PRIVACY POLICY
**Last Updated: October 14, 2025**
Emma Bromley and The Bromley Method ("we," "us," or "our") respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites, including bromleymethod.com and thebromleymethod.com (collectively, the "Site"), and when you purchase our products or services.
Please read this Privacy Policy carefully. By using the Site, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use the Site.
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1. INFORMATION WE COLLECT
We collect several types of information from and about users of our Site.
Information You Provide to Us
We collect information that you voluntarily provide when you:
- Register for an account or membership
- Make a purchase
- Sign up for our newsletter or email list
- Download free resources or guides
- Register for webinars, events, or training programs
- Fill out forms on our Site
- Contact us via email or contact forms
- Participate in surveys or provide feedback
- Communicate with us through any channel
**This information may include:**
- Name
- Email address
- Billing address
- Payment information (processed securely through third-party payment processors)
- Phone number (if provided)
- Account username and password
- Any other information you choose to provide
Information Collected Automatically
When you access and use our Site, we automatically collect certain information about your device and browsing behavior:
**Device & Usage Information:**
- IP address
- Browser type and version
- Operating system
- Device type (computer, mobile, tablet)
- Internet service provider
- Pages you visit on our Site
- Time and date of your visit
- Time spent on pages
- Links you click
- Referring website addresses
- Search terms used to find our Site
**Location Information:**
- General geographic location based on your IP address
Cookies and Tracking Technologies
We use cookies, pixels, web beacons, and similar tracking technologies to collect information about your browsing behavior. See Section 3 below for detailed information about cookies.
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2. HOW WE USE YOUR INFORMATION
We use the information we collect for various purposes, including:
To Provide Our Services
- Process and fulfill your orders and purchases
- Deliver digital products and membership access
- Manage your account and membership
- Process payments and prevent fraud
- Provide customer service and support
- Send transactional emails (order confirmations, receipts, account notifications)
To Communicate With You
- Send you our newsletter (with your consent)
- Provide information about products, services, and promotions
- Respond to your inquiries and requests
- Send important updates about our services or policies
To Improve Our Site and Services
- Analyze how users interact with our Site
- Monitor and analyze usage trends and preferences
- Improve Site functionality and user experience
- Develop new products, services, and features
- Conduct research and analytics
For Marketing and Advertising
- Display personalized advertisements based on your interests and characteristics
- Show you targeted ads on third-party platforms (like Facebook and Instagram)
- Measure the effectiveness of our marketing campaigns
- Make offers for third-party products and services (see Section 4)
For Legal and Security Purposes
- Comply with legal obligations and respond to legal requests
- Protect our rights, property, and safety
- Prevent fraud, abuse, and security threats
- Enforce our Terms & Conditions
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3. COOKIES AND TRACKING TECHNOLOGIES
What Are Cookies?
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. Cookies enable the website to remember your actions and preferences over time.
Types of Cookies We Use
**Essential Cookies:** Necessary for the Site to function properly (e.g., maintaining your login session, processing payments)
**Analytics Cookies:** Help us understand how visitors use our Site (e.g., Google Analytics)
**Marketing Cookies:** Used to track visitors across websites to display relevant advertisements (e.g., Facebook Pixel, advertising platform cookies)
**Preference Cookies:** Remember your settings and preferences
Specific Technologies We Use
**Google Analytics:** We use Google Analytics to analyze Site traffic and user behavior. Google Analytics uses cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to our Site. We use this information to improve our Site and services. Google's ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.
**Facebook Pixel:** We use the Facebook Pixel, a tracking code that allows us to measure the effectiveness of our advertising, build targeted audiences for ad campaigns, and remarket to people who have visited our Site. The Facebook Pixel collects information about your browsing behavior on our Site and may share this data with Facebook. This information may be used to show you targeted advertisements on Facebook and Instagram.
**Other Advertising Pixels:** We may use similar tracking pixels from other advertising platforms to measure ad performance and create targeted advertising audiences.
Your Cookie Choices
**Browser Settings:** Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. However, if you disable or refuse cookies, some parts of the Site may become inaccessible or not function properly.
**Opt-Out Tools:** You can opt out of interest-based advertising from participating companies through:
- Digital Advertising Alliance: www.aboutads.info/choices
- Network Advertising Initiative: www.networkadvertising.org/choices
- Your device settings (iOS: Limit Ad Tracking; Android: Opt out of Ads Personalization)
**Do Not Track:** Some browsers have a "Do Not Track" feature. Our Site does not currently respond to Do Not Track signals.
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4. HOW WE SHARE YOUR INFORMATION
We do not sell, rent, or lease your personal information to third parties for their direct marketing purposes without your explicit consent. However, we may share your information in the following circumstances:
Service Providers
We share information with third-party service providers who perform services on our behalf, including:
- Payment processors (to process your purchases)
- Email service providers (to send newsletters and transactional emails)
- Website hosting providers
- Customer support platforms
- Analytics providers (like Google Analytics)
- Marketing and advertising platforms (like Facebook)
These service providers are authorized to use your information only as necessary to provide services to us and are contractually obligated to protect your information.
