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.
- Payment information: you pay through Whop, and card payments are processed by Stripe. We receive confirmation of your payment and your subscription status. We never see or store your full card number.
- Discord data: your Discord username, the role you hold, and your activity inside the community (posts, messages, and reactions).
- Communication and engagement data: how you interact with our emails and community content, and any messages you send us.
- Website data (if you use our site): basic technical and analytics data, only where a site is in use and only with your consent where required.
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 Stripe. 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 share it only with the service providers we need to run Close Rate UK, and only so they can do their job for us. These providers act as our data processors:
- Whop: our checkout and membership platform. Whop handles your subscription, manages your access, and automatically grants and removes your Discord role. Whop arranges card payment through Stripe.
- Stripe: payment processing on Whop’s behalf. Stripe handles your card details directly. We do not receive or store your full card number.
- Discord: hosts the community and manages member accounts and roles.
- Our email provider (MailerLite): sends your welcome, membership, and marketing emails. If we move to a different provider, such as ConvertKit, we will update this policy.
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
Some of our providers, including Whop, Stripe, and Discord, 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.
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
If you use a Close Rate UK website:
- We use only the cookies needed to make the site work, plus basic analytics.
- We do not run third-party marketing trackers without your consent.
- You can control or block cookies through 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 Stripe through Whop. 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.