Effective date: 01/09/2026

 Version: 1.0

1. Who we are

This Privacy & Cookies Policy is issued by Amy Clare Deignan Limited, trading as BROODE (“BROODE”, “we”, “our” or “us”), company number 809007.

Registered office: 14 Church Drive, Eden Gate, Delgany, Co. Wicklow, A63 DY95, Ireland.

For privacy questions or requests relating to your personal data, contact support@broode.ie.

BROODE is the controller of the personal data described in this policy except where another organisation acts as an independent controller for a particular activity.

 

2. Scope of this policy

This policy applies to personal data processed in connection with BROODE, including through:

• the public BROODE website, including broode.ie;
• the BROODE membership platform and member area hosted using Kajabi;
• the BROODE branded app and community features provided through Kajabi;
• BROODE forms, onboarding, email communications, courses and member content;
• BROODE webinars and online sessions, including sessions delivered using Zoom;
• support communications, surveys, competitions and other BROODE services.

This policy is intended to cover the public website and the Kajabi membership environment together. 

3. Personal data we collect

3.1 Information you provide directly

• Identity and contact information, such as your name, email address and telephone number where requested.
• Account and membership information, such as your login/account details, membership type, membership status, subscription status and records needed to administer access.
• Approximate location information that you choose to provide, such as county, town or local area, for relevant community, meet-up or event information.
• Pregnancy and parenthood information that you choose to provide, such as your current stage, number of weeks pregnant, estimated due date, number of children and your youngest child's date of birth.
• Information about the areas in which you would like support and what you would like your BROODE guidance to be tailored around.
• Partner or support-person information, where you choose to invite a partner/support person to receive complimentary BROODE access, including their name and email address.
• Community information, including posts, comments, questions, replies, reactions, profile information and other content you choose to contribute.
• Webinar, programme and event information, including registrations and participation information.
• Communications with us, including emails, forms, support requests, complaints, survey answers and other correspondence.
• Marketing preferences and records of consent or unsubscribe choices.

3.2 Information generated through use of BROODE

• Technical information such as IP address, browser type, device type, operating-system information and similar technical identifiers.
• Usage information about how you access and interact with our public website, membership environment, app, content and services.
• Transaction information, including membership purchases, subscription status and payment status. BROODE does not directly store full card details.

3.3 Information from third parties and service providers

We may receive information from service providers where necessary to operate BROODE, for example payment status from our payment provider or information needed to administer your Kajabi account.

We do not use third-party databases to enrich member profiles with unrelated personal data.

4. Pregnancy, postpartum and other health-related information

Some information you choose to provide may reveal information about your health. This includes information that you are pregnant, your stage of pregnancy and your estimated due date. Members may also voluntarily discuss pregnancy, birth, postpartum, mental health or other health-related matters when using BROODE community or support features.

Where you provide pregnancy or postpartum information through onboarding, BROODE uses that information to personalise BROODE communications, educational content and member guidance according to your stage of pregnancy or postpartum journey. We do not use this onboarding pregnancy information for third-party advertising and we do not sell it to third parties.

Pregnancy, postpartum and other information concerning health may constitute special-category personal data under the GDPR. Where you choose to provide this information to personalise your BROODE experience, we rely on your consent under Article 6(1)(a) GDPR and your explicit consent under Article 9(2)(a) GDPR. Providing this information is optional. You may withdraw your consent at any time by contacting support@broode.ie or through any consent-management facility we make available. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, but we will stop using the relevant information for personalisation unless another lawful basis applies.

Where you choose to provide health-related information through a BROODE community, Q&A or support feature, we will process that information only for the relevant community, moderation or support purpose and will identify and obtain any explicit consent required under Article 9(2)(a) GDPR for that processing.

 

5. Information about children

BROODE membership is intended for adults aged 18 or over. We do not knowingly create BROODE membership accounts for children.

An adult member may choose to provide limited information about their child, such as their youngest child's date of birth, where this is relevant to tailoring BROODE guidance and content to the member's stage of parenthood.

Members should avoid sharing more information about a child than is reasonably necessary when using BROODE.

