Brushworks
Brief us

Political strategy and data, at human resolution

Elections are decided by people, not demographics. We work at that scale.

Brushworks is a political intelligence firm. We model how individual voters behave, determine what would move each of them, and put persuasion into the field with a standard of proof — across the United States and in the harder theaters abroad.

  1. 1. The file
  2. 2. Signals resolve
  3. 3. Deciders surface
  4. 4. A program in field
Plate IFour thousand people as the voter file sees them: identical rows, nothing to tell one from another.
500+contests, from presidential to school board, over a decade
96%won, across every level and both parties
$5B+approved in more than a hundred bond and levy measures
270M+American adults and households, resolved and behaviorally scored
12countries of institutional and diaspora work
7offices on a single 24-hour desk
The premise

Most campaigns still buy the electorate the way television networks sold it in 1985: by age, sex, county and party file. Those labels are easy to purchase and easy to defend in a budget meeting. They are also the reason two neighbors with identical demographics receive identical mail and vote in opposite directions.

People do not decide as categories. They decide as individuals, under pressure, with whatever they happened to pay attention to that month. That attention leaves traces — what someone reads, buys, searches, cancels, renews, drives past on the way to work. Read carefully and modeled properly, those traces describe a person far better than the file does: what they are anxious about, what they take pride in, whom they trust, and what they have quietly stopped believing.

Brushworks was built to work at that resolution. We do the research, the modeling, the message architecture and the delivery ourselves, through our own media seats, and we measure every program against a held-out control — so that what we report at the end is what actually happened.

What we doThe method, in five movements

Terrain, audience, message, delivery, proof.

The order matters. Nothing is built before the race is mapped; nothing is written before the deciders are named; nothing is reported that was not measured against a control.

Capabilities in full

  1. I

    Terrain

    Where the race will actually be decided: the precincts, the margin, the money coming against you, and the clock.

  2. II

    Audience

    Deciders identified by what they do rather than by label, and grouped by what would move them.

  3. III

    Message

    A narrative track for each group, built from the anxieties and hopes it already holds and sequenced for the persuasion arc.

  4. IV

    Delivery

    Three registers: precision paid media, organic advocacy, and the ambient campaign. All of it disclosed, all of it through our own seats.

  5. V

    Proof

    Randomized holdouts, daily measurement, and a publish gate no model passes without beating the baseline.

The human layerExhibit 1

One person, seventeen thousand signals.

Our view of the American electorate is assembled from roughly sixty-two billion observed behaviors, resolved to more than 270 million adults and their households, organized into a ten-thousand-topic dictionary, and scored by models trained on real outcomes rather than proxies.

No single signal is decisive. The pattern is. A subscription cancelled, a commute lengthened, a local news habit, a sudden interest in prescription prices — each is noise on its own and evidence together. The graph is rebuilt monthly, digital activity refreshed daily, and none of it touches ethnicity, religion or ideology, which we do not model.

Inside the human layer

Exhibit 1The active signal registry, drawn to scale by domain — roughly 17,000 signals, each line a family of observed behaviors. Ochre marks signals that entered a scored model this month. Grouping illustrative.
From the behavioral lexiconExhibit 2, composites, not individuals

A campaign speaks to millions. It persuades one at a time.

Every other vendor in politics starts from the voter file, because that is what there is to buy: age band, sex, party, precinct, vote history. It is enough to send mail. It is not enough to know what to say. We describe deciders as phenotypes — composite people assembled from thousands of behavioral neighbors — so that a strategist and a copywriter can hold an entire segment in mind as a single person, and so that the person receives a line that was written for her.

Exhibit 2The same voter, two ways. Left, everything the voter file knows about the Night Nurse. Right, what the human layer knows — signals color-coded by domain, six scores, and the track she was assigned. Composite; the file's fields are typical, the signals illustrative.
  • Behavior, not labels.

    Cohorts are built from what people do — sixty-two billion observed events — never from ethnicity, religion or party as a proxy for what they will do.

    The category default: age band, sex, party, precinct

  • Named, and written for.

    Each cohort is a person with a name, a narrative track and a register mix. Copy is written to her; the studio produces the variants; every one carries a disclosure.

    The category default: one message, three demographic cuts

  • Measured against a control.

    Every track is judged against a randomized holdout. A line that moves the Steward and suppresses the Pharmacist is caught in week two, not guessed at in November.

    The category default: a post-election poll

The Steward

n., first-ring suburb

Homeowner, twenty years at the same employer, runs the parish fish fry. Believes the deal has been broken by people who never had to keep one.

Reads as
Order, obligation, the fair deal
Moves on
Cost-of-living arithmetic told with respect, not alarm

"The people who wrote the last budget never had to keep one."

The Splitter

n., late-deciding

Has voted for both parties in the last four cycles and resents being told what she is. Decides in the final ten days, mostly on character.

Reads as
Independence
Moves on
The single credible detail, not the platform

"Two votes, two dates, on the record. Judge them yourself."

The Night Nurse

n., shift worker

Mid-career, watches the news on a phone between rounds, has no patience for anyone who has not done a hard job under pressure.

Reads as
Competence
Moves on
Proof that someone has carried weight and kept their head

"She ran a trauma floor for eleven years. You'll hear she has never run anything."

The Renter

n., downtown, under 35

Three employers on the résumé, a lease that resets every twelve months, and a commute that has quietly become the central fact of life.

Reads as
Momentum
Moves on
A candidate who names the rent and the commute in the first sentence

"Your lease resets in March. Your rent didn't ask permission."

The Pharmacist

n., exurban professional

Meticulous about sources, allergic to slogans, and will read the footnote if there is one. Trusts the messenger who shows the working.

