer;
• Data is shared with third-party model providers;
• Customers can opt out of training or secondary use; or
• Outputs or derived data may be reused commercially.

Key risk: The absence of an explicit training position creates contractual and regulatory ambiguity. Any data-use authorization should be confirmed in the governing agreement, privacy notice, DPA, and applicable product terms—not inferred from this webpage content.

4. Recommended follow-up

Confirm that the updated privacy and cookie materials expressly address AI training, model improvement, third-party providers, customer opt-out rights, data deletion, and use of personal data in autonomous-agent workflows.

Structured Summary of Important Changes

1. Cookie notice and consent framework

The revised text replaces general website navigation and marketing content with a more detailed cookie-consent notice. It states that Bloomreach uses cookies to:

• Optimize communications and enhance customer experience;
• Personalize advertisements;
• Perform website functions;
• Analyze site usage and improve functionality; and
• Customize content, including text size, fonts, and displayed content.

The notice introduces or clarifies cookie categories:

• Essential cookies: Required for basic website functionality and cannot be disabled.
• Functional cookies: Used to provide additional functionality and personalize the browsing experience.
• Analytical cookies: Used to analyze website usage and improve performance.
• Advertising or other non-essential cookies: The text indicates that users can choose which categories are allowed and which are processed.

The revised language provides “Accept All,” “Decline Cookies,” “Customize Consent,” and preference-management options. This is a more explicit consent model, but legal sufficiency will depend on whether non-essential cookies are actually blocked before consent and whether the interface provides equally prominent acceptance and rejection options.

2. Data-use implications

The revised notice expressly states that cookie data may be used to:

• Tailor the website and show content;
• Personalize the user’s experience;
• Serve ads relevant to the user’s interests;
• Partner with companies to serve relevant advertisements; and
• Analyze usage and improve the site.

These statements broaden or clarify purposes beyond basic website operation. They create potential transparency and consent risks under privacy laws if advertising, analytics, profiling, or sharing with partners occurs without appropriate consent or opt-out rights.

3. AI-related changes

The revised content prominently adds or expands references to:

• Loomi AI
• Agentic personalization
• Marketing Agent
• Shopping Agent 2.0
• AI-powered personalization across email, SMS, and other channels;
• Custom agents and workflows powered by “Loomi intelligence”; and
• AI-native commerce search and shopping assistants.

However, the diff does not expressly state that customer data, cookie data, prompts, outputs, or usage information will be used to train, fine-tune, or improve general-purpose AI models. It also does not provide a clear customer opt-out from AI training.

The language that data may be used to personalize content, improve functionality, analyze usage, or support AI-powered services could nevertheless create ambiguity about whether such data is used for model improvement. A separate, explicit AI-data clause should identify:

• Whether customer data is used for model training or fine-tuning;
• Whether data is used to improve Bloomreach’s models for other customers;
• Retention, deletion, and de-identification practices;
• Human review and vendor/subprocessor access; and
• Customer controls or opt-out rights.

4. Other notable change

The diff substantially reorganizes website navigation and adds AI products, integrations, and marketing claims. These changes appear primarily editorial and navigational, but references to “175 more integrations” and partner advertising may signal broader data-sharing or third-party processing that should be addressed in the privacy notice and contractual data-processing terms.

Summary

The provided diff does not include the actual added contractual language. It only states:

> “Added approximately 284 words to the document”

Accordingly, it is not possible to determine what terms changed or whether the amendments create new legal or commercial risks.

AI-Training and Data-Use Changes

No substantive wording concerning AI, machine learning, model training, customer data, prompts, outputs, usage data, or service improvement is included in the diff provided.

Therefore, I cannot determine whether the new language:

• Permits the provider to use customer data to train or fine-tune AI models;
• Allows use of data for product improvement, analytics, or benchmarking;
• Applies training rights to identifiable, confidential, or personal information;
• Allows data to be aggregated, anonymized, or de-identified before use;
• Gives the customer an opt-out or requires express consent;
• Permits sharing with affiliates, vendors, or third-party model providers;
• Grants the provider rights to retain data after termination; or
• Limits the customer’s ownership or control of inputs, outputs, or derived data.

Other Legal Risks

No other contractual changes can be evaluated without the text of the additions, deletions, and replacements. In particular, the available information does not permit analysis of changes to:

• Liability or indemnification;
• Confidentiality;
• Data security and privacy;
• Intellectual-property ownership;
• Warranties and disclaimers;
• Termination and data deletion;
• Subcontracting or third-party access; or
• Governing law and dispute resolution.

Information Needed

Please provide the actual 284 added words, together with any deleted or replacement language. The changes should be marked using the stated notation, for example:

• Additions: {new language}
• Deletions: [removed language]
• Replacements: [old language]{new language}

Without the underlying text, no reliable legal comparison or AI-training risk assessment can be made.

Summary

The supplied diff indicates that approximately 284 words were removed, but it does not identify the deleted language or show any replacement text.

AI Training and Data Use

• It is not possible to determine whether the deleted text addressed:
• Use of customer data to train, fine-tune, or improve AI models;
• Whether customer data, prompts, outputs, or metadata may be retained;
• Whether data may be shared with affiliates, vendors, or model providers;
• Opt-out rights or consent requirements;
• Ownership and licensing of customer data or generated outputs;
• De-identification, aggregation, or re-identification practices; or
• Security, confidentiality, and deletion obligations relating to AI systems.

Potential Legal Risk

• Deleting language can materially change the agreement even if no replacement language is shown. The removed provisions may have limited the provider’s rights to use customer data or may have imposed confidentiality, security, deletion, or indemnity obligations.
• If the deleted text concerned AI training, its removal could potentially broaden the provider’s ability to use customer data—or eliminate protections that previously restricted such use.
• Conversely, the deletion could remove a broad data-use permission or disclaimer, which might benefit the customer. The direction of the change cannot be determined from the information provided.

Required Information

To conduct a reliable legal analysis, the actual deleted wording and any added or replacement wording are required. The statement that approximately 284 words were removed is insufficient to identify the changes, their legal effect, or any impact on customer-data use for AI training.

Structured Summary of Important Changes

1. Major replacement of the cookie-consent notice

The original text was a conventional cookie banner explaining that cookies are used to:

• Optimize communications and customer experience;
• Personalize advertisements;
• Collect and use cookies for specified purposes;
• Allow users to customize or decline cookies;
• Categorize cookies as necessary, functional, analytical, and marketing.

The replacement is largely Bloomreach website navigation and product-marketing content, including links to products, industries, resources, careers, and contact pages.

Key risks

• Loss of meaningful consent language: The revised text no longer clearly explains what data is collected, why it is collected, or how consent operates.
• Loss of granular controls: The original references to “Accept All,” “Decline Cookies,” and “Consent Preferences” are substantially removed or obscured.
• Reduced transparency: The revised content does not clearly identify cookie categories, purposes, retention, sharing, or the consequences of refusing cookies.
• Potential regulatory exposure: This could create compliance concerns under laws requiring informed, specific, freely given, and withdrawable consent, including the GDPR/ePrivacy rules, UK PECR, and certain U.S. state privacy laws.
• Possible user-interface confusion: Product links and marketing copy appear to replace legally relevant consent content, potentially making it difficult for users to understand or exercise privacy choices.

