Section 1 — Introduction
Brookfield Media LLC™, presented publicly as Brookfield Media Group ("Company," "we," "us," or "our"), is committed to lawful, fair, and transparent collection and use of your personal information. This Privacy Policy ("Policy") governs how we collect, use, store, share, and protect information from individuals who access or use our websites, digital products, courses, coaching programs, live training programs, communities, software tools, and any related content or services (collectively, the "Services").
This Policy applies to www.ralphervin.com and to all other websites, subdomains, funnels, landing pages, registration pages, order forms, member portals, communities, and platforms operated by the Company, including premiumofferschallenge.com and any successor, replacement, or additional domains used to market or deliver the Services.
This Policy applies to all users of our Services regardless of location. By accessing or using our Services, you agree to the terms of this Policy. If you do not agree with any part of this Policy, you should not use our Services.
This Policy should be read together with our Terms of Service, which govern your use of the Services generally.
We may update this Policy from time to time to reflect changes in our practices, technology, or applicable law. The "Last Modified" date at the top of this document indicates when the most recent revision was made. Your continued use of our Services after any update constitutes acceptance of the revised Policy. Where changes are material, we will make reasonable efforts to notify you by email or by a prominent notice on our website.
Region-specific provisions. Certain sections of this Policy, which are clearly labeled, apply only to residents of particular jurisdictions, such as California, other United States jurisdictions with comprehensive privacy laws, the European Economic Area, and the United Kingdom. All other provisions apply to every user of the Services regardless of location.
Section 2 — Information We Collect
We collect personal information that you voluntarily provide when you:
Register for an account or create a user profile
Purchase a product, course, program, or subscription
Submit an inquiry, application, intake form, or contact form
Apply for or enroll in a coaching, group, or private program
Subscribe to our email list or newsletter
Provide your mobile phone number and opt in to text messages
Participate in surveys, challenges, contests, community discussions, or live sessions
Submit a testimonial, review, or written or recorded feedback
Communicate with us by email, phone, text, or any other channel
This information may include your full name, email address, mobile and other phone numbers, mailing and billing address, payment information (processed by third-party payment processors; we do not store full payment card numbers), business name, business stage, revenue range, time availability, business goals, and any other information you choose to provide.
Application information. Where you apply for a program, we collect the responses you provide, including business revenue range, investment readiness, available time commitment, desired start timing, and similar business qualification information. We use this information to evaluate program fit and to communicate with you about the program.
When you interact with our Services, we and our service providers may automatically collect technical and usage information, including:
IP address, which may constitute personal data under applicable privacy laws
Browser type, version, and language settings
Device type, operating system, and unique device identifiers
Pages visited, time spent on pages, links clicked, and navigation paths
Referring and exit URLs, and campaign tracking parameters such as UTM values
Date and time of your visit
General geographic location derived from IP address
Email open and click activity where you have received email from us
This information is collected through cookies, web beacons, pixel tags, and similar technologies described in Section 5.
We may receive information about you from third-party sources, including:
Payment processors who provide transaction confirmation data
Social media and video platforms where you interact with our content or connect an account
Analytics and advertising platforms that provide aggregated audience data
Referral partners or affiliates who direct you to our Services
We use this information to verify transactions, improve our Services, and personalize your experience.
We do not intentionally collect sensitive categories of personal information, including health or medical information, genetic or biometric data, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions, precise geolocation, or account login credentials for accounts other than ours.
We collect financial account information only to the extent necessary to process a payment, and that information is collected and stored by our payment processors rather than by us.
We do not require, request, or condition access to any Service on disclosure of your religious beliefs or affiliation. Where you voluntarily disclose such information in a community discussion, application response, live session, or communication with us, we do not use it to make decisions about program eligibility or pricing.
Please do not submit sensitive personal information through our Services. If you inadvertently provide such information, we will delete it as soon as reasonably practicable upon becoming aware of it.
For purposes of the California Consumer Privacy Act and comparable state laws, the following identifies the statutory categories of personal information we collect. Examples given are illustrative rather than exhaustive.
