Privacy Policy

1. Who We Are

This Privacy Policy applies to Richie Broom LLC, a Florida limited liability company (Document No. L23000368718) headquartered at 11850 Biscayne Blvd, PMB 381, Miami, FL 33181, and its family of brands and platforms:

• Richie Deluna™ — richiedeluna.com
• THIS BRO™ — thisbro.co
• Brohoes™ — brohoes.com
• Trace Your Tee™ — traceyourtee.com
• Richie Broom LLC (holding company) — richiebroom.com

References to “we,” “us,” or “our” in this policy refer to Richie Broom LLC and all brands listed above. This policy governs the collection, use, and sharing of personal information across all of our websites and digital properties.

2. Information We Collect

We collect information you provide directly to us, information collected automatically when you use our services, and information from third-party sources.

Information you provide directly:

• Name, email address, and contact details when you create an account, place an order, or contact us
• Billing and shipping address, payment information (processed by our payment providers — we do not store full card numbers)
• Communications you send us, including support requests and press inquiries
• Newsletter subscriptions and marketing preferences
• Information submitted via our contact forms

Information collected automatically:

• Browser type, operating system, IP address, and device identifiers
• Pages visited, time on site, referring URLs, and clickstream data
• Cookies and similar tracking technologies (see Section 6)
• Digital product passport scan data when a Trace Your Tee™ QR code is scanned — including approximate location (at the city level) and scan timestamp

Information from third parties:

• Social media platforms if you interact with our accounts or connect a social account
• Payment processors (e.g., Stripe, Shopify Payments) who provide transaction confirmation data
• Analytics providers who aggregate usage data across our properties

3. How We Use Your Information

We use the information we collect to:

• Process and fulfill orders, including shipping confirmation and order history
• Respond to inquiries, support requests, and press or partnership communications
• Send transactional emails (order confirmations, shipping updates)
• Send marketing communications if you have opted in — you can opt out at any time
• Operate the Trace Your Tee™ digital product passport platform, including maintaining product provenance records and authentication status
• Improve our websites, products, and services through analytics and user research
• Prevent fraud, enforce our Terms of Service, and comply with legal obligations
• Comply with applicable law, including EU ESPR Digital Product Passport requirements

We do not sell your personal information to third parties. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

4. Trace Your Tee™ Digital Product Passports

Trace Your Tee™ is our digital product passport and traceability platform. When you scan a QR code on a Richie Broom LLC garment, the following data is collected and associated with that product record:

• Scan timestamp and approximate geographic location (city-level, not precise coordinates)
• Device type and browser used to access the passport
• Number of times the code has been scanned and general scan history

This data is used to maintain the garment’s provenance record, detect potential counterfeit activity, and improve the passport scan experience. We do not link scan data to your personal identity unless you have created an account and explicitly connected a product to it.

Product passport data — including material composition, supply chain origin, and sustainability metrics — is product-level information, not personal data. It is associated with the garment, not with individual users.

5. How We Share Your Information

We share personal information only in the following circumstances:

• Service providers: We share data with vendors who help us operate our business, including payment processors, shipping carriers, email service providers, and analytics platforms. These providers are contractually required to protect your data and use it only for the services they provide to us.
• Legal requirements: We may disclose information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect rights, safety, or property.
• Business transfers: If Richie Broom LLC or any of its brands is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.
• With your consent: We will share your information with third parties when you have given us explicit consent to do so.

We do not share your personal information with advertisers or data brokers. Our brands and platforms are ad-free and do not participate in behavioral advertising networks.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our websites and understand how they are used. The types of cookies we use:

• Strictly necessary cookies: Required for the website to function. These cannot be disabled. They include session cookies for shopping carts, login state, and security tokens.
• Analytics cookies: Help us understand how visitors use our sites (pages visited, time on site, error rates). We use aggregated, anonymized analytics data.
• Preference cookies: Remember choices you’ve made, such as language preferences or newsletter opt-in status.

We do not use advertising cookies, retargeting cookies, or cross-site tracking technologies. You can control cookies through your browser settings. Disabling cookies may affect the functionality of our checkout and account features.

7. Your Rights and Choices

Depending on where you are located, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request that we correct inaccurate or incomplete information
• Deletion: Request that we delete your personal information, subject to certain legal exceptions
• Portability: Request your data in a structured, machine-readable format
• Objection: Object to processing of your personal information for direct marketing purposes
• Opt-out of marketing: Unsubscribe from marketing emails at any time using the link in any email we send, or by contacting us directly

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected and sold, and the right to opt out of the sale of personal information. We do not sell personal information.

EU and UK residents have rights under the General Data Protection Regulation (GDPR) and UK GDPR, including the right to lodge a complaint with a supervisory authority. Our legal bases for processing include contract performance, legitimate interests, consent, and legal obligation.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, and reporting requirements.

• Order and transaction data: 7 years (required for tax and financial record-keeping)
• Account information: Until account deletion is requested, plus 90 days
• Marketing email opt-in records: Until opt-out, plus 3 years
• Product passport scan logs: Associated with the product record for the lifetime of the passport
• Support correspondence: 3 years from last contact
• Analytics data: 26 months in aggregated, anonymized form

When personal information is no longer required, we delete or anonymize it securely.

9. Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, or misuse. These include:

• 256-bit AES encryption for stored product passport data
• TLS encryption for all data transmitted between your browser and our servers
• Access controls limiting who within our organization can access personal data
• Regular security reviews of our systems and third-party service providers

No transmission over the internet is completely secure. While we take reasonable steps to protect your information, we cannot guarantee its absolute security. If you believe your information has been compromised, please contact us immediately at [email protected].

10. Children’s Privacy

Our websites and services are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verified parental consent, we will delete that information promptly.

If you believe we may have collected information from a child under 13, please contact us at [email protected].

11. Third-Party Links

Our websites may contain links to third-party websites, including the independent brand sites of our portfolio companies (richiedeluna.com, thisbro.co, brohoes.com, traceyourtee.com). Each of these sites operates under its own privacy policy. This Privacy Policy applies only to richiebroom.com and the data practices of Richie Broom LLC as the holding company.

Links to social media platforms, payment processors, and other external services are subject to those parties’ own privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

12. International Transfers

Richie Broom LLC is based in the United States. If you are accessing our services from the EU, UK, or other regions with laws governing data collection and use, your information may be transferred to and processed in the United States.

For transfers from the EU or UK, we rely on appropriate safeguards including Standard Contractual Clauses approved by the European Commission. By using our services, you acknowledge that your information may be transferred to our facilities and those of our service providers in the United States and other countries.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the “Last Updated” date at the top of this policy
• Notify subscribers via email if the changes are significant
• Post a notice on our websites for 30 days following a material update

Your continued use of our services after the effective date of any changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us: