Brookwood Financial Partners, LLC
Investor Privacy Policy 2025
We appreciate the importance of maintaining the confidentiality of your personal information. This notice describes the types of personal information we collect about our investors and explains what we do with this information and the ways that we protect your privacy. This notice also provides disclosures pursuant to, where applicable, the Gramm-Leach Bliley Act (the “GLBA”), the California Consumer Protection Act (the “CCPA”), the General Data Protection Regulation 2016/679 (the “EU GDPR”), the retained EU law version of the GDPR (the “UK GDPR”) (together the “GDPR”) and other United Kingdom (the “UK”) and EU privacy laws (together, the “Privacy Laws”). In this notice, the terms “we,” “us,” and “our” refer to Brookwood Financial Partners, LLC (the data controller under applicable Privacy Laws), and its affiliates, including Brookwood Securities Partners, LLC, and their managers, partners, principals, registered representatives and agents, whether such individuals are engaged directly by us as employees or as independent contractors, to the extent relevant to the processing of your personal information (collectively, “BFP” and individually, a “BFP Party”).
We want you to know that: (i) we do not sell to anyone the personal information that you have entrusted to us; and (ii) you do not need to contact us to benefit from our privacy protections.
I.Types of Personal Information We Collect
In the conduct of our business, we collect and maintain various types of personal information, including nonpublic personal information, about our investors and related representative and business contacts, including: personal identification information (e.g., name, address, telephone/fax numbers, electronic addresses, date of birth, social security number and tax identification number) and personal financial information (e.g., bank account information, income and net worth information, and investment experience and risk tolerance). Such information is collected from subscription documents and other forms which clients may provide to us. The source of this personal information is you or your representative or the organization for whom you work (as applicable).
II. How We Use Your Personal Information
We collect and use the categories of personal information listed in Section I only to fulfill our contractual obligations, fulfill our statutory obligations, for our legitimate business purposes set out in more detail below (where our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms), and for other purposes as permitted by (or, for UK/EU residents, for which we have a lawful basis under) the Privacy Laws and that are in compliance with applicable laws and regulations. The following summarizes the principal ways in which we use your personal information:
To help us comply with applicable laws and regulations (including rules of the Securities and Exchange Commission and the Financial Industry Regulatory Authority and Treasury Regulations under the Bank Secrecy Act of 1970, as amended by the USA PATRIOT Act, intended to help the government fight the funding of terrorism and money laundering activities).
To help us inform you of investment opportunities. For example, we use information from your prior investments to assist us in determining your qualifications for subsequent offerings.
To perform our contractual obligations to you and/or take pre-contractual obligations in relation to diligence or other checks prior to the investment activity.
To fulfill our legitimate interests with respect to our business activities and compliance requirements.
We also collect personal information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of BFP and for other purposes for which BFP is permitted to do so under the Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Client” requirements, as well as to verify the status and / or eligibility of BFP clients for funds or services offered by BFP and for compliance with tax reporting requirements; (ii) for purposes of reporting to, or communicating with, BFP clients concerning their investment in BFP funds or appointment or engagement of BFP consistent with our obligations to such BFP clients; (iii) in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Client” requirements of counter-parties; (iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving BFP, BFP funds, or BFP clients; and (v) for other legitimate business interests. If you have provided special categories of personal information (defined as special categories of personal data under the GDPR and UK GDPR) to us to enable us to respond to certain requests by you, such as access requests or scheduling of meetings or similar requirements, we do so with your consent and/or on the grounds of legal necessity. Further, for California residents, we do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA.
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case.
In addition, we may, with your consent or where we have other lawful processing grounds like legitimate interests, process your personal information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about financial products or services, news updates, research or market commentary, conferences, or events offered by or in conjunction with us. You have the right to unsubscribe from these communications by emailing Privacy@brookwoodfinancial.com or by following the instructions in any such communication, e.g., by clicking on the link to unsubscribe. The withdrawal of your consent will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
III. Data Retention
The period for which we retain personal information varies depending on the type of personal information, our reasons for collecting it, and our relationship with you. We will retain your personal information for a period of at least five to seven years in most instances from the date on which the relevant business relationship, for which purpose such personal information was provided, has ended (or, if later, the date on which the last transaction was completed, the last entry to the record was made, or the last tax return for an investment was filed). Thereafter, we will delete (or otherwise erase, de-identify, anonymize, or equivalent) any such personal information except as required or permitted by applicable law or regulation.
IV. Sale & Sharing
Outside of BFP, we do not sell or share for targeted cross-context behavioral advertising, as those terms are defined under applicable law, and we have not sold or shared in the past twelve months, the categories of personal information listed in Section I that we collect from our investors. Accordingly, we do not recognize opt-out preference signals with respect to investor 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
While we never sell your personal information, we disclose and we have disclosed in the past twelve months the categories of personal information listed in Section I, above, to our service providers, BFP Parties, and/or third parties for the purposes listed in Section II and in this Section V. The nature of our business requires us to work very closely with each BFP Party. We may make such disclosures (i) for servicing and processing transactions (e.g., handling escrow accounts), (ii) for legal purposes, such as to comply with the requests or instructions of our regulators, to protect against fraud, for risk control, or to respond to subpoenas, court orders and legal reporting requirements, (iii) to provide to state and federal regulators or service providers such as lenders to satisfy applicable laws and regulations and (iv) to companies that provide services to us, such as our attorneys, accountants, lenders, and auditors for assistance in performing our business operations. We require BFP and our service providers and third parties to protect your personal information. Within BFP, we may share your personal information among the various BFP-affiliated entities, which includes our affiliated companies located in the United Kingdom (“UK Affiliates”). Such sharing will be limited to the everyday business purposes described in Section II of this notice, including compliance, servicing of transactions, investment management, reporting, and other legitimate business purposes.