Identifiers. Collected. Name, postal address, email address, phone number, IP address, and account identifiers.
Customer records information (Cal. Civ. Code 1798.80(e)). Collected. Billing address and payment confirmation data. We do not store full payment card numbers.
Protected classification characteristics. Not collected.
Commercial information. Collected. Products and programs purchased, purchase history, and application responses regarding business revenue and readiness.
Biometric information. Not collected.
Internet or network activity. Collected. Browsing and interaction history within our Services, search history within our Services, and email open and click data.
Geolocation data. Collected, general only. Approximate city or region derived from IP address. We do not collect precise GPS location.
Sensory data. Collected, limited. Audio and video recordings of group calls, live sessions, and coaching sessions where recording is disclosed.
Professional or employment information. Collected. Business name, role, business stage, revenue range, and industry.
Education information. Not collected.
Inferences. Collected. Preferences and interests derived from the categories above, used to personalize content and marketing.
Sensitive personal information. Not collected. See Section 2.4.
Sources. We collect these categories directly from you, automatically through your use of the Services, and from the third-party sources described in Section 2.3.
Business purposes. We collect these categories for the purposes described in Section 3, and we disclose them to the categories of recipients described in Section 6.
Section 3 — How We Use Your Information
We use the information we collect to:
Create, manage, and maintain your account and access to purchased Services
Process payments and fulfill orders, enrollments, and service agreements
Deliver course content, coaching sessions, live trainings, program materials, and community access
Evaluate applications and determine program fit
Send transactional communications, including purchase confirmations, receipts, access credentials, scheduling notices, and service-related notices
Send marketing and promotional communications about our products, programs, and events, where you have opted in or where permitted by applicable law
Send text messages where you have provided your mobile number and opted in
Respond to your inquiries, support requests, and feedback
Personalize your experience and improve the relevance of our content and recommendations
Analyze usage patterns and improve the performance, design, and content of our Services
Measure the effectiveness of our marketing and advertising
Record and archive group sessions and live trainings for replay and program delivery
Enforce our Terms of Service and protect the rights, property, and safety of the Company and others
Comply with legal obligations, respond to legal process, and cooperate with regulatory authorities
Detect, investigate, and prevent fraudulent transactions, chargebacks, and other prohibited or illegal activity
We will not use your personal information for purposes materially different from those described above without obtaining your prior consent or as otherwise required or permitted by applicable law.
Section 4 — Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)
If you are located in the European Economic Area, the United Kingdom, or another jurisdiction requiring a legal basis for processing, we process your personal information under one or more of the following:
Contractual Necessity. Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract, such as delivering a purchased program.
Legitimate Interests. Processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights, such as improving our Services, preventing fraud, and marketing to existing customers.
Consent. You have given explicit consent for a specific purpose, such as subscribing to marketing emails or opting in to text messages. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Legal Obligation. Processing is necessary to comply with a legal or regulatory obligation.
Vital Interests. Processing is necessary to protect the vital interests of you or another natural person.
Section 5 — Cookies and Tracking Technologies
We use cookies and similar technologies, including web beacons and pixel tags, to operate and improve our Services and to deliver relevant advertising. These technologies help us understand how visitors use our Services, remember your preferences, and measure the effectiveness of our marketing.
Strictly Necessary. Required for the Services to function, enabling core features such as security, account access, and order processing. These cannot be disabled without breaking functionality.
Analytics and Performance. Used to collect information about how visitors use our Services, including pages visited, time on site, and errors. This data is aggregated and anonymized where possible.
Functional. Used to remember your preferences and settings to provide an enhanced experience.
Marketing and Targeting. Used to deliver advertising relevant to your interests. These may include pixels and tracking tags from third-party advertising platforms and may track activity across websites to build a profile and show you relevant ads.
We may use tracking pixels, tags, and similar technologies provided by third-party advertising and analytics platforms, including but not limited to Meta Pixel, Google Analytics, Google Tag Manager, YouTube, and our CRM and marketing automation platform. These third parties maintain their own privacy policies governing their use of information collected through these technologies. We are not responsible for their practices.