Reads as
Skepticism
Moves on
The claim with its evidence attached

"Here is the ratio she wrote, the hospital that adopted it, and the audit that followed."

The Contractor

n., rural-exurban, self-employed

Runs a crew of four, bids every job against someone cheaper, and keeps his own books at the kitchen table on Sunday nights.

Reads as
Self-reliance
Moves on
The rule that cost him a week, named specifically

"Section 4 cost you a week in March. Here is who wrote it and who voted to repeal it."

Commerce Media Civic Household Health and work Bars show the signal domains that define each composite

The recordExhibits 3 to 5

Ninety-six in a hundred.

Across more than five hundred contests — presidential, gubernatorial, Senate and House, ballot measures, and over a hundred bond and levy elections — the programs we have designed have won ninety-six percent of the time, for candidates and causes across the spectrum. Client names are held under agreement. The methods and the margins are not.

Open the casebook

Exhibit 3Five hundred contests, one dot each. Ochre, won; bone, lost. Drawn from the firm's record across a decade; positions of the losses are schematic.
OfficeMethodNote
PresidentialHyper-localization of a national narrativeA 2016 national campaign; the message rewritten county by county for the places that decided it.
GubernatorialBehavioral targeting across three distinct strategiesThree competitive states, three different theories of the race, one measurement standard.
U.S. SenateThe neglect algorithmPersuadable voters both parties had stopped contacting, found and moved.
U.S. HouseGrassroots amplificationSmall-dollar and volunteer growth engineered from behavioral affinity, not lists.
Ballot measuresSimplifying complexityA 2022 California measure: 65 percent support at launch, 17.7 percent at the ballot.
Bonds and leviesConcrete, not abstractMore than a hundred measures; more than five billion dollars approved by voters raising their own taxes.
Committees and NGOsThe permanent campaignTrigger-based activation between cycles, so the audience is warm when it matters.
Exhibit 4The record, by office. Each method is a case in the casebook.
Exhibit 5Support for a 2022 California ballot measure. The launch figure is the campaign's baseline polling; the result is the official statewide vote of November 8, 2022 (17.7 percent yes). The intervening trajectory is drawn to scale between them. Program in field from the second month.
CasebookThree of nine

What the method did when it met a real race.

  • Simplifying complexity

    A California measure whose text ran to dozens of pages, at 65 percent support, defeated with 17.7 percent of the vote — one true sentence per voter.

  • The neglect algorithm

    The persuadable, likely voters both parties had stopped calling, found by cross-referencing contact history with receptivity.

  • Ten million, five countries

    A diaspora treated as the constituency it is, across the United States, the United Kingdom, Canada, the UAE and Australia.

All nine cases

AbroadExhibit 6

The harder theaters.

The same discipline travels. Our people have run engagement, security and narrative programs for governments and institutions in the Gulf, South Asia, Southeast Asia and West Africa, and diaspora programs in five countries at once. Seven offices sit on a single desk, so a mandate in Riyadh and a race in Michigan are watched by someone who is awake.

Where we have worked

Diaspora as an electorate. A ten-million-person community spread across five countries is a constituency, whether or not anyone treats it as one. We do.

Featured readFrom the Brushworks Review
Also in the ReviewAll twenty-four papers
    The rules we work byFive things we will not do

    Five things we will not do.

    Written into every engagement letter, and the first page a donor's counsel or a ministry's compliance office is shown.

    I

    Target on identity

    We model behavior only. Ethnicity, religion and ideology are never modeled, never bought, and never accepted as a filter.

    So the Steward can be any color and any faith.

    II

    Hide the messenger

    Paid advocacy is labeled. We do not operate undisclosed personas or accounts, on any platform, in any language, for any client.

    So the second voice is a real one.

    III

    Report without a control

    Every program carries a randomized holdout sealed on day five, and every model beats a demographic and a look-alike baseline before it ships.

    So the number in the report is the number that happened.

    IV

    Cross a wall

    Independent-expenditure work is separated from candidate work by structure — teams, systems and seats. Foreign work is registered before it begins.

    So a donor's counsel can certify the posture, not take our word for it.

    V

    Run what we could not describe

    If a program could not be explained on the record, in public, in the client's name and ours, we do not run it. Mandates that fail the test are declined in writing.

    So there is nothing to find.

    Policies, disclosures and governance

    The commitments we are bound by, in plain language.

    Written for the people whose behavior we model, the clients we work for, the regulators who oversee both, the journalists who will ask, and anyone who reads this site. Effective September 18, 2026. Every commitment on this page is one the firm can be held to, and the section that follows says how.

    How to verify what this page says

    A policy is a claim. This ledger says where each claim can be checked — by a client's counsel, a committee treasurer, a ministry's compliance office, a regulator, or a reporter.

    ClaimWhere to check itWho can
    We register before foreign-principal work touches the United StatesThe Department of Justice's public FARA registry and the House and Senate Lobbying Disclosure databasesAnyone
    Every paid political communication carries its disclaimer and names its sponsorThe public ad libraries of the major platforms, under the sponsor's verified name; the client's own filingsAnyone
    Candidate and independent-expenditure work are walledThe firm's written wall certification, delivered on request to any committee, counsel or regulatorClients, committees, counsel
    Every program is measured against a sealed controlThe client's holdout report — the control is reported to the client directly and never enters the delivery pathClients and their auditors
    No model uses ethnicity, religion or ideologyThe registry exclusion and the proxy-reconstruction test, documented in the program's model cards and kill logClients, auditors; summarized annually in public
    Every data source has a documented lawful basisThe provenance record for the client's program, delivered with the engagementClients, auditors, regulators
    The performance assurance is underwrittenThe carrier's certificate, provided to qualifying clients under the engagement letterQualifying clients
    Security controls are independently assessedThe independent assessment summary, under non-disclosure agreementClients and prospective clients under NDA
    Concerns are answered and nobody is retaliated againstThe semiannual transparency report: concerns received, resolved and outstanding, in aggregateAnyone

    Press and public inquiries: press@brwrks.com, answered within one business day. We do not disclose client identities held under agreement, and we do not decline to confirm a registration, a disclaimer or a policy.