2. Expanded marketing and personalization references

The revised content promotes:

• AI-powered personalization;
• Email, SMS, RCS, WhatsApp, web, and mobile-app personalization;
• Ads and retargeting;
• Product recommendations;
• Ecommerce search;
• Autonomous marketing and shopping agents;
• “Custom agents and workflows powered by Loomi intelligence”;
• Integration with more than 175 systems.

Key risks

These references suggest broader processing and profiling capabilities, potentially involving customer behavior, browsing activity, purchase information, marketing interactions, and data imported from connected systems. However, the revised text does not explain:

• The categories of personal data involved;
• Whether data is combined across platforms;
• Whether profiling or automated decision-making occurs;
• The legal basis for such processing;
• Opt-out rights or limits on targeted advertising;
• Data-sharing arrangements with partners or integrations.

3. AI-model training

No express provision was added stating that customer data, personal data, prompts, outputs, or usage information may be used to train, fine-tune, evaluate, or improve AI models. The diff contains references to AI products, agents, workflows, and “Loomi intelligence,” but these are marketing descriptions rather than a clear data-use authorization.

Important implication

The absence of an explicit AI-training clause does not establish that customer data will not be used for training. The revised language is too unclear to determine whether customer content or usage data may be used for model improvement. This should be confirmed in the governing privacy policy, product terms, or data-processing agreement.

4. Overall assessment

The revision appears to replace privacy and cookie disclosures with website content. It materially reduces clarity around consent, tracking, personalization, profiling, and data sharing, while introducing prominent AI-related functionality without explaining associated data uses.

Structured Summary of Important Changes

1. Major Content Change

The diff appears to replace substantial website navigation and marketing content with a cookie-consent and cookie-policy interface. The revised text introduces:

• A general statement that cookies are used to optimize communications, enhance customer experience, personalize advertisements, and perform other functions.
• Links or references to a Cookie Policy and Privacy Notice.
• Cookie controls including Accept All, Decline Cookies, Customize Consent, and Save Preferences.
• Cookie categories:
• Essential/Active cookies
• Functional cookies
• Analytical cookies
• Potentially other categories associated with advertising and personalization.

The amount of unrelated navigation text remaining in the diff suggests the final presentation may be technically malformed or confusing. The contractual/legal effect of this content should therefore be confirmed in the rendered version.

2. Data-Use Changes and Risks

The new language expressly states that cookies may be used to:

• Personalize the customer’s browsing experience.
• Customize text size, fonts, and content.
• Analyze website usage and improve functionality.
• Cater the experience to the visitor.
• Partner with companies to serve advertisements relevant to the visitor’s interests.
• Tailor the website and show content or workflows based on the visitor.

These statements broaden or clarify purposes beyond basic website operation. They may involve profiling, behavioral advertising, analytics, and sharing data with advertising or business partners. The revised language should identify the relevant data types, partners, retention periods, legal bases, international transfers, and opt-out mechanisms.

3. AI Model Training

No express provision was added stating that customer data, cookie data, prompts, usage data, or personal information may be used to train, fine-tune, evaluate, or improve AI models.

The text does refer to:

• Loomi AI and agentic personalization.
• AI-powered personalization and recommendations.
• Custom agents and workflows “powered by Loomi intelligence.”
• Using data to personalize content and improve the website.

However, these references describe product functionality and personalization, not AI training rights. They should not be interpreted as granting a right to train general-purpose or customer-specific AI models.

Risk: The wording is not sufficiently explicit to rule out AI-related secondary use. If the intended position is that customer data will not be used for model training, that restriction should appear expressly in the applicable privacy notice, cookie policy, and customer agreement. If training is permitted, the agreement should specify the data covered, purposes, de-identification, customer controls, retention, model ownership, and whether data may benefit other customers.

4. Consent and Compliance Risks

• “Accept All” consent appears to cover collection and use of cookies broadly, while “Decline” and customization controls are introduced but their operation is unclear.
• The statement that only strictly necessary cookies are allowed by law may be oversimplified and jurisdiction-dependent.
• Advertising, personalization, analytics, and partner disclosures may require separate, granular consent in some jurisdictions.
• “Processed” data and partner sharing are mentioned without sufficient detail.
• The revised text should be checked for consistency with GDPR/ePrivacy, UK PECR, CCPA/CPRA, and other applicable laws.

Diff Analysis

Limitation

The supplied diff does not include the actual contractual language. It only states:

> “Added approximately 284 words to the document”

Without the added, deleted, or replacement text, it is not possible to reliably identify:

• New legal obligations or rights
• Changes to liability, indemnities, confidentiality, or termination
• Changes to data ownership or permitted data uses
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models
• Whether data is shared with affiliates, vendors, or other third parties
• Retention, deletion, security, or anonymization requirements
• Whether the customer has an opt-out or consent right
• Any changes to applicable law, jurisdiction, or dispute procedures

AI-Training Risk Review

No conclusion can be reached regarding AI-model training because the relevant added language is missing. The key terms to check for include:

• “train,” “fine-tune,” “improve,” “develop,” or “optimize” models
• “customer content,” “customer data,” “inputs,” “outputs,” or “usage data”
• Rights granted to use data in “aggregated,” “de-identified,” or “anonymized” form
• Permission to use data for “research,” “product improvement,” or “machine learning”
• Whether human reviewers or service providers may access the data
• Whether the provider retains rights after termination or deletion
• Whether use is automatic, optional, or subject to an opt-out
• Whether confidential or personal information is excluded from training

Required Information

Please provide the actual diff text, including the words shown in {additions}, [deletions], and []{replacements}. Once provided, the changes can be analyzed for:

1. The precise contractual effect of each change

2. New or increased customer risks

3. Specific AI-training and data-use permissions

4. Conflicts with confidentiality, privacy, or data-protection obligations

5. Recommended revisions or negotiation points

Summary of Changes

Overall Change

• Approximately 284 words were removed from the document.
• The specific deleted language was not provided, so it is not possible to determine precisely which obligations, rights, limitations, or protections were eliminated.

Customer Data and AI Training

• The available diff contains no identifiable language concerning customer data, artificial intelligence, machine learning, model training, or use of customer content.
• Accordingly, it is not possible to confirm whether the deletion:
• Authorizes or restricts use of customer data to train AI models;
• Changes whether customer data may be used for product improvement or analytics;
• Removes consent, opt-out, or deletion rights;
• Changes ownership or licensing rights in customer data or outputs; or
• Affects confidentiality, security, or data-retention commitments relating to AI systems.