Most web browsers allow you to control cookies through browser settings. You may refuse non-essential cookies by adjusting those settings, though doing so may limit certain features. You may also opt out of interest-based advertising through the Digital Advertising Alliance at www.aboutads.info, the Network Advertising Initiative at www.networkadvertising.org, or through platform-specific opt-out controls. Opting out does not mean you will stop seeing ads. It means the ads you see may be less relevant.
Section 6 — How We Share Your Information
We do not sell your personal information for money. We may disclose your personal information in the following circumstances.
We share information with third-party vendors who assist us in operating our business and delivering our Services, including:
Payment processors for billing and transaction processing
CRM and marketing automation platforms for contact management, email and text delivery, scheduling, and funnel operations
Email and text message service providers
Video hosting, course delivery, and live session platforms
Analytics platforms for website and content performance measurement
Scheduling and calendar tools
Cloud storage and infrastructure providers
Contractors, coaches, and team members supporting program delivery
These providers are authorized to use your personal information only as necessary to perform services on our behalf and are contractually required to protect it in a manner consistent with this Policy.
We may share information with affiliated entities for purposes consistent with this Policy. In the event of a merger, acquisition, reorganization, dissolution, or sale of all or part of our assets, your information may be transferred to the acquiring entity, subject to the same protections described here.
We may disclose personal information where required by law, court order, or governmental or regulatory authority, or where we believe in good faith that disclosure is necessary to comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the Services, or protect the safety of users or the public.
We may share information in ways not described above where we have obtained your explicit consent.
We do not sell personal information for monetary consideration. However, our use of certain advertising cookies and pixels may constitute a "sale" or "sharing" of personal information for cross-context behavioral advertising under the California Privacy Rights Act and comparable state laws. You may opt out as described in Section 11.
Section 7 — Text Message and Mobile Information
Where you provide your mobile phone number and opt in, we may send you text messages relating to your account, your purchases, program delivery, scheduling, and, where you have consented, marketing and promotional messages. Consent to receive text messages is not a condition of any purchase. Message frequency varies. Message and data rates may apply.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All categories of information sharing described in Section 6 exclude text messaging originator opt-in data and consent. This information is not shared with any third parties, other than with the service providers strictly necessary to transmit the messages you have requested, who are prohibited from using it for any other purpose.
You may opt out at any time by replying STOP to any message, after which you will receive a single confirmation message and no further messages. Reply HELP for assistance, or contact us using the details in Section 18.
We retain a record of your opt-in and any opt-out request as required by applicable law and by mobile carrier requirements.
Section 8 — International Data Transfer
The Company may, at its sole discretion, operate an affiliate or referral program. Participation is by approval only and is governed by a separate written affiliate agreement that states the applicable commission rate, payout schedule, attribution window, and program rules. Nothing in these Terms creates an affiliate relationship, entitles any person to commission, or obligates the Company to operate an affiliate program.
Where an affiliate program is in effect, approved affiliates are prohibited from making income claims, results guarantees, earnings representations, or any statement about the Company's products that is not expressly authorized in writing by the Company. Affiliates must comply with all applicable advertising laws and disclosure requirements, including Federal Trade Commission endorsement and testimonial guidelines.
The Company reserves the right to remove any approved affiliate at any time, for any reason, with or without notice, and to withhold or reverse commission on any sale that is refunded, disputed, charged back, or otherwise cancelled.
Section 9 — Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy and in accordance with our legal and regulatory obligations. Our retention periods are as follows:
Account and Transaction Data. Retained for the duration of your active account plus seven years following account closure or the last transaction, to comply with tax, accounting, and legal record-keeping requirements.
Course and Program Access Records. Retained for the duration of your enrollment plus five years, to support potential disputes, refund inquiries, or regulatory requests.
Application Responses. Retained for three years from submission, whether or not the application resulted in enrollment.
Session Recordings. Retained for the duration of the program plus any communicated replay window, and thereafter archived for up to three years.