    Privacy policy

    Applies to this website, to the people whose data appears in our programs, and to clients, counterparties and correspondents.

    In short. We use behavioral data — what people do — to design and measure lawful political and institutional communication. We never model who people are; we never sell information; we never run undisclosed accounts; we never keep a client's data after the engagement; and we never build a profile of anyone from this website. You can ask what we hold about you, have it corrected or deleted, and opt out. The addresses are at the end.

    1. Who we are and what this policy covers

    Brushworks, Inc. ("Brushworks," "we") is a Wyoming corporation providing political strategy, behavioral research, creative and delivery services to campaigns, committees, institutions and governments, with offices in Washington, New York, Ottawa, London, Munich, Dubai and Tokyo. This policy covers three groups: visitors to this site; people whose information is in the data we license, receive or produce for a program; and the clients, vendors and correspondents we deal with. Brushworks is the controller of the personal information described here except where it processes a client's data on the client's instructions under a written data-use agreement, in which case it acts as a processor and this policy applies alongside that agreement.

    2. Definitions

    • Behavioral data — recorded acts with a time and a source: a subscription, a search, a renewal, a visit, a donation, a returned ballot. Not opinions, not attributes, not categories.
    • Signal — a defined, versioned pattern over behavioral data that has been shown to predict a later act. The registry of active signals is curated and pruned monthly.
    • Cohort — a group of people defined by what they attend to and act on. Cohorts are composites; no cohort is a person, and no program contacts a cohort of one.
    • Program — a single engagement for a single client with a single purpose, from terrain to proof report.
    • Holdout — a share of every cohort drawn at random before any spend and never contacted, against which the program is measured.
    • Hashed identifier — a one-way transformation of an identifier such as an email address, used to match an audience inside a delivery platform without transmitting the identifier itself.
    • Client data — data a client lawfully holds and provides to us under a data-use agreement. Licensed data — data licensed from a provider under written terms that document its lawful basis and source.

    3. Visitors to this site

    We collect the minimum needed to operate the site: server logs (IP address, browser and device type, pages requested, timestamps), the information you choose to send when you brief us, and, only if you consent, the analytics described in the cookie notice. We do not sell visitor information, we do not use this site to build behavioral profiles, we do not match visitors to the behavioral graph, and we do not use advertising cookies or tracking pixels from any third party.

    4. The people whose behavior we model — sources

    Programs use data of four kinds. Licensed behavioral data from established providers, under written agreements that document the lawful basis on which the data was collected and may be used for political communication and that warrant its provenance. Client data a client lawfully holds — a supporter file, a member list, a donor record — provided under a data-use agreement and used for that client's program alone. Public records, including voter registration and participation files, obtained and used only as the law of the issuing state permits, for the political purposes the state allows. Our own measurement of the programs we run — the holdout comparison, response records and sentiment instruments. Information is resolved to individuals and households for research, audience design, delivery and measurement, and for nothing else.

    5. What we never do

    • We do not model, license, infer, purchase or accept as a targeting filter any data describing ethnicity, race, religion, or political ideology, even where the law would permit it. The exclusion is enforced where signals are defined, and every model is tested for reconstructing an excluded attribute by proxy; models that do are retired and logged.
    • We do not process the sensitive categories data-protection law protects: health status or records, genetic or biometric data, sexual orientation, immigration status, criminal history, precise geolocation, or financial account data. Attention to a topic in the media — a person who reads about hospital staffing — is a media-behavior signal, not a health record, and is treated as such.
    • We do not sell personal information, and we do not share it for cross-context behavioral advertising, in any jurisdiction, under any definition.
    • We do not operate undisclosed personas or accounts on any platform, in any language, for any client.
    • We do not combine one client's data with another's, and we do not retain a client's data after the engagement and its wind-down period.
    • We do not knowingly collect or model data about anyone under eighteen. Voter files by construction contain only adults; licensed sources are contractually restricted to adults; a record found to belong to a minor is deleted on discovery.
    • We do not scrape websites or social platforms, and we do not license from brokers who cannot document how their data was collected.
    • We do not produce synthetic depictions of real people — voice, likeness or fabricated statements — for any purpose.

    6. Lawful basis, by jurisdiction

    In the United States, our use of behavioral data for political communication rests on the licenses and agreements above and on the state laws governing voter files and consumer data; the California Consumer Privacy Act as amended by the California Privacy Rights Act, and comparable statutes in other states, govern the rights described in section 8, and we treat those rights as available to everyone regardless of residence. In the European Union, the United Kingdom and Germany, processing rests on legitimate interests assessed and documented for each program, with consent where the law requires it and with the safeguards the GDPR, the UK GDPR and the Bundesdatenschutzgesetz provide for processing that may reveal political opinions — which our behavior-only design is built to avoid. In Canada, on PIPEDA and Quebec's Law 25. In the United Arab Emirates, on the Personal Data Protection Law. In Japan, on the Act on the Protection of Personal Information. Where a program touches more than one of these, the stricter rule governs.

    7. Sharing

    Audiences leave the platform only as hashed identifiers, matched inside the delivery platforms that carry a program; raw personal data does not travel. We share information with processors — hosting and infrastructure, security and monitoring, delivery platforms, measurement — bound by written terms at least as protective as this policy; with clients as their data-use agreement provides and only for their program; and with regulators, courts or law enforcement where the law requires it, in which case we notify the affected client unless prohibited. We do not share personal information with data brokers, with other clients, or with any political party, committee or campaign other than the client for whom a program is run.