Advertising Partners
We may share information with advertising partners to:
- Display targeted advertisements to you on third-party websites and platforms
- Measure advertising effectiveness
- Build custom audiences for advertising campaigns
**Important:** Under California law (CCPA), sharing information with advertising partners for targeted advertising may be considered a "sale" of personal information, even though we don't receive direct monetary compensation. See Section 8 for California-specific rights and how to opt out.
Third-Party Offers
From time to time, we may share your information with selected third parties to make you offers for their products or services, in exchange for a commission. We will only do this with your consent or where permitted by law. If you opt into such promotions, the third party will receive your information and their own privacy policy will apply.
Business Transfers
If we are involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Site of any change in ownership or use of your personal information.
Legal Requirements
We may disclose your information when required by law or when we believe in good faith that disclosure is necessary to:
- Comply with legal obligations, court orders, or government requests
- Enforce our Terms & Conditions or other agreements
- Protect our rights, property, or safety, or that of others
- Prevent fraud, security threats, or illegal activity
With Your Consent
We may share your information for any other purpose with your explicit consent.
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5. EMAIL COMMUNICATIONS
Newsletter and Marketing Emails
**Outside the European Union:** If you register for free resources, webinars, events, or purchase products from us, we will automatically enroll you in our email newsletter. You may unsubscribe at any time.
**European Union Residents:** We will only send you marketing emails if you affirmatively opt in to receive them.
How to Unsubscribe
Every marketing email we send includes an "unsubscribe" link at the bottom. Click this link to stop receiving marketing emails. You may also email us at emma@thebromleymethod.com to request removal from our mailing list.
**Note:** Even if you unsubscribe from marketing emails, we will still send you transactional emails related to your purchases, account, or services (e.g., order confirmations, password resets, important account updates).
Email Privacy
We are committed to keeping your email address confidential. We do not sell, rent, or lease our email lists to third parties, except as described in Section 4 above.
CAN-SPAM Compliance
All emails sent from us clearly identify the sender and provide clear information on how to unsubscribe. We comply with the CAN-SPAM Act and applicable email marketing laws.
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6. DATA SECURITY
We implement commercially reasonable security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
- Secure Socket Layer (SSL) encryption for data transmission
- Secure servers and data storage
- Regular security assessments
- Limited employee access to personal information
- Working only with reputable third-party vendors
**Payment Information:** We do not store complete credit card information on our servers. Payment information is processed and stored by our third-party payment processors who comply with PCI-DSS standards.
**Email Security:** Please note that email is not a secure medium of communication. While we take reasonable precautions, we cannot guarantee the security of information sent via email. Sending us information via email is done at your own risk.
**No Guarantee:** Despite our efforts, no security measures are perfect or impenetrable. We cannot guarantee absolute security of your information.
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7. DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
**Criteria for Retention:**
- Account holders: We retain your information as long as your account is active or as needed to provide you services
- Marketing contacts: We retain your email address until you unsubscribe from our mailing list
- Purchase records: We retain transaction records as required for accounting, tax, and legal purposes (typically 7 years)
- Analytics data: Aggregate analytics data may be retained indefinitely in anonymized form
**Deletion:** You may request deletion of your personal information at any time (see Section 8 and Section 9 for your rights).
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8. CALIFORNIA PRIVACY RIGHTS (CCPA)
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA).
### Categories of Personal Information We Collect
In the past 12 months, we have collected the following categories of personal information:
- **Identifiers:** Name, email address, IP address, account username
- **Commercial Information:** Purchase history, products/services purchased, payment information
- **Internet Activity:** Browsing history on our Site, pages visited, links clicked, search queries
- **Geolocation Data:** General location based on IP address
- **Inferences:** Preferences and characteristics derived from your activity
### Sources of Information
We collect information:
- Directly from you (when you provide it)
- Automatically through cookies and tracking technologies
- From third-party analytics and advertising platforms
### Purposes for Collection
We use your information for the purposes described in Section 2 above.
### Sale or Sharing of Personal Information
**Disclosure Regarding "Sale":** Under the CCPA, sharing personal information with advertising partners for targeted advertising may be considered a "sale," even when no money is exchanged.
**What We Share:** We share the following categories of information with advertising platforms (including Facebook, Instagram, and other ad networks) for targeted advertising purposes:
- Identifiers (IP address, device ID, email in hashed form)
- Internet activity (pages visited, products viewed)
- Inferences (interests, preferences)
**Recipients:** Advertising platforms and social media networks (e.g., Facebook/Meta, Google Ads)
**Opt-Out:** You have the right to opt out of this "sale" or sharing. See "Your California Rights" below.
Your California Rights
As a California resident, you have the following rights:
**1. Right to Know**
You can request that we disclose:
- Categories of personal information we collected about you
- Categories of sources from which we collected your information
- Our business purpose for collecting your information
- Categories of third parties with whom we share your information
- Specific pieces of personal information we collected about you
**2. Right to Delete**
You can request that we delete your personal information, subject to certain exceptions (e.g., to complete transactions, comply with legal obligations, or prevent fraud).