Potential Legal Risks

Because the deleted text is unavailable, the following risks should be specifically checked:

1. Expanded data-use rights

Deleted restrictions may have limited the provider’s ability to use customer data, including for AI training or development.

2. Loss of customer protections

The deletion may remove confidentiality obligations, data-security standards, anonymization requirements, or limits on secondary use.

3. Changed consent or opt-out rights

Language allowing customers to prohibit AI training or withdraw consent may have been removed.

4. Reduced transparency

Deleted disclosure language may have explained what data is used, for what purposes, and whether data is shared with affiliates or third-party AI providers.

5. Allocation of liability

Deleted indemnities, warranties, compliance commitments, or limitations of liability may affect responsibility for misuse of data or AI-generated results.

Recommended Review

The complete redlined text or the 284 deleted words should be reviewed before approving the amendment. Particular attention should be given to sections titled:

• Customer Data or Customer Content;
• Privacy and Confidentiality;
• Artificial Intelligence or Machine Learning;
• Product Improvement or Analytics;
• Data Retention and Deletion;
• Intellectual Property;
• Security; and
• Indemnification and Liability.

Without the deleted wording, no definitive conclusion can be reached about whether the customer’s data may now be used to train AI models.

Executive Summary

The diff appears primarily to replace website navigation and marketing content with cookie-consent language and expanded product descriptions. It does not contain an express provision authorizing Bloomreach to use customer data to train AI models. However, it does expand or clarify several categories of cookie-based data use that could support profiling, personalization, analytics, advertising, and potentially AI-enabled services.

Important Changes

1. Expanded cookie collection and purposes

New language states that cookies are used to:

• Optimize communications;
• Enhance the customer experience;
• Personalize advertisements;
• Tailor the website to users’ needs;
• Perform website functions;
• Analyze site usage and improve functionality;
• Cater the user experience; and
• Partner with companies to serve relevant advertisements based on user interests.

Risk: These purposes are broader than strictly necessary website operation and may involve behavioral tracking, profiling, targeted advertising, and sharing data with advertising or business partners. The language does not identify the specific data collected, retention periods, recipients, or countries of transfer.

2. Consent and cookie controls

The additions introduce or emphasize:

• “Accept All” and “Decline Cookies” options;
• Cookie-category selection;
• A distinction between strictly necessary, functional, and analytical cookies; and
• A statement that users can change their preferences.

Necessary cookies are described as unable to be switched off, while functional and analytical cookies may be controlled by the user.

Risk: The effectiveness of consent depends on whether non-essential cookies are actually disabled unless accepted and whether the categories accurately reflect the technologies used. The diff itself does not provide sufficient detail to assess compliance with applicable consent laws.

3. AI-related services and content

The revised content promotes:

• Loomi AI;
• AI-powered personalization;
• AI agents that create workflows from prompts;
• Autonomous marketing;
• AI-native commerce search; and
• AI-powered shopping assistants.

AI training assessment: No new language expressly states that customer data, prompts, outputs, personal information, or usage data may be used to train, fine-tune, or improve general-purpose or proprietary AI models. The phrase “powered by Loomi intelligence” describes product functionality but is not a training-data license.

Residual risk: The new references to personalization, analytics, integrations, prompts, workflows, and AI agents create ambiguity about whether customer inputs or usage data may be retained or used for service improvement. This should be addressed in the operative privacy policy, product terms, or data-processing agreement.

4. Documentation and policy references

The additions point users to a Cookie Policy, Privacy Notice, and “Control Your Data” resources.

Risk: Those documents should be reviewed for any separate AI-training rights, data-sharing permissions, opt-out mechanisms, and distinctions between customer data and aggregated or de-identified data.

Summary of Changes

High-Level Overview

• Approximately 284 words have been removed from the document.
• No replacement language or added provisions are provided.
• Because the deleted text is not included, the specific legal and commercial effects cannot be determined.

Customer Data and AI Training

• The supplied diff does not identify whether the deleted language addressed:
• Use of customer data to train, fine-tune, or improve AI models;
• Whether customer data may be used for general model training or only to provide the services;
• Whether prompts, inputs, outputs, personal information, or confidential information are retained;
• Whether data is anonymized, aggregated, or de-identified before use;
• Whether the customer can opt out of AI training or requires consent;
• Whether human reviewers or third-party AI providers may access the data; or
• Ownership and permitted use of model outputs or derived data.
• However, deletion of approximately 284 words could materially weaken the customer’s protections if the removed provisions contained restrictions on data use, confidentiality, security, deletion, or AI training.
• The absence of replacement language may create ambiguity or leave broader rights in other provisions governing service improvement, analytics, de-identified information, or product development.

Other Potential Risks

The deleted language may have included important terms concerning:

• Confidentiality and permitted disclosures;
• Data security and breach notification;
• Data retention and deletion;
• Data processing roles and regulatory compliance;
• Intellectual-property ownership and licenses;
• Liability limitations, indemnities, or warranties;
• Audit rights and subcontractor use; or
• Termination and post-termination obligations.

Recommended Follow-Up

To assess the amendment accurately, obtain:

1. The full text of the approximately 284 deleted words;

2. The surrounding provisions and section headings;

3. Any new or unchanged provisions concerning “service improvement,” “analytics,” “de-identified data,” “machine learning,” or “AI”; and

4. Any separate privacy policy or data-processing agreement incorporated by reference.

Bottom line: The diff shows a potentially material deletion, but it does not provide enough information to determine whether customer data may now be used to train AI models or whether existing restrictions were removed.

Summary of Important Changes

1. Major replacement of the cookie/privacy notice

The original text was a cookie-consent notice describing:

• Use of cookies to optimize communications, personalize advertising, and improve customer experience.
• Cookie categories, including strictly necessary, functional, analytical, and marketing cookies.
• The customer’s ability to accept, decline, or customize cookies.
• A statement that certain cookie data may be processed to tailor the website and advertising.

The replacement is largely Bloomreach website navigation and marketing content, including product descriptions, industries, resources, careers, and contact links. The substantive cookie and privacy explanations have been removed.

Risk

This may leave customers without legally required information about:

• What data is collected;
• The purposes and legal bases for processing;
• Cookie categories and third parties;
• Retention periods;
• International transfers;
• How consent can be withdrawn; and
• Available privacy rights.

If this text is intended to function as a consent interface or privacy notice, replacing it with marketing content could undermine consent validity and regulatory compliance.

2. Reduced consent controls and transparency

The original wording expressly stated that customers could choose which cookie categories to allow and which not to allow, except for strictly necessary cookies. It also included “Accept All,” “Decline Cookies,” and “Customize” options.

Those explanations and controls are no longer meaningfully described. The replacement instead contains ordinary website links and product calls to action.

Risk

The revised content may make consent:

• Less informed;
• Less specific;
• More difficult to refuse or modify; and
• Potentially invalid under applicable privacy and e-privacy laws.

The statement that certain cookies “cannot be switched off” has also been removed or obscured, meaning the treatment of necessary cookies is no longer clearly explained.

