Privacy Policy

Last Updated: February 5, 2026

1. Introduction

Paul Broome ("we," "us," or "our") is committed to protecting the privacy and confidentiality of all individuals who visit our website or engage with our services.

This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information.

Paul Broome operates a professional sales coaching practice and treats all client information with complete confidentiality and discretion.

We take our duty of privacy extremely seriously.

By using our website or engaging with our services, you consent to the practices described in this Privacy Policy.

2. Information We Collect

We collect several types of information to provide and improve our services.

2.1 Personal Information You Provide

When you interact with our website or services, you may voluntarily provide:

Name and contact information (email address, phone number)

Business information (company name, location, business type)

Information about your current sales situation and goals

Responses to consultation questionnaires

Communication preferences

Payment and billing information (processed securely through third-party payment processors)

Any other information you choose to provide during consultations or communications

2.2 Automatically Collected Information

When you visit our website, we may automatically collect:

IP address

Browser type and version

Device information

Pages visited and time spent on pages

Referring website addresses

Cookies and similar tracking technologies (see Section 8)

2.3 Business-Sensitive Information

As a sales coaching practice, we may collect business-sensitive information including:

Current close rates and sales performance metrics

Revenue and financial information related to your business

Customer objections and sales challenges

Any other business data you share during consultations

This information is collected only with your explicit consent and is protected with complete confidentiality.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide Services

Conduct free strategy calls

Deliver The 7 Steps to Sales Mastery™ program

Provide ongoing coaching and support

Schedule appointments and send reminders

Communicate about your sales transformation journey

3.2 To Improve Our Services

Understand how visitors use our website

Improve website functionality and user experience

Develop new programs and resources

Analyze the effectiveness of our methods

3.3 To Communicate With You

Respond to inquiries and requests

Send appointment confirmations and reminders

Provide program updates and sales tips

Send newsletters (only with your consent)

Request feedback and testimonials

3.4 For Legal and Safety Purposes

Comply with legal obligations

Protect against fraud or illegal activity

Enforce our Terms of Service

Ensure client and service security

4. Confidentiality in Coaching Relationships

Paul Broome operates with strict professional confidentiality standards. All information shared during consultations or program participation is treated with complete privacy.

4.1 What Confidentiality Means

What you share in sessions stays private

We do not disclose your participation to anyone (your team, competitors, or industry contacts won't know)

We do not share case details or business information with third parties

All records are securely stored and accessed only by authorized personnel

4.2 Exceptions to Confidentiality

Confidentiality may only be breached if:

You provide written consent to share information

A court order requires disclosure

There is evidence of illegal activity that requires reporting

Disclosure is required under UK law

If confidentiality must be breached, we will inform you unless prohibited by law.

5. How We Share Your Information

We never sell or rent your personal data. Sharing occurs only under limited circumstances:

5.1 Service Providers

Trusted third-party providers may assist with:

Website hosting

Email delivery

Scheduling and calendar tools (e.g., Calendly, Acuity)

Payment processing (e.g., Stripe, PayPal)

CRM systems

Video conferencing (e.g., Zoom)

All providers are contractually bound to protect your information.

5.2 Legal Requirements

We may disclose data when required to:

Comply with legal obligations

Protect our rights or property

Prevent fraud or illegal activity

Ensure public or client safety

5.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred. You will be notified and protections will remain in place.

5.4 With Your Consent

Examples include:

Publishing a testimonial (with identifying details removed or changed unless you provide explicit permission)

Referring you to another professional (with permission)

6. Data Security

We use robust technical and organizational measures to protect data against unauthorized access, alteration, or destruction.

6.1 Security Measures Include

SSL/TLS encryption (in transit and at rest)

Password-protected systems

Restricted data access (authorized staff only)

Regular security reviews

Secure backups

Staff training in data protection

6.2 Your Responsibility

Please:

Keep login credentials private

Use strong, unique passwords

Log out on shared devices

Notify us immediately if you suspect unauthorized access

7. Data Retention

We retain your information only as long as necessary to provide services or comply with legal obligations.

Active clients: Data retained for continuity of coaching

Former clients: Coaching records: 7 years Financial records: 6 years (UK tax law) Marketing data: Until you unsubscribe

Website analytics: Up to 2 years

When no longer needed, data is securely deleted or anonymized.

8. Cookies and Tracking Technologies

Our website uses cookies to enhance user experience and analyze traffic.

Essential cookies: Necessary for core functionality

Analytics cookies: Track website usage (e.g., Google Analytics)

Functional cookies: Remember preferences

Advertising cookies: Support targeted marketing (e.g., Facebook Pixel, Google Ads)

You can manage cookies via your browser settings.

Opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout

9. Your Rights Under UK GDPR

You have the right to:

Access – Request a copy of your personal data

Rectification – Correct inaccurate or incomplete data

Erasure ("Right to be Forgotten") – Request deletion (subject to legal limits)

Restriction – Limit processing of your data

Portability – Receive data in a structured format

Objection – Object to processing or marketing

Withdraw Consent – Revoke previously given consent

To exercise any right, contact us at: [email protected]

We respond within 30 days.

You may also file a complaint with the Information Commissioner's Office (ICO):
https://ico.org.uk/

10. Third-Party Websites

Our website may link to third-party sites (e.g., ComfyRoof.co.uk, social media platforms). We are not responsible for their privacy practices. Review their policies before sharing personal data.

11. Children's Privacy

Our services are for business owners 18 years and older.

We do not knowingly collect data from minors.

If such data is identified, it is deleted immediately.

12. International Data Transfers

Your information is primarily processed within the UK. If processed outside the UK, we ensure safeguards such as:

ICO-approved standard contractual clauses

Adequacy decisions recognizing equivalent protection

Other lawful transfer mechanisms under UK GDPR

13. Changes to This Privacy Policy

We may update this policy periodically.

When changes occur:

The "Last Updated" date will be revised

Significant updates will be announced via email or site notice

Continued use of our services signifies acceptance

Please review this policy periodically.

14. Contact Information

Paul Broome

📧 [email protected]
📧 General inquiries: [email protected]
🏢 8 Ridgeway, Ferndown, Dorset, UK, BH22 8TU

For data protection inquiries: [email protected]

We aim to respond within 30 days.

15. Professional Standards

Paul Broome operates ComfyRoof.co.uk and maintains the highest professional standards in business coaching and sales training. All client information is handled with complete confidentiality and discretion.

16. Your Consent

By using our website or services, you confirm that you have read, understood, and agree to this Privacy Policy.

If you do not agree, please discontinue use of our website and services.

If you do not agree, please discontinue use of our website and services.

END OF PRIVACY POLICY