Any transfers of personal information to UK Affiliates will be conducted in accordance with applicable Privacy Laws, including where applicable the UK GDPR and Data Protection Act 2018. We will ensure that UK Affiliates receiving such information are subject to the same standards of confidentiality, data protection, and security as described in this notice. Where required, appropriate safeguards (such as standard contractual clauses or equivalent mechanisms recognized under UK law) will be implemented to ensure your personal information is adequately protected.
There may be instances when we disclose your personal information to other third parties:
To comply with the law or respond to compulsory legal process (such as a search warrant or court order) or request for information from a regulator or otherwise for legal purposes or disputes or investigations.
To verify or enforce compliance with the policies governing the services we provide to you.
To protect the rights, property, or safety of BFP or BFP funds or any of our respective business partners, or clients or otherwise in the legitimate business interests of BFP and BFP funds and in accordance with applicable laws.
In connection with the sale, assignment, merger, or other transfer of all or a portion BFP’s business to that third party.
VI. Protecting Personal Information from Unauthorized Access
Safeguarding the confidentiality, security, and integrity of your personal information is very important to us. We have established systems, policies, and procedures designed to protect your personal information physically, electronically, and procedurally from being accessed by unauthorized persons. Employees are trained in our privacy policies and procedures, including the proper handling of personal information, including client information. Employee access to personal information is limited to those with a legitimate business reason for such access. However, while the security of your personal information is of the utmost importance to us, please be aware that we cannot fully guarantee the security of any information you choose to disclose online.
VII. Additional Disclosures For EEA/UK Residents
If you are a resident of the UK or the European Economic Area (“EEA”), we may transfer your personal information to BFP in the U.S., which has a lower standard of data privacy laws compared to the GDPR, for the purposes described above.
Where your personal information is processed by service providers or third parties outside the UK and/or EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of specific contracts approved for use in the UK or EU as determined by the European Commission or the Information Commissioner’s Officer (as applicable) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission or the Information Commissioner’s Office).
Residents of the UK and EEA have certain rights relating to the personal information we hold in accordance with and subject to the European Privacy Laws to: (i) check whether we hold personal information about you and to access such data (in accordance with our policy); (ii) request the correction of personal information about you that is inaccurate; (iii) have a copy of the personal information we hold about you provided to you or another controller where technically feasible; (iv) object to the processing of your personal information; (v) request the erasure of personal information; (vi) request the restriction of personal information processing activities; and (vii) make a complaint to a supervisory authority in your country of residence. All of these rights are subject to applicable exemptions and restrictions under applicable European Privacy Laws. We will endeavor to respond within a month of the request and will confirm if this is not feasible, for reasons relating to the complexity of a request, within the first month and extend the timeline by a further two months if necessary.
VIII. GLBA Disclosures
This section applies to and provides disclosures for U.S. residents who are our consumers or customers, as those terms are defined under the GLBA. We collect the categories of nonpublic personal information (“NPI”) listed in Section I of this notice, and we disclose the same categories of NPI to our affiliates and to nonaffiliates as described in Section V of this notice. We disclose the same categories of NPI to nonaffiliates who act as our service providers and are contractually restricted from using your NPI other than to carry out the purposes for which we disclose it to them, as described in Section V of this notice. For individuals who are no longer our customers, we may still disclose the categories of NPI listed in Section I of this notice as described in Section V of this notice, as necessary for our business purposes.
We generally do not disclose NPI to nonaffiliates for purposes other than to perform services for us, to perform functions on our behalf, to process transactions at your request and maintain accounts, with your consent or at your direction, or as permitted by law, as articulated in Section V of this notice. To opt out of disclosures of your NPI to nonaffiliates, to the extent such disclosures are not exempt from the GLBA’s opt-out rights requirement, you can contact us at by phone at 800-277-6300 or by email at Privacy@brookwoodfinancial.com.
For information about how we protect the personal information we collect, including NPI, please see Section VI, above.
IX. Additional Disclosures For California Residents
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.
Right to Appeal. You have the right to appeal for further review any decision we make regarding your information, including any of the privacy rights requests, above.
X. Submitting Data Subject Rights Requests
To submit a data subject rights request as outlined above, please contact us by email at Privacy@brookwoodfinancial.com or by phone at 800-277-6300. 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.
XI. 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.
XII. Updates & Contact Us
We may update this notice periodically. The latest version will be posted on our investor portal. If you have any questions about this notice or if you would like to update your personal information (for example, if your email address or other contact information changes), please contact us at InvestorRelations@brookwoodfinancial.com.
Last Updated: October 5, 2024