Privacy Policy

Last updated: 27 October 2026

This policy explains how CoComms handles personal data. It is written to meet the EU General Data Protection Regulation (GDPR) and the UK GDPR / Data Protection Act 2018.

1. Who we are

CoComms (including CoComms Packs) is operated by Ronnie Dog Media, Lokeren, Belgium ("CoComms", "we", "us"). We are the data controller for the personal data described here. Contact for any privacy question or request: help@cocomms.online.

2. Data we collect

Account data: your name (if given), email address, a securely hashed password, plan and trial status, and settings and preferences.
Content you create: match desks, notes, scripts, uploaded or pasted prep, and pack requests. These stay private to your account unless you choose to share or opt in to shared features.
Purchase data: what you bought, when, and its status. Card details are handled by our payment provider (see section 4). We never see or store your full card number.
Usage and technical data: IP address, browser and device type, pages and features used, error logs and security logs.
Communications: emails you send us and our replies; whether you opened or opted out of product emails.
Sample pack requests: the email address you give us to receive a free sample pack.

3. Why we use it and our legal bases

To provide the service, your account, trials, subscriptions and Packs: performance of a contract.
To keep the service secure, prevent abuse and enforce fair use, and to improve and fix the product: legitimate interests.
To keep tax and accounting records: legal obligation.
To send you product news or tips beyond essential service emails: consent or legitimate interests. You can unsubscribe at any time using the link in each email.

We do not sell your personal data and we do not use it for third-party advertising.

4. Who we share it with (processors)

Polar (polar.sh): our merchant of record. Polar is the seller of record for paid plans and Packs. It processes your payment, billing details and sales tax/VAT, and issues receipts. Polar handles that data under its own privacy policy.
Cloudflare: hosting, content delivery, security and storage of the service.
Email providers: Resend and Zoho, to send account, purchase and pack emails; Cloudflare Email Routing for mail sent to help@cocomms.online.
Fixture and match data providers: API-Football (api-sports.io) and FotMob. We request match, line-up and statistics data from them. We do not send them your account data.
AI provider: Google (Gemini API), to generate research, scripts and suggestions from match data and the content you ask it to process.
Database hosting and our professional advisers, where needed. We will also share data with authorities when the law requires it.

5. International transfers

Some of these providers process data outside the EEA and the UK, including in the United States. Where they do, we rely on adequacy decisions (including the EU–US Data Privacy Framework and the UK extension) or the European Commission's Standard Contractual Clauses (with the UK Addendum).

6. Cookies and sessions

We use only the cookies needed to run the service: a session cookie that keeps you signed in, and small functional cookies that remember your settings, referral or checkout state. We do not use advertising or cross-site tracking cookies. Because these cookies are strictly necessary, they do not need consent. Blocking them will sign you out or stop parts of the service from working.

7. How long we keep data

Account data and content: while your account is open. When you ask us to delete your account, we delete it within 30 days, except where we must keep it.
Purchase and invoice records: as long as tax and accounting law requires, usually up to 7 years in Belgium.
Security and server logs: normally no longer than 90 days.
Sample pack requests: up to 24 months, or until you ask us to delete them.

8. Your rights

You have the right to access, correct, delete, restrict or object to the processing of your personal data. You also have the right to data portability, and to withdraw consent at any time where we rely on it. Email help@cocomms.online; we reply within one month. You can also complain to a supervisory authority. In Belgium that is the Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données). In the UK it is the Information Commissioner's Office (ICO). Or you can complain to the authority where you live.

9. Security

We use encryption in transit (HTTPS), hashed passwords, access controls and provider security measures. No system is perfectly secure. If a breach affects you, we will notify you as the law requires.

10. Children

CoComms is not intended for anyone under 16, and we do not knowingly collect their data.

11. Changes

When we change this policy we update the date above. If a change is significant, we will also tell account holders by email or in the app.