Broomerr Media Ltd is the controller for the processing described here unless another organisation explains that it acts as a separate controller.
Who we are
Broomerr Media Ltd, company number 14908738, is registered in England and Wales. You can contact us about privacy at support@broomerrmedia.com or at Henleaze House Business Centre, 13 Harbury Road, Henleaze, Bristol, BS9 4PN, United Kingdom.
Personal data we collect
- identity and account information, such as your name, username and organisation
- contact information, such as your email address, postal address and support contact details
- order and subscription information, including products, prices, dates, licence type, status and transaction references
- limited payment information supplied by Whop or another processor, such as payment status, currency and the last digits or type of payment method; we do not normally receive complete card details
- communications, support requests, feedback, reviews and complaint records
- technical and usage information, such as IP address, device, browser, referring page, pages viewed and interactions with our website or products
- marketing preferences, mailing-list status, consent records and unsubscribe records
- fraud, security and compliance information where needed to protect users, products or payments
How we receive personal data
We receive data directly from you, from Whop and other payment or marketplace providers, from our website and products, from our self-hosted Mautic mailing system, from Google Analytics if it is enabled after the required consent, and from people or organisations acting with your authority. We may also receive limited information from public sources where lawful and relevant.
Why we use personal data
Where we rely on legitimate interests, we consider the need for the processing, its expected benefit and its effect on your rights. You may object to processing based on legitimate interests.
| Purpose | Typical lawful basis |
|---|---|
| Create and manage accounts, orders, downloads, licences and subscriptions | Performance of a contract |
| Take payment, keep transaction records and meet accounting or tax duties | Performance of a contract and legal obligation |
| Deliver products, provide updates and answer support requests | Performance of a contract and legitimate interests in customer support |
| Prevent fraud, account abuse, security incidents and licence misuse | Legitimate interests and legal obligation where applicable |
| Improve products, troubleshoot services and understand aggregate usage | Legitimate interests; consent where cookies or similar technologies require it |
| Send requested newsletters and marketing | Consent or the limited existing-customer soft opt-in where legally available |
| Handle complaints, claims and legal enquiries | Legal obligation and legitimate interests in establishing or defending legal rights |
Whop payments and marketplaces
Whop processes account, payment, fraud-prevention and transaction information under its own terms and privacy policy and shares information needed for us to supply and support your purchase. Whop may act as payment processor or merchant of record for limited purposes while Broomerr Media Ltd remains the product supplier. You should also read Whop's privacy information.
Email marketing and Mautic
We use a self-hosted installation of Mautic to manage mailing lists, consent records, campaign delivery, opens, clicks and unsubscribe requests. We send marketing to individuals only where we have valid consent or another lawful permission, such as the limited existing-customer soft opt-in where all conditions are met.
Every marketing email will identify us and provide a straightforward unsubscribe method. Withdrawing consent or unsubscribing does not affect service messages needed to deliver or support a purchase. We may retain a minimal suppression record so that we continue to respect an opt-out.
Cookies analytics and advertising
Current website status: this static website does not currently set non-essential cookies, run Google Analytics or use advertising pixels.
Our website may use strictly necessary cookies for security and requested functions. If we enable Google Analytics or another analytics or advertising technology, it will not be activated until the consent required by applicable law has been obtained. We will provide controls that let you refuse or withdraw consent before non-essential cookies are set.
A separate cookie notice or consent panel will identify the cookies in use, their providers, purposes and durations. If we introduce advertising or behavioural tracking, we will update this notice and the available consent choices before activating it.
Who receives personal data
We disclose only what is reasonably necessary to:
- Whop and other marketplace, payment, fraud-prevention and delivery providers
- Google for consented analytics and any other Google services we choose to activate
- hosting, infrastructure, email-delivery, backup and security providers supporting our website and self-hosted Mautic system
- professional advisers, insurers, auditors and accountants
- regulators, courts, law-enforcement bodies or another party where disclosure is required or permitted by law
- a purchaser, investor or successor in connection with a genuine business reorganisation, subject to appropriate safeguards
We do not sell personal data. We do not allow another business to use customer data for its own unrelated marketing unless you have separately agreed.
International transfers
Whop, Google and other service providers may process personal data outside the United Kingdom. Where UK data-protection law requires a transfer safeguard, we will rely on an adequacy regulation, the UK International Data Transfer Agreement or Addendum, or another lawful safeguard. You may contact us for information about the safeguard used for a particular transfer.
How long we keep personal data
We may delete or anonymise information sooner where it is no longer needed. Retention can be extended where required by law, a regulator, litigation hold or an active dispute.
| Record | Typical retention approach |
|---|---|
| Orders, payments, licences and tax records | Normally six years after the end of the relevant financial year, or longer if law or an active claim requires it |
| Account and subscription records | For the relationship and a reasonable period afterwards to support access, disputes and security |
| Support, complaint and contact records | Normally up to two years after closure, or longer for an unresolved claim |
| Marketing contacts and consent records | Until unsubscribe or withdrawal, followed by a minimal suppression record where necessary |
| Website analytics | For the period configured in our analytics service and reviewed regularly for necessity |
| Security and fraud records | For as long as reasonably needed to investigate incidents and protect the service |
Security
We use proportionate technical and organisational measures to protect personal data, including access controls, account security, software updates, backups and service-provider controls. No online system is completely secure. Please keep account credentials confidential and tell us promptly if you suspect unauthorised access.
Your data protection rights
Depending on the circumstances, you may have the right to access personal data, correct it, request deletion, restrict or object to processing, receive portable data, and withdraw consent. You may also object at any time to direct marketing.
Send a request to support@broomerrmedia.com. We may need to verify your identity and clarify the request. We normally respond within the period required by applicable law. Some rights are subject to exemptions, including where records must be kept for legal or contractual reasons.
Children
Our products are offered for purchase by adults aged 18 or over. We do not knowingly collect personal data from a child for the purpose of selling a product. If you believe a child has provided personal data without appropriate authority, contact us so that we can investigate and take appropriate action.
Complaints
Please contact us first at support@broomerrmedia.com so that we can investigate. You also have the right to complain to the Information Commissioner's Office or to another competent data-protection authority where applicable.
Changes to this policy
We may update this policy when our products, providers or legal duties change. The current version will show its effective date. We will provide additional notice where a material change requires it.
Contact details
Questions, complaints and notices may be sent to support@broomerrmedia.com. Broomerr Media Ltd, company number 14908738, is registered in England and Wales. Its registered address is Henleaze House Business Centre, 13 Harbury Road, Henleaze, Bristol, BS9 4PN, United Kingdom.