    8. Your rights, and how to use them

    Wherever you live, you may ask us what personal information we hold about you and receive a copy; have it corrected or deleted; opt out of any use for targeted advertising; object to or restrict processing; limit the use of any sensitive information (we hold none); and, where the law provides it, receive a portable copy and appeal a decision we make about your request. Write to privacy@brwrks.com with enough information for us to find your record and confirm it is yours; we may ask for verification proportionate to the sensitivity of the request, and we accept requests from an authorized agent with written authority. We answer within thirty days, or within forty-five where the applicable law allows it and the request is complex, and we tell you if we need longer. We do not discriminate against anyone for exercising a right. A Global Privacy Control signal from your browser is treated as an opt-out request where the law so provides. If you are unsatisfied, section 13 lists the regulators you may contact.

    Where you liveRights we honorOur response time
    California and other U.S. states with consumer privacy statutesKnow, access, correct, delete, opt out of sale or sharing and of targeted advertising, limit sensitive use, non-discrimination, appeal45 days, extendable once by 45 with notice
    Other U.S. statesThe same rights, extended voluntarily45 days
    European Union and United KingdomAccess, rectification, erasure, restriction, portability, objection, and rights in relation to profiling under Articles 15–22One month, extendable by two for complex requests
    CanadaAccess, correction, withdrawal of consent, and complaint to the Commissioner30 days
    United Arab Emirates and JapanAccess, correction, deletion, restriction and objection as the PDPL and APPI provideAs the law requires; never longer than one month

    9. Retention

    Client program data is retained for the life of the engagement and a wind-down period of not more than ninety days, then destroyed with certification. Licensed data is refreshed and superseded on its providers' cycles; the behavioral graph is rebuilt in full each month, and superseded data is not archived. The schedule in section 12 governs everything else.

    10. Security

    Access to program data is limited to personnel working on the relevant program under written obligations, with named-user access, multi-factor authentication, encryption in transit and at rest, logged access to client files reviewed monthly, and separate systems and seats for the candidate and independent-expenditure practices. Every employee and contractor completes data-protection and political-compliance training before access and annually thereafter, and loses access on the day their role ends. Security controls are independently assessed each year and the assessment summary is available under non-disclosure agreement. Where a mandate requires it, program data is held in-country with residency and replication attestations delivered to the client.

    Control areaWhat is in placeEvidence available
    Identity and accessNamed-user accounts, multi-factor authentication, least-privilege roles scoped to a program, quarterly access recertification, same-day revocation on role changeAccess matrix; recertification records
    EncryptionTLS 1.2 or higher in transit; AES-256 at rest; keys managed in a dedicated key service with rotation and separation of dutiesConfiguration attestation
    SegregationSeparate environments per practice; program data isolated by client; no shared credentials; delivery seats separated by practiceWall certification; environment diagram
    Logging and monitoringImmutable access and change logs retained one year, reviewed monthly; alerting on anomalous access; export and bulk-read events flaggedLog samples; review records
    Vulnerability managementContinuous dependency scanning; patching within defined windows by severity; annual independent penetration test with remediation trackingTest summary under NDA
    Secure developmentCode review for every change; secrets kept out of repositories; production changes logged and reversibleChange records
    Business continuityEncrypted backups with restoration tested quarterly; documented recovery objectives per system; the desk's seven-office handoff for operational continuityRestoration test records
    Incident responseWritten runbook; on-call across the desk; containment, notification and post-incident review under counselRunbook summary; incident log in aggregate
    VendorsDue diligence before onboarding; written terms; annual review; a maintained processor listProcessor list; diligence records
    PeopleBackground screening where lawful; training before access and annually; written obligations that survive employmentTraining records

    11. Automated decisions, profiling and international transfers

    Our models score the likelihood that a person will act; they do not make decisions with legal or similarly significant effects about anyone, and no score is ever used to deny anyone a service, a benefit, an opportunity or the right to vote. Where the GDPR or UK GDPR applies, this is profiling for a legitimate interest and not automated decision-making within Article 22; a data-protection impact assessment is completed for every program in those jurisdictions and is available to the supervisory authority on request. We operate from seven offices in six countries. Personal information may be processed in the United States and, for programs abroad, in the country of the mandate. Transfers out of the European Economic Area or the United Kingdom rely on standard contractual clauses or an adequacy decision; transfers out of other jurisdictions rely on the mechanisms their law provides.

    12. Retention schedule

    DataKept forThen
    Client program dataLife of the engagement, plus a wind-down of not more than ninety daysDestroyed, with certification on request
    Hashed audiences in delivery platformsLife of the programDeleted from the seats at close
    Licensed behavioral dataRefreshed and superseded on providers' cycles; the graph is rebuilt monthlySuperseded; not archived
    Models trained on a client's outcomesLife of the programRetired with the program; recorded in the kill log
    Measurement and proof reportsDelivered to the client; the client's propertyFirm copy retained as an engagement record for seven years
    Compliance records: registrations, wall certifications, reviews, conflict and gift registersSeven years, as the law and our auditors requireDestroyed
    Site logsNinety daysDeleted
    Correspondence about a briefTwo years, unless an engagement followsDeleted
    Rights requests and concernsThree years, as a compliance recordDeleted

    13. Processors, regulators and contact

    We use processors in four categories — hosting and infrastructure, security and monitoring, the delivery platforms that carry a program, and measurement — each bound by written terms at least as protective as this policy; a current list is available on request and is delivered to every client. If you are not satisfied with our answer, you may contact your regulator: in the United States your state attorney general or, in California, the California Privacy Protection Agency; in the European Union your national data protection authority; in Germany the federal or state commissioner with jurisdiction; in the United Kingdom the Information Commissioner's Office; in Canada the Office of the Privacy Commissioner or, in Quebec, the Commission d'accès à l'information; in the United Arab Emirates the UAE Data Office; in Japan the Personal Information Protection Commission. We post revisions here with a new effective date and, for material changes affecting people in our programs, notify affected clients. Questions, requests and complaints: privacy@brwrks.com, or by post to Brushworks, Inc., attention Data Protection Lead, at our registered agent's address in Wyoming.