Where an adult Member provides limited information about their child, such as the child's date of birth, BROODE processes that information on the basis of its legitimate interests in tailoring age- or stage-appropriate guidance to the adult Member, provided that those interests are not overridden by the child's rights and interests. Members should not provide health or other special-category information about a child unless BROODE specifically requests it for a stated purpose and explains the applicable lawful basis and Article 9 condition.

 

6. How and why we use personal data

We process personal data only where we have a lawful basis to do so. Depending on the activity, the basis may include performance of our contract with you, compliance with a legal obligation, our legitimate interests or your consent.

Purpose	How we use personal data	Draft lawful basis
Membership administration	Create and manage accounts, subscriptions, access, member support and service communications.	Contract
Personalised member guidance	Tailor communications, educational content and guidance to the pregnancy/parenthood information you choose to provide.	Consent – Article 6(1)(a); and, where the information concerns health, explicit consent – Article 9(2)(a)
Community operation and moderation	Enable member participation, administer community spaces, enforce rules and respond to concerns.	Contract and/or legitimate interests
Payments	Administer payments, payment status, refunds where applicable and subscription records.	Contract and legal obligations
Customer support	Respond to enquiries, complaints and support requests and maintain appropriate records.	Contract and/or legitimate interests
Marketing	Send marketing communications where permitted and in accordance with your choices.	Consent, or where all applicable conditions for marketing to an existing customer are satisfied, legitimate interests together with the applicable existing-customer exception under Irish electronic-marketing law
Website analytics	Understand how visitors use the public BROODE website through Google Analytics, where the required cookie consent has been obtained.	Consent for non-essential cookies/analytics where required
Security and fraud prevention	Protect BROODE, members, systems, accounts and intellectual property.	Legitimate interests and/or legal obligation
Legal and regulatory compliance	Meet tax, accounting, regulatory and other legal obligations and respond to lawful requests.	Legal obligation

7. Partner/support-person access and Zapier

If you choose to invite a partner or support person to receive complimentary BROODE access, we use the name and email address you provide to send that person an invitation to create their own BROODE account. Our onboarding process asks you to confirm that you have their permission for BROODE to contact them.

BROODE uses Zapier to automate this partner-access process. Zapier receives the information needed to trigger the partner invitation and to link the complimentary partner account with the paying member's account. If the paying membership ends, Zapier may use the linked membership status/tag to trigger removal of the complimentary partner access.

Zapier is not used by BROODE for this partner-access automation to process pregnancy, postpartum or health-related onboarding information.

Where the paying Member provides a partner/support person's name and email address, BROODE processes that limited information for the purpose of administering the complimentary partner access requested by the paying Member. Our lawful basis for this initial invitation processing is our legitimate interests in administering the complimentary partner-access arrangement requested by the paying Member, having regard to the limited information used and the partner’s interests and rights. The paying Member must confirm that the person has agreed to receive the invitation. The invitation will identify the paying Member as the source of the person's details, explain why BROODE is contacting them and provide access to this Privacy & Cookies Policy. BROODE will not use the partner's details for unrelated direct marketing unless the partner separately agrees to receive it.

8. Payments

BROODE uses Kajabi Payments with payment processing provided through Stripe for membership payments. Full debit or credit card details are not stored directly by BROODE. Payment providers process payment information in accordance with their own privacy terms and applicable law.

9. Community information

BROODE includes private member community features. Information that you choose to post in a community space may be visible to other authorised members with access to that space and to BROODE administrators or moderators.

BROODE community areas are intended to be member environments, not publicly indexed profile pages. However, members should use care when sharing personal information, particularly information about health, pregnancy, children or other people.

Our Community Guidelines prohibit misuse of other members' information, including unauthorised sharing of private community content. Despite those rules, BROODE cannot guarantee that another member will never copy or share information in breach of the rules.

10. Service providers

We use third-party service providers to operate BROODE. They may process personal data on our behalf or, in some circumstances, as independent controllers for particular activities. Current core providers include:

• Kajabi — public/member platform functions used by BROODE, including membership, courses/content, app, community, forms, communications and related services;
• Kajabi Payments / Stripe — payment and subscription-related payment processing;
• Zapier — limited automation used to administer complimentary partner access and linked membership status;
• Zoom — webinars and other live online sessions where used;
• Google Analytics — analytics on the public BROODE website (broode.ie), as described in the Cookies section below.