**3. Right to Opt-Out of Sale/Sharing**
You can opt out of the "sale" or sharing of your personal information for targeted advertising purposes.
**4. Right to Correct**
You can request that we correct inaccurate personal information we maintain about you.
**5. Right to Limit Use of Sensitive Personal Information**
We do not collect or use sensitive personal information in ways that would trigger this right.
**6. Right to Non-Discrimination**
We will not discriminate against you for exercising any of your CCPA rights. You will not be denied services, charged different prices, or provided different quality of service for exercising your rights.
How to Exercise Your California Rights
**To Submit a Request:**
**Email:** emma@thebromleymethod.com with subject line "CCPA Privacy Request"
**In your request, please specify:**
- Which right you are exercising (Know, Delete, Opt-Out, or Correct)
- Sufficient information to identify you (name, email address associated with your account)
- A description of your request
**Verification:** For your security, we may need to verify your identity before responding to your request. We will ask you to provide information that matches what we have on file.
**Response Time:** We will respond to verified requests within 45 days. If we need more time, we will notify you and may take up to 90 days total.
**Authorized Agents:** You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization.
Do Not Sell or Share My Personal Information
**To opt out of the "sale" or sharing of your personal information for targeted advertising:**
1.**Email us:** emma@thebromleymethod.com with subject "Do Not Sell My Information"
2. **Opt out of cookies:** Use the cookie settings in your browser
3. **Opt out of Facebook Pixel:** Adjust your Facebook ad preferences at www.facebook.com/adpreferences
4. **Use opt-out tools:** Visit www.aboutads.info/choices or www.networkadvertising.org/choices
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9. EUROPEAN UNION PRIVACY RIGHTS (GDPR)
If you are located in the European Union (EU) or European Economic Area (EEA), you have specific rights under the General Data Protection Regulation (GDPR).
Legal Basis for Processing
We process your personal information based on the following legal grounds:
- **Consent:** When you have given us permission (e.g., to send marketing emails)
- **Contract:** To fulfill our contractual obligations to you (e.g., deliver products you purchased)
- **Legitimate Interests:** For our business purposes, such as improving our services, where these interests don't override your rights
- **Legal Obligations:** To comply with applicable laws
Your GDPR Rights
**1. Right to Access**
You can request access to your personal data that we hold.
**2. Right to Rectification**
You can request that we correct inaccurate or incomplete personal data.
**3. Right to Erasure ("Right to Be Forgotten")**
You can request that we delete your personal data in certain circumstances.
**4. Right to Restrict Processing**
You can request that we limit how we use your personal data.
**5. Right to Data Portability**
You can request a copy of your personal data in a structured, machine-readable format.
**6. Right to Object**
You can object to our processing of your personal data based on legitimate interests or for direct marketing purposes.
**7. Right to Withdraw Consent**
Where we process your data based on consent, you can withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.
**8. Right to Lodge a Complaint**
You have the right to lodge a complaint with your local supervisory authority if you believe we have violated your data protection rights.
### How to Exercise Your GDPR Rights
**Email:** emma@thebromleymethod.com with subject line "GDPR Privacy Request"
We will respond to your request within one month. If we need more time, we will inform you and may take up to three months total.
Data Transfers
We are based in the United States. If you are accessing our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our service providers operate. By using the Site, you consent to this transfer.
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10. CHILDREN'S PRIVACY
Our Site is not intended for children under the age of 13 (or 16 in the EU). We do not knowingly collect personal information from children under 13.
**If you are under 13, do not:**
- Use or access the Site
- Register for an account
- Make any purchases
- Provide any personal information about yourself
If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as quickly as possible.
If you believe we might have information from or about a child under 13, please contact us at emma@thebromleymethod.com.
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11. THIRD-PARTY WEBSITES AND SERVICES
Our Site may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices or content of these third parties.
**When you click on a third-party link:**
- You are leaving our Site
- Our Privacy Policy no longer applies
- The third party's privacy policy governs their collection and use of your information
We encourage you to review the privacy policies of any third-party sites you visit.
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12. INTERNATIONAL USERS
Our Site is operated from the United States and is intended for users in the United States. If you are accessing the Site from outside the United States, please be aware that:
- Your information will be transferred to and processed in the United States
- U.S. data protection laws may differ from those in your country
- By using the Site, you consent to this transfer and processing
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13. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time. Changes will be effective immediately upon posting to the Site.
**We will notify you of material changes by:**
- Updating the "Last Updated" date at the top of this page
- Sending an email to the address associated with your account (for significant changes)
- Posting a notice on our Site homepage (for significant changes)
**Your continued use of the Site after changes are posted constitutes your acceptance of the revised Privacy Policy.**
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
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14. CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
**Email:** emma@thebromleymethod.com
**Please allow up to 45 days for us to respond to privacy-related inquiries.**
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15. CONSENT
By using the Site, you consent to this Privacy Policy and agree to its terms.
**BY USING THE BROMLEY METHOD WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO ITS TERMS.**