Privacy Policy

June 1, 2019

Brookes Development LLC (Brookes Development) values its users’ privacy. This Privacy Policy (“Policy”) will
help you understand how we collect and use personal information from those who visit our website or make use
of our online facilities and services, and what we will and will not do with the information we collect. Our
Policy has been designed and created to ensure those affiliated with Brookes Development LLC of our
commitment and realization of our obligation not only to meet, but to exceed, most existing privacy standards.
We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up
to date with the latest changes, we advise you to frequently visit this page. If at any point in time Brookes
Development LLC decides to make use of any personally identifiable information on file, in a manner vastly
different from that which was stated when this information was initially collected, the user or users shall be
promptly notified by email. Users at that time shall have the option as to whether to permit the use of their
information in this separate manner.

This Policy applies to Brookes Development LLC and any subsidiary company listed below, and it governs any
and all data collection and usage by us.

Brookes Group LLC

Through the use of and any subsidiary
website listed below, you are therefore consenting to the data collection procedures expressed in this Policy.

Please note that this Policy does not govern the collection and use of information by companies that Brookes
Development LLC does not control, nor by individuals not employed or managed by us. If you visit a website
that we mention or link to, be sure to review its privacy policy before providing the site with information. It is
highly recommended and suggested that you review the privacy policies and statements of any website you
choose to use or frequent to better understand the way in which websites garner, make use of and share the
information collected.
Specifically, this Policy will inform you of the following:

  1. What personally identifiable information is collected from you through our website;
  2. Why we collect personally identifiable information and the legal basis for such collection;
  3. How we use the collected information and with whom it may be shared;
  4. What choices are available to you regarding the use of your data; and
  5. The security procedures in place to protect the misuse of your information.

Information We Collect
It is always up to you whether to disclose personally identifiable information to us, although if you elect not to
do so, we reserve the right not to register you as a user or provide you with any products or services. This
website collects various types of information, such as:

Information automatically collected when visiting our website, which may include cookies, third party
tracking technologies and server logs.
In addition, Brookes Development LLC may have the occasion to collect non-personal anonymous demographic
information, such as age, gender, household income, political affiliation, race and religion, as well as the type of
browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining
superior quality service.
Brookes Development LLCmay also deem it necessary, from time to time, to follow websites that our users may
frequent to gleam what types of services and products may be the most popular to customers or the general

Why We Collect Information and For How Long
We are collecting your data for several reasons:

  • To better understand your needs and provide you with the services you have requested;
  • To fulfill our legitimate interest in improving our services and products;
  • To send you promotional emails containing information we think you may like when we have your
    consent to do so;
  • To contact you to fill out surveys or participate in other types of market research, when we have your
    consent to do so;
  • To customize our website according to your online behavior and personal preferences.

The data we collect from you will be stored for no longer than necessary. The length of time we retain said
information will be determined based upon the following criteria: the length of time your personal information
remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our
duties and obligations; any limitation periods within which claims might be made; any retention periods
prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we
have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in
this Policy.

Use of Information Collected
Brookes Development LLC does not now, nor will it in the future, sell, rent or lease any of its customer lists
and/or names to any third parties.

Brookes Development LLC may collect and may make use of personal information to assist in the operation of
our website and to ensure delivery of the services you need and request. At times, we may find it necessary to
use personally identifiable information as a means to keep you informed of other possible products and/or
services that may be available to you from and its subsidiaries.

Brookes Development LLC and its subsidiaries may also be in contact with you with regards to completing
surveys and/or research questionnaires related to your opinion of current or potential future services that may be
Brookes Development LLC uses various third-party social media features including but not limited to LinkedIn,
Instagram, Facebook and other interactive programs. These may collect your IP address and require cookies to
work properly. These services are governed by the privacy policies of the providers and are not within Brookes
Development LLC’s control.

Disclosure of Information
Brookes Development LLC may not use or disclose the information provided by you except under the following

  • as necessary to provide services or products you have ordered;
  • in other ways described in this Policy or to which you have otherwise consented;
  • in the aggregate with other information in such a way so that your identity cannot reasonably be
  • as required by law, or in response to a subpoena or search warrant;
  • to outside auditors who have agreed to keep the information confidential;
  • as necessary to enforce the Terms of Service;
  • as necessary to maintain, safeguard and preserve all the rights and property of Brookes Development

Non-Marketing Purposes
Brookes Development LLC greatly respects your privacy. We do maintain and reserve the right to contact you if
needed for non-marketing purposes (such as bug alerts, security breaches, account issues, and/or changes in
Brookes Development LLC products and services). In certain circumstances, we may use our website,
newspapers, or other public means to post a notice.

Children under the age of 13
Brookes Development LLC’s website is not directed to, and does not knowingly collect personal identifiable
information from, children under the age of thirteen (13). If it is determined that such information has been
inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps
to ensure that such information is deleted from our system’s database, or in the alternative, that verifiable
parental consent is obtained for the use and storage of such information. Anyone under the age of thirteen (13)
must seek and obtain parent or guardian permission to use this website.