    Version 1.2, September 18, 2026. Versions 1.0 and 1.1 published September 2026. Prior versions available on request.

    Data use policy

    Governs every dataset Brushworks licenses, receives or produces, and every model built from it. Incorporated by reference into every client, vendor and employment agreement.

    In short. One program, one purpose, one client; behavior only; hashed on the way out; destroyed with certification at close. Every source has a documented lawful basis or it is not used. Every model faces the same gate, every failure is logged, and every result is measured against a control drawn before any money was spent. A request to do otherwise ends the engagement.

    1. Principles

    • Purpose limitation. Data is used for the program it was licensed or provided for, and for no other client, program or purpose. A client's file is matched to the graph for that client's program alone and unmatched at close.
    • Behavior only. We do not model or infer ethnicity, race, religion or political ideology, and we do not accept such attributes from clients or vendors as targeting criteria, even where they are lawful to use. We do not process the sensitive categories listed in the privacy policy.
    • No commingling. One client's data is never combined with another's. Models trained on a client's outcomes belong to that program and are retired with it. Learning that improves the firm's methods is carried forward only in aggregate and never as data.
    • Provenance. We license only from providers who document the lawful basis and source of their data and warrant it in writing. We do not scrape, and we do not buy from brokers who cannot answer the question.
    • Minimization. Programs use the signals the models need and nothing else; the registry is pruned monthly of signals that have stopped predicting.
    • Hashed activation. Audiences are transmitted to delivery platforms as hashed identifiers matched inside those platforms. Raw personal data is never uploaded to a platform.
    • Retention. Program data is destroyed on a written schedule after close, with certification to the client on request and as standard for institutional mandates.
    • Onward transfer. No data is transferred to a third party except delivery platforms and processors bound by written terms at least as protective as this policy.
    • Human review. Every creative master is reviewed and approved by a named person before any variant is produced from it; no communication is published without a person having read it.

    2. Sources we accept, and sources we refuse

    Accepted, with a provenance recordRefused, without exception
    Licensed behavioral data from providers who warrant lawful collection and permitted political useData obtained by scraping websites or social platforms
    Client files the client lawfully holds and may use for political communicationHacked, leaked, breached or otherwise unlawfully obtained data, however it is offered
    Voter registration and participation files, within the issuing state's permitted usesHealth, genetic, biometric or financial-account records; precise geolocation; immigration or criminal-history data
    Our own program measurement: holdout comparisons, responses, sentiment instrumentsAny dataset describing ethnicity, race, religion or ideology, or built to infer them
    Public statistical and administrative data at the aggregate levelData about minors, and data from sources that cannot exclude them
    Aggregate, non-identifying platform reportingFacial recognition or other biometric identification outputs

    3. Data classification and handling

    ClassExamplesHandling
    Client-confidentialClient files, strategy, creative masters, plans, resultsProgram-scoped access; encrypted; never commingled; destroyed at close with certification
    Licensed behavioralEvents, signals, the graphProvider terms enforced; refreshed and superseded; not exported; used only for the program a license permits
    DerivedScores, cohorts, models, holdout assignmentsLabeled with confidence and attribution level; models retired with the program; holdouts sealed and reported to the client only
    ActivationHashed audiences in delivery platformsHashed before transmission; matched in-platform; deleted from seats at close
    PublicThis site, the Review, published reportsNo personal data; corrections dated

    4. Prohibited uses

    No program run by Brushworks may use data to suppress turnout or discourage any eligible person from voting; to deceive voters about the time, place, manner or eligibility rules of voting; to impersonate a person, organization or official source; to operate undisclosed accounts or personas; to target on identity; to re-identify a hashed audience or a holdout; to harass or intimidate; to produce synthetic depictions of real people; or to resell or repurpose data licensed or provided for a program. A request to do any of these ends the engagement, and the request is recorded.

    5. Model governance

    Every model faces the publish gate: on the client's own sealed holdout it must beat a demographic baseline — the voter file used as well as a good consultant would use it — and a look-alike baseline — the delivery platforms' own targeting — before it is used. Candidate models are tested for reconstructing an excluded attribute by proxy and retired if they do. Models that fail any test are logged with the reason and killed; the kill log is delivered to the client with the proof report and summarized in aggregate each year. Every shipped model carries a model card recording its training data, baselines, discrimination, known limits and kill threshold, and is watched in field daily against that threshold. Every score is labeled with its confidence and with the attribution level — person or household — of its weakest input.

    6. Measurement and reporting

    Every program carries a randomized holdout drawn before any spend and sealed; the holdout reports to the client directly and never enters the delivery path. Results are reported as the difference against the control with confidence intervals, never as raw outcomes alone, and null results are reported as prominently as positive ones. Weekly field reports, the proof report and the kill log are the client's property. The methodology — holdout size, estimand, interval construction, baselines — is published with the Review.

    7. Provenance standard

    Before a dataset is licensed or a client file is accepted, the firm records, for that source: the lawful basis on which it was collected and may be used for political communication; the notice given to the people in it; the provider's written warranties and audit rights; the refresh cycle; whether records are person- or household-attributed; the categories present, confirming that the excluded and sensitive categories are absent; and the jurisdictions in which it may be used. A source that cannot answer every question is not used. The record is available to the client for its program and to a regulator on request.