Marketing and Communications Data. Retained until you unsubscribe, withdraw consent, or request deletion, whichever occurs first.
Text Message Consent Records. Retained for four years following opt-out, as required for compliance with applicable telecommunications law.
Support and Correspondence Records. Retained for three years from the date of the last communication.
Automatically Collected Technical Data. Retained for up to twenty-four months, after which it is anonymized or deleted.
When personal information is no longer needed and no legal retention obligation applies, we securely delete, destroy, or anonymize it so that it can no longer be associated with you. We may retain a record of your email address or phone number following an unsubscribe or opt-out request solely to ensure we do not contact you again.
Section 10 — How We Protect Your Information
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include encrypted transmission of sensitive data using Secure Sockets Layer technology, access controls limiting data access to authorized personnel with a legitimate business need, secure hosting environments maintained by our infrastructure providers, and periodic review of our security practices.
However, no method of transmission or storage over the internet is completely secure. We cannot guarantee absolute security. Any transmission of personal data to our Services is at your own risk. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately using the details in Section 18.
In the event of a data breach affecting your personal information, we will notify you and the appropriate regulatory authorities as required by applicable law.
Section 11 — Your Privacy Rights
Depending on your location and applicable law, you may have some or all of the following rights.
Right to Access. You may request a copy of the personal information we hold about you.
Right to Correction. You may request that we correct inaccurate or incomplete personal information.
Right to Deletion. You may request that we delete your personal information, subject to legal exceptions such as where retention is required by law or necessary to fulfill a contract.
Right to Opt Out of Marketing. You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email, by replying STOP to any text message, or by contacting us. Opting out of marketing does not opt you out of transactional or service-related communications.
If you are located in the EEA or the UK, you have the following additional rights under the General Data Protection Regulation or UK GDPR:
Right to Restriction of Processing. You may request that we restrict processing in certain circumstances, such as while we verify the accuracy of data you have contested.
Right to Data Portability. You may receive personal data you provided to us in a structured, commonly used, machine-readable format, and transmit that data to another controller where technically feasible.
Right to Object. You may object to processing based on legitimate interests or carried out for direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for legal claims.
Right Not to Be Subject to Automated Decision-Making. You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects, unless necessary for a contract, authorized by law, or based on your explicit consent.
Right to Lodge a Complaint. You may lodge a complaint with a supervisory authority in your country of residence.
If you are a California resident, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act:
Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collection, and the categories of third parties to whom we disclose it. The categories we collect are set out in Section 2.5.
Right to Delete. You may request deletion of personal information we collected from you, subject to exceptions.
Right to Correct. You may request correction of inaccurate personal information.
Right to Opt Out of Sale or Sharing. We do not sell personal information for monetary consideration. Our use of certain advertising cookies and pixels may constitute sharing for cross-context behavioral advertising. You may opt out by adjusting your cookie preferences, by enabling a Global Privacy Control signal in your browser, or by contacting us.
Right to Limit Use of Sensitive Personal Information. We do not collect sensitive personal information as defined by the CPRA. See Section 2.4.
Right to Non-Discrimination. We will not discriminate against you for exercising your rights. We will not deny you goods or services, charge different prices, or provide a different level of quality because you exercised a privacy right.
Residents of states with comprehensive consumer privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, and others as such laws take effect, have rights that generally include the right to confirm whether we process their personal data, to access it, to correct it, to delete it, to obtain a portable copy, and to opt out of targeted advertising, sale, and certain profiling.
Where required by applicable state law, you also have the right to appeal a decision we make regarding a privacy request. To appeal, reply to our decision or contact us using the details in Section 18 with the subject line "Privacy Appeal." We will respond within the period required by applicable law and, if we deny the appeal, will provide information about how to contact your state attorney general.
To exercise any of the rights described in this Section, contact us using the details in Section 18 with the subject line "Privacy Rights Request." Please include your full name, the email address associated with your account, and a description of the right you wish to exercise. California residents should use the subject line "California Privacy Request."
We will respond within the timeframe required by applicable law, generally 45 days, with extensions where permitted.