We may also disclose personal data to professional advisers, insurers, regulators, law-enforcement bodies or other suppliers where reasonably necessary and permitted or required by law.

We do not sell your personal data.

11. Cookies and similar technologies

Cookies are small text files or similar technologies stored on or accessed from your device. They can be used to provide core website functionality, maintain security and sessions, remember preferences, and understand how visitors use a website.

11.1 Strictly necessary and functional cookies

The BROODE public website and Kajabi membership environment may use cookies that are necessary or functional for activities such as security, account sign-in, session management, checkout and the operation of member features. Where a cookie is strictly necessary for a service you request, consent may not be required under applicable law.

A functional or preference cookie that is not strictly necessary for a service requested by you will be used only where the consent required by applicable law has been obtained.

11.2 Google Analytics on the public website

Google Analytics is installed on the public BROODE website, broode.ie. It helps us understand matters such as how visitors arrive at the website, which pages are used and how visitors interact with the site. Google Analytics may use cookies or similar identifiers and may process technical and usage information.

At the date of this draft, Google Analytics has not been separately installed by BROODE within the Kajabi membership environment, and BROODE has not installed Meta Pixel in Kajabi.

Google Analytics is a non-essential analytics technology and will not be activated on the public BROODE website until the visitor has given the required consent. Visitors must be able to reject non-essential cookies and subsequently change or withdraw their cookie choices as easily as they gave consent.

11.3 Changes to tracking technologies

If BROODE later introduces additional analytics, advertising or tracking technologies, we will update this policy and our consent mechanism as appropriate before using them where consent is required.

12. Marketing communications

We may send you marketing communications where permitted by law and in accordance with your marketing preferences. You can unsubscribe using the link in a marketing email or by contacting support@broode.ie.

Unsubscribing from marketing does not necessarily prevent BROODE from sending service communications that are required to administer your membership, account, booking or transaction.

13. International data transfers

Some of the service providers used by BROODE may process personal data outside Ireland or the European Economic Area (EEA). Where personal data is transferred outside the EEA, BROODE will ensure that the transfer is made in accordance with Chapter V GDPR. This may include relying on a European Commission adequacy decision, including the EU-U.S. Data Privacy Framework where applicable to a certified recipient, or using European Commission Standard Contractual Clauses together with any supplementary safeguards required in the circumstances. You may contact support@broode.ie if you would like further information about the safeguard applicable to a particular transfer or how to obtain a copy of it.

14. Data security

We take reasonable technical and organisational measures to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. We also expect service providers processing personal data for BROODE to maintain appropriate security.

No online system can be guaranteed to be completely secure, and members are responsible for keeping their account credentials confidential.

15. How long we keep personal data

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including to provide services, administer memberships and accounts, comply with legal, tax and accounting obligations, resolve disputes and establish or defend legal claims.

Different categories of personal data may be retained for different periods. Where information is no longer required, we will delete or anonymise it in accordance with our retention practices, subject to legal obligations or other lawful requirement to retain it.

16. Your data-protection rights

Subject to applicable law, you may have rights to access your personal data, correct inaccurate data, request deletion, restrict or object to certain processing, receive certain data in a portable format and withdraw consent where processing is based on consent.

To exercise a right, contact support@broode.ie. We may need to verify your identity before acting on a request.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal and does not prevent us from processing personal data where another lawful basis applies.

17. Communications and complaints

When you contact BROODE, we may keep the information you provide and our response for customer-service, record-keeping, complaint-handling and legal purposes.

If you have a concern about how BROODE uses your personal data, please contact support@broode.ie so that we have an opportunity to address it.

You also have the right to lodge a complaint with the Irish Data Protection Commission (DPC).

18. Changes to this policy

We may update this Privacy & Cookies Policy from time to time to reflect changes to BROODE, our services, technology or applicable law. The current version will be made available through BROODE and the date at the top will be updated.