Unsubscribe or Opt-Out
All users and visitors to our website have the option to discontinue receiving communications from us by way of
email or newsletters. To discontinue or unsubscribe from our website please send an email that you wish to
unsubscribe to If you wish to unsubscribe or opt-out from any third-party
websites, you must go to that specific website to unsubscribe or opt-out. Brookes Development LLC will
continue to adhere to this Policy with respect to any personal information previously collected.

Links to Other Websites
Our website does contain links to affiliate and other websites. Brookes Development LLC does not claim nor
accept responsibility for any privacy policies, practices and/or procedures of other such websites. Therefore, we
encourage all users and visitors to be aware when they leave our website and to read the privacy statements of
every website that collects personally identifiable information. This Privacy Policy Agreement applies only and
solely to the information collected by our website.

Notice to European Union Users
Brookes Development LLC’s operations are located primarily in the United States. If you provide information to
us, the information will be transferred out of the European Union (EU) and sent to the United States. (The
adequacy decision on the EU-US Privacy became operational on August 1, 2016. This framework protects the
fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial
purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.)
By providing personal information to us, you are consenting to its storage and use as described in this Policy.
Brookes Development LLC takes precautions to protect your information. When you submit sensitive
information via the website, your information is protected both online and offline. Wherever we collect sensitive
information (e.g. credit card information), that information is encrypted and transmitted to us in a secure way.
You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the
address of the webpage.
While we use encryption to protect sensitive information transmitted online, we also protect your information
offline. Only employees who need the information to perform a specific job (for example, billing or customer
service) are granted access to personally identifiable information. The computers and servers in which we store
personally identifiable information are kept in a secure environment. This is all done to prevent any loss, misuse,
unauthorized access, disclosure or modification of the user’s personal information under our control.
The company also uses Secure Socket Layer (SSL) for authentication and private communications to build users’
trust and confidence in the internet and website use by providing simple and secure access and communication
of credit card and personal information. In addition, Brookes Development LLC is a licensee of TRUSTe. The
website is also secured by VeriSign.

Acceptance of Terms
By using this website, you are hereby accepting the terms and conditions stipulated within the Privacy Policy
Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use
of our sites. In addition, your continued use of our website following the posting of any updates or changes to
our terms and conditions shall mean that you agree and acceptance of such changes.

How to Contact Us
If you have any questions or concerns regarding the Privacy Policy Agreement related to our website, please feel
free to contact us at the following email, telephone number or mailing address.
Telephone Number: 212-552-1495
Mailing Address:
Brookes Development LLC
PO Box 12207
Baltimore, Maryland

GDPR Disclosure:
If you answered “yes” to the question Does your website comply with the General Data Protection Regulation (“GDPR”)? then the
Privacy Policy above includes language that is meant to account for such compliance. Nevertheless, in order to be fully compliant with
GDPR regulations your company must fulfill other requirements such as: (i) doing an assessment of data processing activities to
improve security; (ii) have a data processing agreement with any third party vendors; (iii) appoint a data protection officer for the
company to monitor GDPR compliance; (iv) designate a representative based in the EU under certain circumstances; and (v) have a
protocol in place to handle a potential data breach. For more details on how to make sure your company is fully compliant with GDPR,
please visit the official website at FormSwift and its subsidiaries are in no way responsible for determining whether or
not your company is in fact compliant with GDPR and takes no responsibility for the use you make of this Privacy Policy or for any
potential liability your company may face in relation to any GDPR compliance issues.

COPPA Compliance Disclosure:
This Privacy Policy presumes that your website is not directed at children under the age of 13 and does not knowingly collect personal
identifiable information from them or allow others to do the same through your site. If this is not true for your website or online service
and you do collect such information (or allow others to do so), please be aware that you must be compliant with all COPPA regulations
and guidelines in order to avoid violations which could lead to law enforcement actions, including civil penalties.
In order to be fully compliant with COPPA your website or online service must fulfill other requirements such as: (i) posting a privacy
policy which describes not only your practices, but also the practices of any others collecting personal information on your site or
service — for example, plug-ins or ad networks; (ii) include a prominent link to your privacy policy anywhere you collect personal
information from children; (iii) include a description of parental rights (e.g. that you won’t require a child to disclose more information
than is reasonably necessary, that they can review their child’s personal information, direct you to delete it, and refuse to allow any
further collection or use of the child’s information, and the procedures to exercise their rights); (iv) give parents “direct notice” of your
information practices before collecting information from their children; and (v) obtain the parents’ “verifiable consent” before
collecting, using or disclosing personal information from a child. For more information on the definition of these terms and how to
make sure your website or online service is fully compliant with COPPA please visit FormSwift and its subsidiaries are in no way responsible
for determining whether or not your company is in fact compliant with COPPA and takes no responsibility for the use you make of this
Privacy Policy or for any potential liability your company may face in relation to any COPPA compliance issues.