    8. People and vendors

    Every employee and contractor signs this policy, completes training before access and annually, may not use program data for any personal purpose including personal political activity, and loses access on the day their role ends. Every vendor that touches program data signs terms at least as protective as this policy, accepts audit, and is listed on the processor list delivered to clients. A breach of this policy by an employee is a disciplinary matter up to dismissal; by a vendor, grounds for termination.

    9. Incidents

    We notify affected clients within seventy-two hours of confirming a security incident involving their data, and regulators and individuals as the applicable law requires, with a written account of what happened, what was affected, what has been done and what will change. Incidents are recorded, reviewed under counsel, and reported in aggregate in the transparency report.

    10. Audit and retention

    Clients may audit our compliance with this policy on reasonable notice under their agreement, including the single-origin media trail from invoice to placement to impression and the provenance records for their program. Independent security reporting is available under agreement. The retention schedule in the privacy policy applies to every dataset covered here.

    11. Use of AI tools

    AI tools assist the studio in producing variants from an approved master and the research practice in modeling; they do not originate claims, do not depict real people, and do not decide anything about a person. Every AI-assisted variant traces to a source the campaign supplied and is read by a person before it exists as a creative; every model is gated and logged as section 5 describes. AI-generated or materially altered content is disclosed wherever the platform or the law requires it. No client or program data is used to train any model that serves another client, and no program data is submitted to a third-party AI service that retains it.

    Version 1.2, September 18, 2026.

    Governance

    How the firm is run, who is accountable for what, what we will not take on, and where to take a concern.

    In short. Separate practices behind a documented wall; a signed compliance review before anything goes on air; written client sign-off gates with a ten-percent reallocation threshold; no opposing sides of the same contest; clients of both parties and none; a written list of work we decline; a concerns channel that answers in writing and never retaliates; and an annual independent review.

    1. Structure and accountability

    Brushworks, Inc. is a Wyoming corporation whose whole business is political and institutional work. It is organized as a candidate practice, an independent-expenditure practice and an international practice, served by research and modeling, a creative studio and a seven-office desk. Political work in the United States is contracted through Brushworks and no other entity. The chief executive is accountable to the board for every policy on this page. A compliance lead owns the reviews, registrations and registers; a data protection lead owns the data use policy, the retention schedule and rights requests; the head of research owns model governance and measurement; counsel of record is named in every engagement letter. Each reports on the policies to the board at least quarterly.

    RoleAccountable forReports toCadence
    Chief executiveEvery policy on this page; client acceptance; the conflict registerThe boardQuarterly, and after any incident
    Compliance leadCompliance reviews, registrations, disclaimers, the gift register, trainingChief executive and counsel of recordEvery program at day ten; quarterly summary
    Data protection leadData use policy, retention, rights requests, impact assessments, processor listChief executive; regulators on requestMonthly review; annual report
    Head of researchPublish gate, model cards, kill log, measurement methodologyChief executive; clients through the proof reportEvery program; annual kill-log summary
    Head of the deskSeven-office handoff, crisis architecture, business continuityChief executiveQuarterly rehearsal
    Counsel of recordNamed in every engagement letter; signs the compliance review; supervises investigationsThe client and the boardEvery program

    2. Practice walls

    The candidate practice and the independent-expenditure practice are separate teams with separate systems, separate media seats and separate access to data. No person works in both during a cycle; no data, creative or plan crosses between them; shared functions — research, the studio, the desk — serve each practice through separate, logged channels under the firewall policy. The wall is documented, is reviewed by counsel each cycle, and a certification of it is available to any client, committee, counsel or regulator that requires one. The international practice is separately walled from domestic political work where a mandate touches the United States.

    3. Compliance review

    Every program passes a compliance review on the tenth day of the engagement and before any material change: disclaimers and disclosures, coordination protocols, registration under the laws governing foreign representation and lobbying, sanctions and end-use screening, platform political-advertising policies and verification, synthetic-media and AI-disclosure requirements, and brand safety. The review is signed by the compliance lead and counsel of record. A program does not go on air without a signed review, and the review is delivered to the client.

    4. Client sign-off gates

    Strategy, creative masters and the media plan are approved in writing by the client — or, for donor-funded committees, by the contributors' advisory board — before execution. Reallocations of more than ten percent of any budget line require the same approval. In-flight optimization within approved lines is Brushworks' responsibility and is reported weekly. Clients hold audit rights over the single-origin media trail and receive the invoice-to-impression chain in the proof report.

    5. Client acceptance, neutrality and what we decline

    We work for candidates and causes across the political spectrum and take no position as a firm on partisan questions; the record spans both major parties at every level. Every prospective engagement is screened before acceptance for the identity of the client and the source of its funds, its purpose, the jurisdiction, sanctions exposure, and conflicts. We decline, and record the declination of: work on opposing sides of the same contest or question; mandates whose client, funds or purpose cannot be described in public; work for parties subject to sanctions; work for organizations that advocate violence or the denial of civil rights to any group; programs whose object is to suppress or discourage lawful voting; foreign-principal work intended to influence a United States election; and any program that would require undisclosed messengers, synthetic depictions of real people, or targeting on identity. Mandates declined are reported in aggregate in the transparency report.

    6. Conflicts, gifts and personal political activity

    A conflict register is reviewed before every engagement and quarterly thereafter. A gift and hospitality register records anything offered to or by a public official. Employees may engage in personal political activity on their own time and at their own expense, may not use the firm's data, systems or name in doing so, and disclose personal political contributions and any campaign roles to the compliance lead so that conflicts can be identified before they arise.