We are required to verify your identity before acting on a request. To verify your identity, we may:
Ask you to respond from the email address associated with your account
Send a verification code to the email address or mobile number we have on file
Ask you to confirm information about a recent transaction or account activity
We will not act on a request we cannot reasonably verify. Information collected for verification is used only for that purpose.
You may designate an authorized agent to submit a request on your behalf. Where an agent submits a request, we require written permission signed by you authorizing the agent to act, or proof that the agent holds a valid power of attorney. We may also require you to verify your own identity directly with us.
Section 12 — Children's Privacy
Our Services are not directed to, and are not intended for use by, individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately using the details in Section 18. If we learn that we have collected personal information from a minor, we will take prompt steps to delete it.
In jurisdictions where the age of digital consent differs, we apply the stricter applicable standard.
Section 13 — Third-Party Links, Tools, and Services
Our Services may contain links to third-party websites, platforms, or services not owned or controlled by the Company. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party site or service. This Policy does not apply to any third-party site or service you access through a link from our Services. We encourage you to review the privacy policies of any third-party sites you visit.
Section 14 — Email Communications and Marketing Opt-Out
By providing your email address, you agree to receive transactional communications related to your account, purchases, and Services. If you have opted in to marketing communications, you will also receive promotional emails about our products, programs, events, and content.
You may opt out of marketing emails at any time by clicking the unsubscribe link at the bottom of any marketing email, or by contacting us using the details in Section 18 with the subject line "Unsubscribe."
Please allow up to ten business days for your opt-out request to take effect. Even after opting out of marketing, you may continue to receive transactional and service-related emails, such as purchase confirmations, access credentials, scheduling notices, and policy updates, that are necessary for administration of your account. These are not marketing communications and cannot be opted out of while your account remains active.
We comply with the CAN-SPAM Act and other applicable anti-spam laws. Every marketing email we send includes our physical mailing address and a clear, functional opt-out mechanism.
Section 15 — Do Not Track and Global Privacy Control
Do Not Track. Some browsers transmit Do Not Track signals. There is currently no universally accepted standard for how websites should respond, and our Services do not alter data collection practices in response to Do Not Track signals. We will continue to monitor developments in this area.
Global Privacy Control. Where required by applicable law, including in California, we honor Global Privacy Control signals transmitted by your browser or browser extension. Where we detect a valid Global Privacy Control signal, we treat it as a request to opt out of the sale and sharing of personal information for that browser and device. Because this signal is browser-specific and device-specific, you will need to enable it on each browser and device you use.
Section 16 — Recorded Session and Community Participations
Group coaching calls, live trainings, challenges, community sessions, and other live programming may be recorded. Where a session is recorded, participants are informed and participation constitutes consent to being recorded.
Recordings may include your name, voice, image, and any information you choose to share during the session. We use recordings for program delivery, replay access, archival purposes, and internal quality review.
Where you provide a written or recorded testimonial, or where you consent in writing, we may use excerpts in marketing materials. We will not use a recording of a private one-on-one coaching session for marketing purposes without your separate written consent.
Information you share in a community or group setting may be seen by other participants. We ask all participants to keep that information confidential, but we cannot control the conduct of other participants and are not responsible for their use of information you choose to share.
Section 17 — Change To This Privacy Policy
We reserve the right to update or modify this Policy at any time in our sole discretion. The "Last Modified" date at the top reflects the date of the most recent revision. We will notify you of material changes by posting a prominent notice within the Services, by sending an email to the address associated with your account, or by other means required by applicable law. Your continued use of the Services after changes are posted constitutes acceptance of the revised Policy.
If you choose to use our Services, your use and any dispute over privacy is subject to this Policy and our Terms of Service, including the limitations on damages, the resolution of disputes, and the application of New Jersey law set out there.
Section 18 — Contact Information
Questions, notices, or concerns regarding this Privacy Policy or our data practices, please contact us:
Brookfield Media LLC™
504 Centennial Blvd, Suite 14 Voorhees, NJ 08043
Email: [email protected]
Website: www.ralphervin.com