3. AI-related changes

The replacement introduces extensive references to AI products and services, including:

• “Loomi AI platform”;
• “Agentic personalization platform”;
• “AI-powered personalization”;
• “AI-native commerce search”;
• “Marketing Agent”;
• “Shopping Agent”; and
• Custom agents and workflows “powered by Loomi intelligence.”

The original text did not expressly authorize using customer data to train AI models. The replacement also does not expressly state that customer data will be used for AI training.

Key risk

Although no explicit AI-training right appears in this diff, the removal of the original privacy/cookie disclosures creates uncertainty about whether data used by these AI, personalization, agent, or analytics products may be:

• Used to train, fine-tune, or improve models;
• Combined across customers or services;
• Shared with AI providers or integration partners; or
• Retained after the customer relationship ends.

The contract should expressly address whether customer data, prompts, outputs, usage data, and derived data may be used for model training or product improvement, and should state any opt-out, deletion, confidentiality, and ownership protections.

4. Overall assessment

This is not merely an editorial update. It appears to replace a functional privacy/cookie notice with marketing-site content. The principal legal concern is the loss of privacy transparency and consent language, combined with expanded AI-related product references but no corresponding explanation of AI data use.

Summary of Important Changes

1. Cookie notice and consent language substantially revised

The revised text replaces general website navigation and marketing content with a more detailed cookie-consent notice. It states that Bloomreach uses cookies to:

• Navigate and operate the website;
• Perform certain functions;
• Tailor the website to the visitor;
• Personalize browsing experiences;
• Analyze site usage and improve functionality; and
• Potentially support advertising and personalization.

The notice distinguishes between:

• Strictly necessary cookies, which cannot be switched off;
• Functional cookies, used to customize features such as text size, fonts, and content;
• Analytical cookies, used to analyze website usage and improve functionality; and
• Other cookie categories that visitors may accept or decline.

Risk

The revised language may create clearer consent choices, but it also appears to allow cookies for personalization, advertising, retargeting, and analytics. The actual purposes, vendors, retention periods, international transfers, and specific data collected are not stated in the diff. Those details should be checked in the linked Cookie Policy and Privacy Notice.

2. Broader references to personalization, advertising, and customer experience

The new content describes cookies and related technologies as being used to personalize ads, improve customer experience, and tailor website content. It also introduces or highlights products involving:

• AI-powered personalization;
• Autonomous marketing;
• AI-native commerce search;
• Marketing and shopping agents;
• Product recommendations; and
• Customer and behavioral analytics.

Risk

These changes may expand the apparent scope of tracking and profiling. Depending on the customer’s jurisdiction, use of behavioral data for targeted advertising or personalization may require consent, additional disclosures, opt-out rights, or restrictions on automated decision-making.

3. New AI products and integrations prominently added

The revised content adds descriptions of “Marketing Agent,” “Shopping Agent 2.0,” and “Loomi Connect,” including the ability to build custom agents and workflows powered by Loomi intelligence and connect to more than 175 integrations.

Risk

The language suggests that customer information may be passed among Bloomreach, connected platforms, and third-party integrations. The contractual roles, permitted purposes, security obligations, subprocessors, and allocation of responsibility for AI-generated decisions are not addressed in this diff.

4. AI model training: no express authorization identified

The diff does not expressly state that customer data, personal data, prompts, outputs, or usage data may be used to train, fine-tune, improve, or evaluate AI models. It also does not expressly prohibit such use.

Key concern

Because new AI-agent and personalization functionality is introduced without corresponding training restrictions, the customer should confirm in the operative agreement or privacy documentation:

• Whether customer data is used for model training or product improvement;
• Whether prompts, outputs, or telemetry are retained;
• Whether data is aggregated, anonymized, or shared with providers;
• Whether customers can opt out; and
• Whether data is used to train third-party or general-purpose models.

5. Overall assessment

The diff appears primarily to update website marketing and cookie-consent content rather than amend a customer services agreement. Nevertheless, it signals broader AI, profiling, advertising, and integration functionality without clearly defining data-use boundaries.

Summary of Important Changes

1. Cookie-consent notice introduced or substantially expanded

The revised text adds a detailed cookie banner and consent-preference mechanism. It states that cookies are used to:

• Navigate and operate the website;
• Personalize browsing experiences;
• Customize text size, fonts, and content;
• Analyze site usage and improve functionality;
• Tailor content and advertising;
• Support marketing, retargeting, ecommerce search, product recommendations, and other services.

Users may accept all cookies, decline non-essential cookies, or customize their preferences. Strictly necessary cookies cannot be disabled. The notice also refers users to the Cookie Policy and Privacy Notice.

Risk: The language is broad and may authorize extensive tracking, profiling, personalization, and advertising activities. The organization should ensure that cookie categories, purposes, vendors, retention periods, and consent mechanisms comply with applicable laws, including GDPR/ePrivacy, UK GDPR/PECR, and applicable U.S. state privacy laws.

2. New categories and purposes of cookies

The revised language identifies:

• Necessary/functional cookies;
• Analytical cookies;
• Cookies for personalization;
• Advertising and retargeting cookies;
• Cookies supporting ecommerce, search, recommendations, and marketing automation.

It also says data may be used to “cater your experience” and serve advertisements relevant to users’ interests.

Risk: “Relevant” advertising and personalization may involve profiling or sharing data with advertising, analytics, integration, or marketing partners. The language should clarify whether data is sold, shared for targeted advertising, or used for cross-context behavioral advertising, and should provide applicable opt-out rights.

3. AI-related functionality expanded

The website content now prominently markets AI products and services, including:

• “Loomi AI” and an “Agentic personalization platform”;
• AI-powered personalization across email, SMS, and other channels;
• AI-native commerce search;
• Marketing agents that convert prompts into workflows;
• Shopping agents and autonomous shopping companions;
• Custom agents and workflows powered by Loomi intelligence;
• Connections to more than 175 integrations.

Risk: These changes expand the described uses of customer and visitor data for AI-driven personalization, recommendations, marketing automation, search, and autonomous workflows. They may also involve data transmitted to integrated third parties.

4. AI-model training: no express authorization identified

The diff does not expressly state that customer data, personal data, prompts, outputs, or usage data may be used to train, fine-tune, or improve general-purpose AI models. It also does not add a clear prohibition on such training.

However, references to AI “intelligence,” personalization, analytics, workflow generation, and integrations could create ambiguity about whether data is used to improve Bloomreach’s AI systems.

Recommended clarification: State expressly whether customer data is used for model training; identify permitted data categories, aggregation/de-identification standards, opt-out rights, retention, subprocessors, and whether customer content is used to train models serving other customers.

Structured Summary of Important Changes

1. Cookie notice and consent language substantially removed

The original text described:

• Cookies used to optimize communications, personalize advertising, and improve customer experience.
• Collection and use of cookies upon clicking “Accept All.”
• Ability to customize or decline cookies.
• Cookie categories, including necessary, functional, analytical, and marketing cookies.
• Processing purposes and the customer’s ability to choose which categories are allowed.
• Links to the Cookie Policy and Privacy Notice.