    7. Data governance

    The data use policy above is binding on every employee, contractor and vendor. The data protection lead is responsible for its application, for the retention schedule, for data-protection impact assessments where required, and for responding to rights requests. Model governance — the publish gate, model cards and the kill log — is owned by the head of research and reported to clients with every proof report.

    8. Independent review

    Each year an independent assessor reviews the firm's security controls and the operation of the practice wall, and an independent reviewer with the relevant expertise reviews the measurement methodology — holdout construction, estimands, interval reporting — against the standard published with the Review. Summaries of both are available under non-disclosure agreement to clients and prospective clients and are referenced in the annual report. This policy is reviewed annually by counsel and after any incident, and revisions are posted with a new effective date.

    ReviewBy whomHow oftenOutput
    Security controlsIndependent assessorAnnualAssessment summary under NDA
    Practice wallIndependent assessor and counselAnnual and each cycleWall certification
    Measurement methodologyIndependent reviewer with domain expertiseAnnualMethodology note published with the Review
    Policies on this pageCounselAnnual and after any incidentRevision with new effective date
    TrainingCompliance leadBefore access; annually; on material changeTraining records

    9. Reporting to clients and the public

    Every client receives the weekly field report and, at close, the proof report, the kill log and the compliance review. The firm publishes an annual report, a semiannual transparency report and an annual kill-log summary, listed under Reports below.

    10. Raising a concern

    Anyone — an employee, a client, a vendor, a member of the public — can raise a concern about our conduct at concerns@brwrks.com. Concerns may be raised anonymously. Reports are acknowledged within two business days, investigated under the supervision of counsel, and answered in writing. Retaliation against anyone who raises a concern in good faith is prohibited and is itself a disciplinary matter; a concern about a member of leadership is investigated by counsel alone and reported to the board. Concerns received, resolved and outstanding are reported in aggregate in the transparency report.

    11. Continuity and incident command

    A program in the field is watched continuously by the office whose business day it is, with a written handoff between offices and a rehearsed crisis clock. Systems carry encrypted backups restored on a tested schedule, and every program's data can be reconstituted from the previous day's state. An incident — security, compliance, reputational or operational — is commanded under a written runbook by a named lead, with counsel engaged from the first hour, the client notified as the data use policy requires, and a post-incident review completed within thirty days and reported to the board.

    Version 1.2, September 18, 2026.

    Political and foreign-agent disclosures

    What the law requires of us in the United States and abroad, what we do beyond it, and where the public can see it.

    In short. Every communication carries its disclaimer and names its sponsor, and every paid placement on the major platforms is visible in their public ad libraries. Independent expenditures do not coordinate. Foreign mandates that touch the United States are registered before work begins, and no foreign money reaches United States political work. AI-assisted content is disclosed wherever the law or a platform requires it. Counterparties are screened. The performance assurance is underwritten and applies only to media we place ourselves.

    1. Federal and state political work

    Communications we produce for candidates, committees and ballot campaigns carry the disclaimers required by federal law (52 U.S.C. §30120 and 11 C.F.R. §110.11) and by the states and localities in which they run, including top-funder and committee-name requirements where they apply. We support clients' reporting obligations, including 24- and 48-hour independent-expenditure reports, with the placement records the single-origin media trail produces, and our vendor payments appear in clients' public filings. We do not make contributions to candidates or committees, and we do not solicit them.

    RegimeWhen it applies to usWhat we doWhere the public can see it
    Federal disclaimers and coordination (FECA; 11 C.F.R. Parts 109, 110)Every federal candidate, committee and independent-expenditure communicationDisclaimers on every communication; firewall policy; no common vendor across the wallThe communication itself; clients' FEC reports
    State and local campaign financeState, local and ballot-measure workState disclaimers, top-funder and committee-name language; vendor reporting through clientsState and local filings
    Foreign Agents Registration ActWork for a foreign principal that involves activity in the United StatesRegistration before work begins; labeling of informational materials; semiannual reportsThe Department of Justice's FARA registry
    Lobbying Disclosure Act; state lobbying lawsWhere our activity constitutes lobbyingRegistration and periodic reportsHouse and Senate LDA databases; state registries
    Foreign-influence and third-party regimes abroadPolitical or institutional work in jurisdictions with such regimesRegistration and reporting with local partners of recordThe relevant national registry
    Platform political-advertising policiesEvery paid political placement on the major platformsAdvertiser verification in the sponsor's name; disclaimers as the platform requiresThe platforms' public ad libraries
    Sanctions and export controlsEvery counterparty, before and during an engagementScreening of parties, owners and funds; a match ends the engagementCertification available to counsel

    2. Independent expenditures

    Independent-expenditure work is performed by a separate practice that does not coordinate with any candidate, campaign or party committee. We do not act as a common vendor across the wall within the periods the regulations define, do not republish campaign materials, and maintain a documented firewall that satisfies 11 C.F.R. §109.21(h). Where a client requires it we provide a certification of the firm's posture with respect to a given contest, and we will provide the same certification to the Commission or a court.

    3. Foreign governments and foreign principals

    Where a mandate for a foreign government, political party or other foreign principal involves activity in the United States, Brushworks registers under the Foreign Agents Registration Act (22 U.S.C. §611 et seq.), or the Lobbying Disclosure Act where that statute applies, before work begins, and files the informational materials and periodic reports the law requires; those filings are public. We do not accept foreign funds for United States political work of any kind, and we do not accept a mandate whose object is to influence a United States election. Work abroad that does not touch the United States is conducted under the laws of the relevant jurisdiction — including third-party and foreign-influence registration regimes where they exist — and with local partners of record, and every placement carries its sponsor in the language of the market.

    4. State lobbying and gifts

    Where our work constitutes lobbying under a state's or a foreign jurisdiction's law, we register and report there. We do not offer gifts, hospitality or anything of value to public officials beyond what the applicable rules permit, and we keep a register of what is offered.

