Privacy Policy
Brown Management, LLC is committed to protecting your privacy and complying with the California Consumer Privacy Act (CCPA) and all applicable federal and state privacy laws.
1. Information We Collect
Information You Provide Directly
When you contact us, submit an inquiry form, or engage our services, we collect: your full name, email address, phone number, mailing address, and the details of your estate, trust, conservatorship, or fiduciary matter. For professional referral partners, we also collect your firm name, professional license number, and the nature of the referral.
Information Collected Automatically
When you visit our website, we automatically collect certain technical data including your IP address, browser type and version, operating system, referring URLs, pages visited, and time spent on each page. This data is collected through standard web server logs and analytics tools and is used solely for site improvement and security purposes.
Information from Third Parties
In the course of providing fiduciary services, we may receive personal information about beneficiaries, heirs, and interested parties from courts, attorneys, financial institutions, and other fiduciaries. This information is handled under the same privacy standards described in this policy and is subject to applicable court orders and professional confidentiality obligations.
Categories Under CCPA
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, email, phone, IP address | Yes |
| Personal Records | Address, financial account information | Yes |
| Protected Characteristics | Age (for elder law matters) | Limited |
| Commercial Information | Services purchased, transaction history | Yes |
| Internet Activity | Browsing history on our site | Yes |
| Professional Information | License numbers (referral partners) | Yes |
| Sensitive Personal Information | Financial account details, SSN (for court filings) | When required |
2. How We Use Your Information
Brown Management uses personal information for the following business purposes:
- Service Delivery: To provide fiduciary services including estate administration, trust management, conservatorship, and related court-mandated functions.
- Legal Compliance: To fulfill obligations under California Probate Code, court orders, and applicable federal and state regulations governing licensed professional fiduciaries.
- Communication: To respond to inquiries, provide case updates, send required legal notices, and maintain professional correspondence with clients, courts, and co-fiduciaries.
- Security & Fraud Prevention: To protect the integrity of estate assets, detect unauthorized access, and maintain the security of our systems and client data.
- Business Operations: To process payments, maintain records required by the California Professional Fiduciaries Bureau, and improve our services.
- Analytics: To understand how visitors use our website and improve the user experience. Website analytics data is aggregated and does not identify individuals.
We do not use personal information for automated decision-making that produces legal or similarly significant effects without human review and approval.
3. Sharing and Disclosure
Brown Management does not sell personal information to third parties for monetary consideration. We share information only in the following limited circumstances:
- Courts and Legal Authorities: We are required by law to file accountings, inventories, and reports with California Superior Courts. This information becomes part of the public court record as required by the Probate Code.
- Co-Fiduciaries and Professionals: With your consent or as required by the terms of the fiduciary appointment, we share relevant information with co-trustees, attorneys, CPAs, financial advisors, and other professionals serving the estate or trust.
- Financial Institutions: To manage estate or trust assets, we share necessary information with banks, brokerages, and other financial institutions holding assets under our management.
- Service Providers: We engage limited third-party vendors (e.g., cloud storage, accounting software, secure communication platforms) who process data on our behalf under strict confidentiality agreements and data processing terms.
- Legal Obligation: We may disclose information when required by subpoena, court order, regulatory inquiry, or other legal process, or when necessary to protect the rights, property, or safety of Brown Management, our clients, or the public.
4. Your California Privacy Rights (CCPA)
California Consumer Privacy Act — Cal. Civ. Code §1798.100 et seq.
If you are a California resident, you have the following rights under the CCPA:
Right to Know
You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purpose for collecting it, and the categories of third parties with whom we share it.
Right to Delete
You may request that we delete personal information we have collected from you, subject to certain exceptions (e.g., information required to complete a transaction, comply with a legal obligation, or fulfill a court order).
Right to Opt Out of Sale
You have the right to opt out of the sale of your personal information. Brown Management does not sell personal information. If this practice changes, we will provide 30 days' advance notice and update this policy.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. We will not deny services, charge different prices, or provide a different level of service based on your exercise of these rights.
How to Submit a CCPA Request
To exercise any of the above rights, submit a verifiable consumer request by:
- • Email: [email protected]
- • Phone: (866) 324-5350
- • Mail: Brown Management, LLC — Privacy Request, Los Angeles, CA
We will respond within 45 days of receiving a verifiable request. If we require more time (up to 90 days total), we will inform you of the reason and extension period in writing. We may need to verify your identity before processing your request.
5. Do Not Sell or Share My Personal Information
Brown Management does not sell or share personal information for cross-context behavioral advertising. We do not engage in the sale of personal information as defined under the CCPA (Cal. Civ. Code §1798.140(t)).
We do not share personal information with data brokers, advertising networks, or any third party for commercial purposes unrelated to the direct delivery of fiduciary services.
If you wish to confirm this or submit a formal opt-out request as a precautionary measure, please contact us at [email protected]. We will acknowledge your request within 15 business days.
6. Data Security
Brown Management implements administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Our Sovereign OS™ platform maintains an immutable audit trail of all data access and modifications, consistent with the evidentiary standards required for court-supervised fiduciary work.
Specific security measures include: encrypted data transmission (TLS 1.3), encrypted storage, role-based access controls, multi-factor authentication for all staff systems, and regular security assessments. All third-party service providers are contractually required to maintain equivalent security standards.
In the event of a data breach that creates a risk of harm to California residents, we will notify affected individuals in accordance with California Civil Code §1798.82 within the legally required timeframe.
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. For fiduciary matters, California Probate Code and Professional Fiduciaries Bureau regulations require us to maintain records for a minimum of seven (7) years following the close of a matter.
Website analytics data is retained for 24 months. Inquiry and contact form data is retained for 36 months unless a client relationship is established, in which case the retention period follows our fiduciary records policy.
8. Children's Privacy
Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. In the context of fiduciary services involving minor beneficiaries, all personal information is collected from and managed through the legally authorized adult representative (guardian, trustee, or personal representative).
9. Changes to This Privacy 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 and, where appropriate, notify you by email or by posting a prominent notice on our website. Your continued use of our services after any changes constitutes your acceptance of the updated policy.
10. Contact Our Privacy Team
For questions about this Privacy Policy, to exercise your CCPA rights, or to report a privacy concern, contact us through any of the following channels. We are committed to responding promptly and transparently.