This content has largely been replaced with Bloomreach marketing-navigation text, product descriptions, and unrelated website content. The revised text no longer clearly explains:

• What cookies are used;
• The purposes and legal bases for processing;
• Which cookies are optional;
• How consent can be withdrawn;
• How data is shared with partners;
• How long cookies or related data are retained.

Risk: The revised notice may no longer provide valid, sufficiently specific consent information under laws such as the GDPR, UK GDPR, and ePrivacy rules. The interface may also fail to distinguish clearly between “accept,” “decline,” and “customize” choices.

2. Broader marketing and personalization implications

The replacement content promotes:

• AI-powered personalization;
• Marketing automation across email, SMS, RCS, WhatsApp, web, and mobile;
• Ads and retargeting;
• Product recommendations;
• Ecommerce search;
• Customer data integrations;
• Custom agents and workflows powered by “Loomi intelligence.”

Although these appear primarily to be marketing-site content rather than contractual terms, they may imply broader processing of customer or visitor data for personalization, advertising, analytics, and automated marketing.

Risk: If this text forms part of a customer-facing privacy or consent experience, it creates ambiguity about whether data may be used across multiple channels, integrated with third-party systems, or used to create profiles and automated decisions.

3. AI model training

The diff does not expressly state that customer data, cookie data, prompts, outputs, or account information may be used to train, fine-tune, or improve AI models.

However, the new references to:

• “AI-powered personalization”;
• “Loomi intelligence”;
• Custom AI agents and workflows;
• Integrations with more than 175 systems; and
• Autonomous marketing and shopping agents

raise questions about whether customer data is processed to develop or improve AI products.

Key risk: The absence of an express AI-training provision leaves the customer unable to determine whether its data is:

• Used only to provide the contracted service;
• Used for Bloomreach’s own model training or product improvement;
• Aggregated or anonymized before training;
• Shared with model providers or integration partners; or
• Retained after termination for AI-related purposes.

A separate, explicit contractual clause should address these points.

4. Data-protection documentation appears displaced

References to the Privacy Notice, Cookie Policy, DPO, and data-control settings have been replaced or buried among unrelated navigation content.

Risk: Important legal notices may be inaccessible, misleading, or incorporated by reference incorrectly. The revised content should be reviewed for document hierarchy, version control, and enforceability.

Summary of Changes

Overall Change

• Approximately 284 words were removed from the document.
• The specific deleted language is not provided, so the legal effect of the changes cannot be determined reliably.

Customer Data and AI Training

• The supplied diff does not identify whether any language concerning customer data, artificial intelligence, machine learning, model training, or data retention was removed.
• Accordingly, it is not possible to determine whether the amendment:
• Expands or restricts the provider’s right to use customer data;
• Permits customer data to be used to train, fine-tune, or improve AI models;
• Changes whether de-identified, aggregated, or derived data may be used for training;
• Removes consent, notice, opt-out, or deletion rights;
• Changes data ownership or intellectual-property rights; or
• Affects confidentiality, security, or regulatory protections.

Potential Risks

Because the deleted text is not shown, the primary risk is loss of protections that may have appeared in the removed provisions. In particular, the deletion could be significant if it removed:

• Restrictions on using customer content or personal data for AI training;
• Requirements to obtain customer consent before such use;
• Promises that customer data would not be used to train general-purpose models;
• Data deletion, retention, or isolation obligations;
• Confidentiality or security commitments;
• Limitations on use of derived or aggregated information; or
• Customer audit, notice, or opt-out rights.

Conversely, the deletion may have removed permissive language and therefore reduced the provider’s rights. The direction of the change cannot be determined without the actual text.

Recommended Follow-Up

Provide the full before-and-after wording, or at least the approximately 284 deleted words and the surrounding provisions. Particular attention should be given to terms such as:

• “Customer Data,” “Customer Content,” or “Input”;
• “Service Improvement” or “Product Improvement”;
• “Train,” “fine-tune,” “develop,” or “improve” AI or machine-learning models;
• “Aggregated,” “de-identified,” or “derived data”;
• “Retain,” “delete,” or “ownership”; and
• Consent, opt-out, confidentiality, and security obligations.

Summary

The provided diff does not include the actual contractual language that was added, deleted, or replaced. It only states:

> “Added approximately 284 words to the document”

Accordingly, it is not possible to identify:

• Changes to the parties’ rights or obligations;
• New liability, indemnity, warranty, or termination risks;
• Changes to confidentiality or data-protection requirements;
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether such use requires customer consent or an opt-out;
• Whether data is anonymized, aggregated, retained, or shared with third parties; or
• Any restrictions on using prompts, outputs, personal data, or usage metadata for model development.

Information Needed

Please provide the actual diff text, including:

• Additions shown in {braces};
• Deletions shown in [brackets]; and
• Replacements shown as [{old text}]{new text} or in the specified format.

Once provided, the changes can be reviewed for AI-training provisions, data ownership, confidentiality, retention, security, subprocessors, and related legal risks.

Executive Summary

The diff appears to replace a cookie-consent and cookie-policy notice with extensive Bloomreach marketing, navigation, product, and careers content. This is not a conventional legal amendment: it looks like a substantial content or website-rendering error. If deployed, it could materially impair the customer’s ability to understand and control data processing.

Important Changes and Risks

1. Cookie notice and consent language removed

The prior text explained that cookies were used to:

• Optimize communications and customer experience;
• Personalize advertisements;
• Collect and use cookie data;
• Allow users to accept, customize, or decline cookie categories; and
• Process data for necessary, functional, analytical, and marketing purposes.

Much of this language has been replaced by product descriptions, navigation links, and promotional copy. The revised content no longer clearly communicates:

• What categories of cookies are used;
• The purposes of each category;
• Which cookies require consent;
• How consent can be withdrawn or changed; or
• How cookie data is processed.

Risk: This could undermine valid consent, transparency, and notice obligations under privacy laws such as the GDPR, UK GDPR, ePrivacy rules, and similar regimes.

2. Apparent loss of user controls

The original notice included “Customize,” “Decline Cookies,” “Accept All,” and consent-preference functionality. The replacement does not clearly preserve those controls or explain their operation.

Risk: Users may be unable to make a genuine, informed choice. Continuing to place non-essential cookies without effective consent could create regulatory, contractual, and reputational exposure.

3. Marketing and advertising purposes are no longer clearly disclosed

The deleted text expressly stated that marketing cookies could be used to partner with companies to serve advertisements relevant to users’ interests. The replacement instead promotes Bloomreach products and services, including personalization, ads and retargeting, and marketing automation, without clearly stating the legal basis or data-use implications.

Risk: The revised content may conceal or fail to explain profiling, behavioral advertising, sharing with partners, or related international data transfers.

