Your privacy matters. This policy explains what personal data we collect, why we use it, who we share it with, and your rights under UK data protection law (the UK GDPR and the Data Protection Act 2018).
1. Who we are
Will Freeman, trading as Close Rate UK, is the data controller for your personal data. You can reach us at admin@closerateuk.co.uk for anything to do with your data or this policy.
2. What we collect
- Your details: your name and email address.
- Weekly email sign-up: if you sign up on our website, your email address, which page you signed up on, and when.
- Payment information: you pay on Whop’s checkout, not on our website. Whop takes your payment and handles your card details (see section 5). Whop tells us that you have paid, your subscription status, and your username and contact details. We never see or store your card number.
- Discord data: your Discord username, the role you hold, and your activity inside the community (posts, messages, and reactions).
- /ask questions: if you use the /ask command in our Discord, the question you type and the answer you get back.
- Communication and engagement data: how you interact with our emails and community content, and any messages you send us.
- Website data: our website counts page visits using Vercel Web Analytics, which does not use cookies (see section 9).
3. How we use your data and our lawful basis
Under the UK GDPR we must have a lawful basis for using your data. We rely on the following:
- To provide the membership (give you access, run the community, deliver content and calls, manage your account). Lawful basis: performance of our contract with you.
- To take and manage payments through Whop and its payment providers. Lawful basis: performance of our contract with you.
- To keep accounting and tax records. Lawful basis: compliance with a legal obligation.
- To run, improve, and protect the community (understand what content is useful, keep the space safe, prevent misuse). Lawful basis: our legitimate interests in running a functioning, safe service.
- To send you marketing emails (offers, new features, occasional surveys). Lawful basis: your consent, which you can withdraw at any time.
- To use cookies or analytics on a website. Lawful basis: your consent for any non-essential cookies.
4. Marketing
If you have opted in, we may send you monthly updates, community highlights, offers, and occasional survey requests. You can unsubscribe at any time using the link in any email, or by emailing admin@closerateuk.co.uk. We will always send you the service and billing emails you need as a paying member, as these are part of running your membership.
5. Who we share your data with
We do not sell your data. We use a small number of service providers to run Close Rate UK. They handle your data on our behalf, and only so they can do their job for us:
- Vercel: hosts this website, counts page visits, and runs the small service that receives the weekly email sign-up form and the /ask command in our Discord.
- Discord: hosts the community and member accounts and roles. Email addresses from the sign-up form are stored in a channel on our Discord server that is set aside for them. When you use /ask, a copy of your question, the answer, and your Discord username is kept in a private channel on our Discord server so we can check the answers are right.
- Anthropic: its AI model writes the answers to /ask. When you use /ask, the text of your question is sent to Anthropic, together with our own course material, so it can write an answer from that material. Your Discord username and ID are not sent. Anthropic handles it under its commercial terms, which do not allow it to train its models on what we send.
We do not currently use an email marketing provider, and your sign-up address is not sent to one. If we start using one, we will name it here before any address is sent to it.
Paying through Whop
Membership is bought on Whop’s checkout, not on our website. Whop runs the checkout and your membership: it takes your payment, manages your subscription, and grants and removes your Discord role. Whop collects and uses the data you give on its checkout under its own privacy policy, which says it may share confirmation of your purchase, your username and your contact details with the seller, which is us.
Whop uses other companies on its checkout. They work for Whop, not for us. Whop’s privacy policy describes them as vendors and service providers that process information on Whop’s behalf, including to detect and prevent fraud. When we checked the checkout on 24 September 2026, these were:
- Basis Theory: provides the card number, expiry date and security code boxes, so what you type there goes to Basis Theory.
- Stripe: runs payment and security scripts on the checkout.
- Sardine: runs fraud and risk checks, which look at the device and browser you pay from.
- Apple Pay and Google Pay: only if you choose to pay with one of them.
- Advertising and analytics tags: see section 9.
We may also share data with professional advisers (such as an accountant) where needed, and with law enforcement or other authorities where we are legally required to.
6. International transfers
Our providers, Vercel, Discord and Anthropic, are based in the United States or process data outside the UK. Where your data is transferred outside the UK, we rely on appropriate safeguards approved for UK transfers, such as the UK International Data Transfer Agreement or the UK addendum to the EU Standard Contractual Clauses, or a country the UK recognises as providing adequate protection.
Whop is also based in the United States, and so are several of the companies on its checkout. Whop’s privacy policy explains how Whop handles transfers of the data it collects.
7. How long we keep your data
- We keep your account and community data for as long as you are an active member, and for a short period after you leave (normally up to 6 months) so we can help you rejoin or resolve any questions.
- We keep financial and transaction records for 6 years, because UK tax and accounting law requires it (HMRC).
- We keep marketing consent records for as long as you are subscribed, and a record of when you unsubscribed.
After these periods, we delete or anonymise your data.
8. Your rights
Under UK data protection law you have the right to:
- Ask for a copy of the personal data we hold about you.
- Ask us to correct data that is wrong or incomplete.
- Ask us to delete your data, where there is no legal reason for us to keep it.
- Ask us to restrict how we use your data.
- Object to us using your data for our legitimate interests.
- Withdraw your consent at any time (for example, to marketing emails).
- Ask us to send your data to you or another provider in a portable format.
To use any of these rights, email admin@closerateuk.co.uk. We will respond within one month.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator, at ico.org.uk or on 0303 123 1113. We would appreciate the chance to sort out any concern first.
9. Cookies and tracking
On our website:
- We do not set any cookies.
- We count page visits, including clicks on the Join button, with Vercel Web Analytics, which does not use cookies.
- We do not run any advertising or marketing trackers.
Whop’s checkout is Whop’s page, not ours, and it is different. When we checked it on 24 September 2026 it loaded advertising and analytics tags from Google, Meta, TikTok, Snapchat, LinkedIn, X (formerly Twitter), HubSpot and Cloudflare. These are Whop’s own tags. Whop’s privacy policy says Whop and its providers use cookies, pixels and similar tools on its services, including to advertise Whop and measure those adverts. We have not added any tracking of our own to the checkout. You can block or clear cookies in your browser settings at any time.
10. Data security
We use appropriate technical and organisational measures to protect your data. Payments are processed securely by Whop and its payment providers. Access to Discord and our community tools is controlled, and personal information is kept in protected, access-limited systems.
11. Children
Close Rate UK is only for people aged 18 and over. We do not knowingly collect data from anyone under 18.
12. Links to other sites
Our content may link to third-party websites. We are not responsible for their content or their privacy practices, so please check their own policies.
13. Changes to this policy
We may update this policy from time to time. We will tell members about any material change through Discord or by email. The effective date at the top shows when it was last updated.
14. Contact
For any privacy question, request, or complaint, email admin@closerateuk.co.uk.