Brookwood Financial Partners, LLC

Employee/Applicant Privacy Notice

We appreciate the importance of maintaining the confidentiality of your personal information. This notice describes the types of personal information Brookwood Financial Partners, LLC and its affiliates, including Brookwood Securities Partners, LLC and Brookwood Management Partners, LLC (“BFP,” “we,” “us,” “our”) collects from or about California residents who are BFP job applicants (“Applicants”) or employees, independent contractors, or who otherwise interact with us in an employment-related capacity (collectively, “Employees”). This notice also provides details about our purposes for collecting and using such personal information, information about Applicants’ and Employees’ data subject rights, and other disclosures required under the California Consumer Privacy Act, as amended, including its implementing regulations (collectively, the “CCPA”).

This notice does not apply to Applicants or Employees who are not California residents.

I. Types of Personal Information We Collect

We collect, and we have collected in the past twelve months, the below categories of personal information about Applicants and Employees:

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, and other similar contact information and identifiers.

Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.

Internet or Other Electronic Network Activity Information. This category includes, without limitation:

  • all activity on our information systems, such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords

  • all activity on communications systems, including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee’s use of company-issued devices

  • information we may collect passively from Applicants when they use our “Careers” page, such as IP address and browsing information

Geolocation Data. This category includes, without limitation, GPS location data from company-owned or issued mobile devices, applications, or vehicles.

Audio, Electronic, Visual, or Similar Information. This category includes, for example, call and video recordings, and similar information.

Biometric Information. This category includes the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes.

Professional and Employment-Related Information. This category includes, without limitation:

  • data submitted with employment applications, including salary history, employment history, employment recommendations, etc.

  • background check and criminal history

  • work authorization

  • fitness for duty data and reports

  • performance and disciplinary records

  • salary and bonus data

  • benefit plan enrollment, participation, and claims information

  • leave of absence information, including religious and family obligations, and physical and mental health data, concerning employees and their family members

Education Information. This category includes, without limitation, education history.

Sensitive Personal Information. This category includes sensitive information such as:

  • social security, driver’s license, state identification card, or passport number

  • financial account information that allows access to an account, including log-in credentials, financial account numbers, passwords, etc.

  • precise geolocation

  • racial or ethnic origin, religious or philosophical beliefs, or union membership

  • content of mail, email, and text messages (unless we are the intended recipient of the communication)

  • genetic data

  • biometric information for the purpose of uniquely identifying a consumer

  • health information

  • information concerning sex life or sexual orientation

We collect these categories of personal information from you, from our vendors and third parties when they provide information to us, and from social media and publicly-available sources.

Please note that the information we collect about you depends on the context in which you interact with us. For example, if you are an Applicant, we may collect less personal information from or about you (such as your name, contact information, education information, professional and employment related information, etc.) than we will collect if you are or become an Employee.

II. How We Use Your Personal Information

We collect, process, and disclose personal information, including sensitive personal information, about Applicants and Employees for the following purposes:

  • Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, onboarding, and related recruiting efforts.

  • Processing payroll, other forms of compensation, and employee benefit plan and program design and administration, including enrollment and claims handling, and leave of absence administration.

  • Maintaining physician records and occupational health programs.

  • Maintaining personnel records and record retention requirements.

  • Communicating with employees and/or employees’ emergency contacts and plan beneficiaries.

  • Complying with applicable state and federal health, labor, employment, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations.

  • Preventing unauthorized access to, use, or disclosure/removal of BFP property, including our information systems, electronic devices, network, and data.

  • Ensuring and enhancing employee productivity and adherence to BFP policies.

  • Providing training and development opportunities.

  • Investigating complaints, grievances, and suspected violations of BFP policy.

  • Facilitating the efficient and secure use of BFP information systems.

  • Ensuring compliance with BFP information systems policies and procedures.

  • Improving safety of employees, customers, and the public with regard to use of BFP property and equipment.

  • Improving efficiency, logistics, and supply chain management.

  • Improving accuracy of time management systems and attendance, including vacation, sick leave, and other leave of absence monitoring.

  • Evaluating an individual’s appropriateness for a particular position at BFP, or promotion to a new position.

  • Managing customer engagement and other legitimate business purposes.

  • Responding to and managing legal claims against BFP and/or its personnel, including civil discovery in litigation.

  • Facilitating other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, merger and acquisition activities, and maintenance of licenses, permits and authorization applicable to BFP operations.

Please note that we do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA

III. Data Retention

We retain your personal information for as long as is necessary to process your application for employment, process your payroll, administer your benefits, etc. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

IV. Sale & Sharing

We do not sell or share, as those terms are defined under applicable law, and we have not sold or shared in the past twelve months, the above categories of personal information we collect from Applicants and Employees. Accordingly, we do not recognize opt-out preference signals with respect to Applicant and Employee information. Further, we do not have actual knowledge that we sell or share personal information of individuals under 16 years of age.

V. How We Disclose Personal Information

To carry out the purposes outlined above, we disclose and we have disclosed in the past twelve months the categories of personal information listed in Section I, above, to our affiliates and to service providers and third parties, such as background check vendors, third-party staffing vendors, information technology vendors, outside legal counsel, and state or federal governmental agencies.

VI. California Resident Data Subject Rights Requests

Residents of California have certain data subject rights, as outlined below:

  • Right To Know. As a California resident, you have the right to request additional information, beyond that disclosed above, regarding the following, to the extent applicable:

    • the categories of personal information we have collected about you

    • the categories of sources from which that personal information was collected

    • the categories of personal information sold or disclosed for a business purpose

    • the business or commercial purposes for which that information was collected, sold, or shared

    • the categories of third parties to whom we disclose personal information

    • the specific pieces of personal information collected about you

Upon receipt of a verifiable request to know (see below), and as required by applicable law, we will provide a response to such request.

  • Right To Request Deletion. You have the right to request that we delete the personal information we collected from you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and will direct any service providers and contractors to whom we disclosed your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, without limitation, when the information at issue is maintained: (a) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information, or (b) to comply with a legal obligation.

Upon receipt of a verifiable request to delete (see below), and as required by applicable law, we will provide a response to such requests.

  • Right to Request Correction. You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable request to correct (see below), and as required by applicable law, we will provide a response to such requests.

  • Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising your data subject rights. We will not discriminate or retaliate against you for exercising any of the rights described above.

 

VII. Submitting Data Subject Rights Requests

To submit a data subject rights request as outlined above, please contact us at 800-277-6300 or https://brookwoodfinancial.com/contact-us/. You may also authorize an agent to make a data subject rights request on your behalf, and the authorized agent may do so via the above-listed submission methods.

VIII. Verification of Data Subject Rights Requests

We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject rights request. In particular, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity to us or confirm with us that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

IX. Spouses, Dependents, and Associates

If you have knowledge that we have collected personal information related to your spouse, dependent, or associate, please share a copy of this notice with all such individuals.

X. Updates & Contact Us

We may update this notice periodically, and we will post the updated notice on this page. Please direct questions about this notice to privacy@brookwoodfinancial.com.

Last Updated: September 24, 2025