4. AI-related changes

The new content introduces or expands references to:

• “Loomi AI” and “Loomi intelligence”;
• AI-powered personalization;
• Autonomous marketing and shopping agents;
• AI-native commerce search;
• Custom agents and workflows;
• Integrations with more than 175 systems; and
• Email, SMS, WhatsApp, web, mobile-app, and advertising channels.

However, the diff does not expressly state that customer data, personal data, prompts, outputs, or usage data will be used to train AI models. It also does not state that such data will not be used for training.

Risk: The new AI marketing language may create ambiguity about whether customer data is used to develop, improve, fine-tune, or evaluate AI systems. A separate contractual or privacy-policy review is needed to confirm training restrictions, data ownership, retention, subprocessors, security, and opt-out rights.

5. Possible document-integrity issue

The extensive substitution of legal text with website navigation and promotional content suggests a publishing, version-control, or rendering failure.

Recommended action: Do not publish without restoring the approved cookie notice and verifying all consent controls, AI data-use disclosures, and linked privacy documentation.

Summary

The provided material states only that approximately 284 words were added to the document. It does not include the actual inserted, deleted, or replaced legal language.

Assessment

Because the substantive text is missing, it is not possible to determine:

• What contractual terms changed;
• Whether liability, indemnity, confidentiality, privacy, security, intellectual-property, or termination rights were affected;
• Whether the customer’s data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether customer data may be shared with affiliates, vendors, or other third parties;
• Whether the customer has any opt-out, deletion, restriction, or consent rights;
• Whether data may be retained after termination; or
• Whether the changes create new compliance or commercial risks.

AI-Training Review

No conclusion can be reached regarding AI-model training because the relevant added language was not provided. The key terms to review would include language referring to:

• “Train,” “fine-tune,” “develop,” “improve,” or “enhance” models or services;
• Use of “Customer Data,” “Content,” prompts, inputs, outputs, or usage data;
• Aggregated, de-identified, anonymized, or pseudonymized data;
• Rights granted to affiliates, subprocessors, or third-party model providers;
• Retention or use of data after account termination;
• Opt-out, consent, or customer-control mechanisms; and
• Ownership of model improvements, outputs, or derivatives.

Information Needed

Please provide the full redline or the actual text showing the additions, deletions, and replacements. Without that text, any legal-risk assessment would be speculative.

Summary of Important Changes

1. Major change: content replaced with cookie-consent language

The diff substantially replaces website navigation and marketing text with a cookie banner and cookie policy-style disclosure. The new language states that Bloomreach:

• Uses cookies to navigate the website and perform certain functions.
• Uses cookies to personalize browsing, customize text size, fonts, and content.
• Uses analytical cookies to analyze website usage and improve functionality.
• May use cookie data to tailor the customer experience.
• May partner with other companies to serve advertisements relevant to a visitor’s interests.
• Allows users to accept, decline, or customize cookie categories, except for strictly necessary cookies.

Legal risks

• The language is broad and may not clearly identify the specific data collected, retention periods, recipients, international transfers, or legal bases.
• “Partner with companies” and interest-based advertising language may imply disclosure or sharing of personal data with third parties.
• The distinction between analytics, personalization, advertising, and retargeting cookies should be precise to support valid consent under applicable privacy laws.
• The statement that necessary cookies “cannot be switched off” should be limited to cookies genuinely required for the service.
• The cookie language appears mixed with unrelated page content, which could create ambiguity about what users are actually consenting to.

2. AI-related changes

The diff adds or emphasizes references to:

• “Loomi AI platform”
• “Agentic personalization platform”
• AI-powered personalization
• AI-native commerce search
• Marketing Agent and Shopping Agent products
• “Build custom agents and workflows powered by Loomi intelligence”
• Connections to more than 175 integrations

These appear primarily to be product descriptions and navigation changes.

AI training implications

No express language in the diff states that customer data, personal data, prompts, outputs, cookie data, or other customer content may be used to train, fine-tune, improve, or evaluate Bloomreach’s AI models.

Accordingly:

• The diff does not clearly add a contractual right to train AI models using customer data.
• It also does not expressly prohibit such training.
• References to “powered by Loomi intelligence,” personalization, analytics, and integrations could involve processing customer data, but they do not define whether that data is used only to provide the service or also for model development.
• Customers should seek confirmation in the governing agreement, data processing addendum, AI terms, or privacy notice regarding training, de-identification, aggregation, human review, retention, and use of data by subprocessors or third-party model providers.

3. Other notable changes

• Expanded product and integration descriptions may broaden perceived functionality without corresponding contractual limitations.
• New references to agents that autonomously build workflows and shopping experiences may raise allocation-of-responsibility issues for automated decisions, errors, unauthorized actions, and regulatory compliance.
• The diff appears to contain duplicated and malformed webpage text, creating uncertainty about the operative wording and whether the change is intended as a legal notice or merely site content.

Structured Summary of Important Changes

1. Website Navigation and Branding Changes

The diff substantially revises the website’s navigation and promotional content:

• “BFCM” is replaced with “Partners.”
• Navigation labels are reorganized to include or emphasize:
• RFP/RFI
• Company
• Our Story
• Why Bloomreach
• Leadership Team
• ESG at Bloomreach
• News
• Careers
• A promotional banner is added referring to a live event:
• “Watch a real journey built live — no slides, no roadmap pitch. Sept 2. Register Now”
• The website continues to display “Bloomreach” branding and links to “Loomi AI platform” and an “Agentic personalization platform.”

Potential risks

• Promotional language such as “Three-Times a Leader in Gartner® Report” and “Best Minds” may create substantiation, trademark, or advertising-compliance obligations.
• The “Sept 2” event reference may become inaccurate if the page remains live after the event.
• Repeated or unusual navigation text in the diff could indicate implementation or content-management errors that result in broken links or misleading user journeys.

2. Careers and Contact Information

The number associated with the Careers links changes from “69” to “76” in multiple locations:

• “Careers69” → “Careers76”
• “[69]” → “76”

This appears to be an internal count, identifier, or content reference rather than a substantive legal term.

Potential risks

• If these numbers are intended as job counts, the company should ensure they are accurate and regularly updated.
• If they are internal identifiers exposed publicly, they may indicate a formatting or deployment issue.

3. Language and Regional Options

The revised content adds or preserves regional and language options, including:

• APAC, EU, US, UK, and Canada
• English, French, and German

The second version specifically includes “Français” and “Deutsch.”

Potential risks

• Expanding or highlighting regional versions may increase the importance of ensuring that privacy notices, cookie disclosures, marketing consents, and other legal terms are properly localized and legally compliant in each jurisdiction.

4. AI and Customer Data Training

The diff references AI-related products, including:

• “Loomi AI platform”
• “Agentic personalization platform”
• “Clarity (AI-powered Shopping Assistant)”

However, the diff contains no provision stating that customer data, personal data, prompts, outputs, usage data, or other customer content may be used to train AI models. It also does not add or remove any data-usage permissions, model-training rights, confidentiality terms, or opt-out rights.

Overall Legal Significance

The changes appear primarily to concern website navigation, marketing content, regional presentation, and careers-page references. No material contractual change regarding customer data use or AI model training is shown.

Summary of Important Changes

1. Cookie notice and consent language largely removed

The prior text was a conventional cookie-consent notice explaining that cookies were used to:

• Optimize communications and customer experience;
• Personalize advertising;
• Perform necessary, functional, analytical, and marketing functions;
• Analyze website usage and improve functionality;
• Serve interest-based advertising; and
• Allow users to accept, decline, or customize cookie categories.

That language has been replaced almost entirely with Bloomreach website navigation, product marketing, and company-content text. The revised text no longer clearly explains:

• What cookies or similar technologies are used;
• The purposes for each cookie category;
• Which cookies are strictly necessary;
• Whether analytics or advertising cookies are used;
• How users can withdraw or change consent; or
• How cookie-derived data is processed.

Risk: The revised text may no longer provide legally adequate transparency or valid consent under privacy laws such as the GDPR, UK GDPR, ePrivacy rules, and certain U.S. state laws. It may also make prior consent controls unusable or misleading.

2. Privacy and cookie policy references changed or disappeared

The original notice expressly directed users to the Cookie Policy and Privacy Notice and included controls such as “Customize,” “Decline Cookies,” “Accept All,” and “Consent Preferences.”

Those references and controls appear to have been replaced by links and labels for products, resources, careers, regional websites, and marketing content. Although the final content includes a general “Privacy Policy,” “Contact DPO,” and “Cookie Settings” reference, these appear embedded in footer/navigation text rather than presented as operative consent disclosures.

Risk: Users may not have a clear way to exercise privacy rights or manage consent. The change could also create inconsistencies between the cookie banner, privacy notice, and actual tracking practices.

3. AI-related content added, but no express AI-training authorization

The revised content introduces or expands marketing references to:

• “AI-powered personalization”;
• “AI-native commerce search”;
• Loomi intelligence;
• Custom agents and workflows;
• Marketing and Shopping Agents;
• Autonomous marketing, search, and shopping functionality; and
• Integrations with other systems.

However, the diff does not expressly state that customer data, personal data, cookie data, prompts, outputs, or usage data may be used to train, fine-tune, evaluate, or improve AI models.

Important limitation: No clear customer-data AI-training permission is added. Nevertheless, the removal of the prior data-use explanations creates ambiguity about whether data collected through cookies or AI features may be used for model development or product improvement.

4. Material drafting and implementation risk

The diff appears to replace legal notice content with unrelated website-navigation content, potentially due to a faulty content-management or extraction process.

Recommended action: Confirm the intended legal text, restore complete cookie disclosures and consent controls, and separately address AI data use in a clear privacy notice or product terms provision.

Summary of Important Changes

1. Major replacement of cookie-consent content

The original cookie-banner and cookie-policy language has largely been replaced with Bloomreach website navigation and marketing content. Deleted language included:

• Consent to the collection and use of cookies.
• Ability to customize or decline cookie categories.
• Explanations of necessary, functional, analytical, and marketing cookies.
• Statements about personalization, analytics, advertising, and sharing data with partners.
• References to the Cookie Policy and Privacy Notice.

The replacement content mainly promotes Bloomreach products, including AI-powered personalization, marketing automation, search, agents, and integrations.

Risk: The revised content may no longer provide legally sufficient cookie notice or obtain valid consent. In particular, it appears to remove clear explanations of purposes, consent categories, user choices, and the consequences of accepting or declining cookies. This could create compliance risks under laws such as the GDPR/ePrivacy rules, UK PECR, and applicable U.S. state privacy laws.

2. Reduced transparency regarding data use

The deleted language explained that cookies could be used to:

• Personalize content and advertisements.
• Analyze website usage.
• Improve site functionality.
• Partner with companies to serve interest-based advertising.
• Process cookies depending on the visitor’s consent choices.

The replacement does not provide equivalent disclosures. It instead contains general product descriptions such as “AI-powered personalization,” “autonomous” agents, and “workflows powered by Loomi intelligence.”

Risk: Marketing descriptions do not substitute for a legally adequate privacy or cookie disclosure. The revised text may make it unclear what personal data is collected, for what purposes, by which parties, and on what legal basis.

3. AI and model-training implications

The diff introduces or emphasizes:

• “Loomi AI platform.”
• “Agentic personalization.”
• AI-powered marketing, search, and shopping agents.
• Custom agents and workflows “powered by Loomi intelligence.”
• Connections to more than 175 integrations.
• Intent-driven personalization and autonomous workflows.

However, the diff does not expressly state that customer data will be used to train, fine-tune, or improve AI models, nor does it expressly prohibit such use.

Risk: The absence of a training-data provision leaves an important issue unresolved. Customers cannot determine from this text whether their data, prompts, content, behavioral information, or outputs may be used for:

• Training or improving shared or general-purpose models.
• Training customer-specific models.
• Product development, analytics, or benchmarking.
• Human review or model safety processes.
• Sharing with third-party AI or integration providers.

Any customer agreement or privacy notice should address these points expressly, including ownership, confidentiality, opt-out rights, retention, de-identification, subprocessors, and whether data is isolated from other customers’ models.

4. Broken or misleading presentation risk

The diff appears to insert extensive navigation, promotional, and error-page content into the cookie-policy text, including “404” messaging and unrelated product pages.

Risk: This may be a website publishing or version-control error that makes the policy confusing, inaccessible, or legally unreliable. The correct cookie and privacy notices should be restored and separately reviewed before publication.

Summary of Important Changes

1. Navigation and marketing content replaced

The diff primarily updates website navigation labels and promotional copy. Several existing terms are replaced with new content, including:

• “BFCM” replaced with “Partners” or “ESG”, depending on location.
• “email” replaced with “at Bloomreach”.
• Promotional text about an email journey built live is replaced with navigation items such as:
• “Partners”
• “RFP/RFI”
• “Company”
• “Our Story”
• “Why Bloomreach”
• “Leadership Team”
• “ESG at Bloomreach”
• “News”
• “Careers”
• “is closer than it looks” is replaced with “RFP/RFI Company Our Story Why Bloomreach Leadership Team ESG at Bloomreach News Careers”, suggesting a page-template, navigation, or content-rendering change rather than a substantive contractual amendment.

2. Careers count updated

The displayed careers number changes from:

• “Careers 69” to “Careers 73”

This appears to be a current job-opening count. It has no apparent legal effect unless the number is incorporated into a representation, offer, or other binding commercial statement.

3. Language and regional navigation

The diff adds or preserves expanded regional and language navigation, including:

• APAC, EU, US, UK, and Canada
• English, French, and German

This may affect which regional website version, legal terms, privacy notice, or cookie settings a visitor sees. Businesses should confirm that localized legal documents remain consistent across these versions.

