The Brookwood Privacy Policy
As your financial needs provider, Brookwood is committed to safeguarding the individual privacy rights of all of its customers. Brookwood strongly believes that it has a responsibility to protect from disclosure to any unauthorized parties, your nonpublic and personal information. This policy applies to each and every customer. Therefore, Brookwood has adopted and implemented this privacy policy to protect your account and your personal information. As our customer, we collect and receive nonpublic personal information about you. This includes information such as your name, Social Security Number, birth date, assets, and income.

Information Collection
Brookwood will collect the following kinds of nonpublic personal information about you:

• Information we receive from you on applications or other forms, such as your name, date of birth, contact information, income and obligations;



• Information we receive from you about your transactions with us, our affiliates, or others, such as prior loans, terms, payoffs, and payment history;



• Information we receive from consumer reporting agencies, such as your credit history and credit worthiness; and



• Information we receive as a result of verifying your information with non-affiliated third parties, such as employment history and loan balances.

No Information Sharing Policy
We do not disclose any nonpublic personal information that we collect about our customers or former customers, as described above, to anyone, except as permitted by law.

Brookwood Security Policy
Securing of a customers' nonpublic personal information is very important to Brookwood and our employees must sign a privacy pledge acknowledging that that they are aware of Brookwoods policy regarding the use of and disclosure of customer information. Furthermore, Brookwood has implemented various security measures to protect our customers' personal information from loss, misuse, or alteration. When customers send their personal identifying information to Brookwood via the Brookwood website, Brookwood requires that a secure session be established first, using Secure Socket Layer (SSL) technology supporting up to 128-bit encryption to prevent unauthorized persons from viewing any private information being transmitted during your application process. Information transmitted between the Brookwood server and your computer must be sent only while in a secure mode or Brookwood will have no responsibility for any loss or exposure of personally identifying information to unauthorized third parties during a secure SSL session, data passed between the customer's computer and Brookwood servers are secured through the use of public key cryptography. The customer's computer exchanges key information with Brookwood servers to create a private conversation that only the customer's computer and Brookwood servers may understand. To benefit from SSL protection, customers must use a browser with SSL capabilities. This method of information transfer will apply when the customer is entering in personal information, execution of and submittal of the online promissory note, for validation and verification purposes during your communications through our server and processing systems.

While using the Brookwood website, customers will be notified upon entering and leaving a secured session, unless the setting is turned off on the customers' browser. After leaving a secured session, information transmitted to Brookwood will not be secure. For security purposes, Brookwood uses special software programs to monitor web site traffic and to identify unauthorized attempts to upload or change information or otherwise to cause damage to Brookwood websites. These programs do not collect personally identifying information about customers, but do enable Brookwood to collect information allowing Brookwood to identify website users attempting to tamper with Brookwood websites. Brookwood has policies in place against the misuse, misappropriation, unauthorized access, tampering, damage, destruction, or unlawful utilization of Brookwood websites and computer systems and will seek the maximum enforcement of state, federal, and international criminal and civil laws against any individual engaging in such activity. Please note that when customers send electronic mail messages (e-mail) to Brookwood, the customers' messages will contain the customers' return e-mail address. Thus, Brookwood may utilize customers' e-mail addresses in responding to customer inquiries and the content of customers' e-mail in formulating a response. Brookwood will permanently record and store any substantive e-mail received from its customers. Customer e-mail sent to Brookwood is not necessarily secure against interception. Do not initiate communication with Brookwood by email if your communication will include nonpublic personal information like your Social Security Number, bank account number, or other personally identifying information that you wish to protect. Although Brookwood strives to protect and secure information submitted to it over the internet, your use of this website is strictly at your own risk. Brookwood makes no representations that it can guarantee the security of any information sent by the users of this website during an unsecured session. Brookwood protects the security of its servers but cannot be responsible for any virus, spy ware, ad ware, malicious codes and /or hacker activity that may result in damage to your computer or theft of your identifying information.

Additional Security Feature of Shared Secrets
Shared secrets are a security method for accessing confidential information. A shared secret is something known only to the user and the holder of the confidential information. Shared secrets usually consist of a user ID and password. These shared secrets allow the user to log into the site of the holder of confidential information such as a Credit Card issuer or financial institution. Shared secrets are necessary for a safe and dependable online authentication procedure. In order to minimize potential compromise of your shared secrets, you should create passwords that are a combination of both letters and numbers.

Information Retention Policy
Brookwood will maintain electronic and hardcopy loan application information for funded/closed/withdrawn and declined loans for a period of years in accordance with all mandated federal and State Laws. If you would like to receive copies of any such information, you must notify Brookwood in writing with your request so that the proper authentication and forwarding information can be verified.