4. AI training and customer-data use

No changes concerning customer data, AI-model training, machine learning, or use of customer content were identified in this diff.

Although the updated navigation references the “Loomi AI platform” and an “Agentic personalization platform,” the diff does not add or remove language addressing:

• Whether customer data is used to train AI models;
• Whether data is used to improve Bloomreach’s products or models;
• Customer consent or opt-out rights;
• Ownership of inputs, outputs, or derived data;
• Data retention, anonymization, or aggregation;
• Restrictions on using customer data for general-purpose or third-party model training.

5. Overall legal significance

The changes appear predominantly editorial and navigational, with no clear amendment to contractual rights or obligations. The main legal review point is to verify that links from the revised navigation continue to direct users to the correct privacy, security, cookie, and AI-related terms.

Executive Summary

The diff appears to replace much of the website’s prior content with a cookie-consent notice and revised marketing/navigation content. The most legally significant changes concern cookie use, consent choices, profiling/personalization, analytics, and advertising. The diff does not expressly state that customer data is used to train AI models, nor does it expressly prohibit such use.

Important Changes and Risks

1. Expanded cookie disclosure and consent mechanism

The revised language states that Bloomreach uses cookies to:

• Help users navigate the website and perform functions;
• Tailor the website and display content that “might be interesting” to each visitor;
• Remember user choices;
• Support security and regulatory compliance;
• Personalize browsing experiences;
• Analyze website usage and improve functionality; and
• Partner with companies to serve relevant advertisements.

Users may accept, decline, or customize cookies, except for “strictly necessary” cookies that remain active.

Risks:

• The purposes are broad and may cover profiling, behavioral advertising, and personalization.
• “Strictly necessary” is not defined in the diff. Treating cookies as necessary when they support AI or marketing functionality could create consent and regulatory risk.
• The statement that certain cookies “cannot be switched off” may be problematic if those cookies are not genuinely essential.
• The language does not identify specific cookie providers, retention periods, data categories, international transfers, or user-rights procedures.

2. New or clearer separation of cookie categories

The revised text identifies:

• Essential/Always Active cookies;
• Functional cookies;
• Analytical cookies; and
• Marketing cookies.

Functional cookies are described as enhancing the website, analytical cookies as measuring and improving performance, and marketing cookies as enabling relevant advertising.

Risks:

• The notice may imply that analytical and marketing data is shared with third-party companies, but does not identify those companies or explain their independent uses.
• The consent interface and wording should ensure that non-essential cookies are disabled by default where required and that consent is as easy to withdraw as to give.

3. AI-related data use and model training

The updated website substantially expands references to AI products, including AI-powered personalization, autonomous marketing, search, shopping assistants, agents, and workflows. It also states that Loomi Connect is powered by “Loomi intelligence” and integrates with more than 175 systems.

However, the diff contains no express provision stating that customer data, prompts, outputs, usage data, or cookie data will be used to train, fine-tune, evaluate, or improve AI models. It also contains no express opt-out, ownership protection, de-identification commitment, or restriction on use of customer data for model training.

Risk: The absence of a clear training-use statement leaves the contractual position ambiguous. The privacy notice, product terms, data-processing agreement, and AI terms should be reviewed for provisions addressing model training and secondary use.

4. Broader personalization and advertising claims

The revision changes language from content that “maximizes revenue” to content that “might be interesting,” and adds personalization and relevant-advertising purposes.

This may reduce the strength of the commercial claim but broadens the stated behavioral use of visitor data. It may also require clearer disclosures concerning profiling, automated decision-making, and targeted advertising.

Recommended Follow-Up

Confirm whether separate terms address:

1. AI model training and improvement;

2. Customer-data ownership and permitted processing;

3. Use of prompts, outputs, and telemetry;

4. Third-party AI providers and subprocessors;

5. Cookie consent defaults and withdrawal; and

6. Profiling, targeted advertising, retention, and international transfers.

Summary

Scope of the Change

• The diff states only that approximately eight words were added.
• The actual added wording is not provided.

Legal and Commercial Impact

• It is not possible to determine whether the addition:
• Changes the parties’ rights or obligations;
• Expands or limits liability, confidentiality, indemnity, or termination rights;
• Alters data ownership, licensing, or permitted uses;
• Adds consent, notice, audit, or compliance requirements; or
• Creates new operational or financial risks.

AI Training and Customer Data

• The supplied diff does not identify any specific language concerning:
• Use of customer data to train, fine-tune, validate, or improve AI models;
• Whether customer data may be combined with other users’ data;
• Whether data is anonymized, de-identified, or retained;
• Whether customer consent is required;
• Whether derived data, prompts, outputs, or model weights may be used commercially; or
• Whether the customer may opt out of AI training.

Accordingly, no reliable conclusion can be reached about changes to AI-training rights or related privacy and confidentiality risks.

Required Information

To perform a meaningful legal analysis, provide the actual eight added words, together with the surrounding clause or a redlined version showing the relevant text.

Summary

The diff only states that approximately eight words were added, but it does not identify the actual words or their location in the agreement.

Legal and Risk Analysis

• No substantive change can be assessed from the information provided.
• It is not possible to determine whether the added language changes:
• The parties’ rights or obligations;
• Liability, indemnities, confidentiality, or termination rights;
• Data ownership or permitted data uses;
• Privacy, security, or regulatory compliance obligations; or
• AI-related data processing or model-training rights.

AI Model Training and Customer Data

The diff provides no identifiable change concerning whether customer data may be:

• Used to train, fine-tune, or improve AI models;
• Shared with model providers or other third parties;
• Retained after the customer relationship ends;
• Aggregated, anonymized, or de-identified for model development; or
• Excluded from training or subject to an opt-out.

Because the actual eight added words are not shown, any conclusion about AI training rights would be speculative.

Required Information

To perform a meaningful legal analysis, provide the exact added language and, preferably, its position in the agreement. The comparison should show the words using the stated notation, for example:

• {new language}
• [deleted language]
• [old language]{new language}

Summary

The provided diff does not include the actual contract language. It only states:

> “Added approximately 284 words to the document”

Accordingly, it is not possible to identify:

• The specific legal or commercial changes;
• New customer obligations or provider rights;
• Changes to liability, confidentiality, intellectual property, security, or termination provisions; or
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models.

AI Training and Data-Use Review

No substantive language concerning AI models or customer data is included in the diff provided. Therefore, it is not possible to determine whether the revised terms:

• Permit use of customer data for model training or improvement;
• Limit training use to aggregated, de-identified, or anonymized data;
• Require customer consent or provide an opt-out;
• Allow human review or sharing with affiliates and service providers;
• Grant the provider ownership or broad usage rights in customer inputs or outputs;
• Impose deletion, retention, or data-isolation obligations; or
• Address whether prompts, outputs, or derived information are considered confidential information.

Information Needed

Please provide the actual added, deleted, and replacement text using the stated notation. The phrase indicating that approximately 284 words were added is insufficient to perform a legal comparison or identify new risks.