    5. Sanctions and end use

    Counterparties, their beneficial owners and the sources of their funds are screened against United States, United Kingdom, European Union and United Nations sanctions lists and against export and end-use restrictions before an engagement and periodically during it. A match ends the engagement.

    6. Platforms, AI and synthetic media

    Paid political placements on the major platforms run from accounts verified in the sponsor's name, so that they appear in the platforms' public ad libraries with their disclaimers and spend. Where content is generated or materially altered with the assistance of AI tools, we disclose it as the platform and the growing number of states that require disclosure of such content in political communication demand, and we do not produce synthetic depictions of real people — voice, likeness or fabricated statements — under any circumstances. Variants produced by the studio carry their disclosure as part of the master, so that it cannot be dropped in production.

    7. What a disclaimer looks like

    Every paid communication states who paid for it and, where required, whether it was authorized by a candidate; every organic and ambient placement we arrange identifies its sponsor; validators say who they are and who asked them. Where a jurisdiction requires additional language — a top-funder disclosure, a ballot-measure committee's name, an "independent expenditure" statement, an AI-content notice — the compliance review confirms it before the program goes on air.

    8. Performance assurance

    Where Brushworks offers a performance assurance, it is underwritten by a third-party carrier, applies only to political programs and only to media placed through Brushworks' own seats, and is described in full in the engagement letter, with the carrier's certificate provided to the client. It is not offered on institutional or commercial work. Nothing on this site is an offer of the assurance to any particular client.

    Version 1.2, September 18, 2026.

    Cookie notice

    In short. No advertising cookies, no cross-site tracking, no third-party pixels, and nothing set without your consent except what the site needs to remember a display preference on your own device.

    This site sets only what it needs to work. Analytics, if enabled, run only after you consent, truncate IP addresses, and are configured not to share data with any third party for advertising. We honor Global Privacy Control. You may withdraw consent at any time in your browser settings; every part of the site continues to work without cookies.

    What is setPurposeLasts
    Display preferenceRemembers a theme or tab choice on your device; never sent to usUntil you clear it
    Privacy choicesRecords your Do Not Sell or Share opt-out and your analytics choice on this device, from the "Your privacy choices" panel in the footer; never sent to usUntil you clear it
    Analytics, if allowedAggregate page-level usage with truncated IP; no advertising useThirteen months

    Terms of use

    In short. The site is information, not an offer; engagements exist only in writing. Quote with attribution; do not republish exhibits or papers in full without permission. Figures marked illustrative are the method, not a client's result.

    By using this site you agree to these terms. The material on the site is published for information; it is not an offer of services, not legal or financial advice, and not a guarantee of any result. Engagements are governed exclusively by written agreements. Case descriptions are accurate to the firm's records and are anonymized under client agreements; official election results are stated from the public record; figures marked illustrative or pooled depict the method rather than a specific program and should not be read as a specific client's result. Content, exhibits and the Brushworks name and marks are the property of Brushworks, Inc.; you may quote from the site with attribution and may not reproduce exhibits or papers in full without permission. The Brushworks Review is published for general readers and practitioners; papers state their sources and their own limits, and corrections are published with the paper and dated. These terms are governed by the laws of the State of Wyoming.

    Acceptable use

    You may read, link to and quote from the site with attribution. You may not scrape it, reproduce it in substantial part, present its exhibits as your own, use its contents to train a model without permission, misrepresent the firm's positions, or use the site to attempt access to any system behind it.

    No advice; no reliance

    Nothing on the site is legal, financial, electoral or compliance advice, and nothing on it describes what a program would do for you; that is stated only in a written engagement, after a terrain brief, with the measurement design and the assurance terms set out in full. Case descriptions are accurate to the firm's records and anonymized under agreement. The Review's papers are the firm's own analysis and are corrected, with a dated note, when a reader shows us an error.

    Liability

    The site is provided as it is. To the extent the law allows, Brushworks accepts no liability for reliance on it, for interruptions to it, or for third-party sites it links to; nothing in these terms limits liability that cannot be limited by law.

    Changes

    We revise these terms by posting a new version with a new effective date. Material changes are noted in the version log. Disputes are subject to the exclusive jurisdiction of the courts of the State of Wyoming, and these terms are governed by its laws.

    Version 1.2, September 18, 2026.

    Accessibility

    This site is built to WCAG 2.2 AA: it is keyboard navigable, labeled for screen readers, and offers reduced-motion and dark-mode variants. Every animated exhibit has a text equivalent in its caption and label; charts are described in words; color is never the only carrier of meaning. Known limitations: some data exhibits are dense at the smallest screen sizes and can be scrolled sideways; live clocks read as text. If anything on the site is not accessible to you, write to access@brwrks.com and we will fix it or provide the content in another form within five business days.

    Conformance and testing

    The site is built to the Web Content Accessibility Guidelines 2.2 at level AA and is tested before each release with automated checks and manual keyboard and screen-reader passes at desktop and phone widths, in light and dark modes, and with reduced motion enabled. Exhibits that animate have text equivalents; interactive exhibits have keyboard-operable controls and do not rely on drag alone. Where an exhibit cannot be made fully accessible — a dense data visualization at the smallest screen sizes — its caption states what it shows, and the same content is available in words on request. This statement is reviewed with every release.

    Reports

    What the firm publishes, on what cadence, and what is available under agreement.

    • Annual report, Vol. I PDF

      The record for the cycle — contests, methods, aggregate lift against holdouts, losses and post-mortems, the kill-log summary, the governance ledger and the independent-review summaries.

      Spring 2027, in preparation
    • Transparency report PDF

      Registrations filed, disclaimers carried, concerns received and resolved, mandates declined, incidents, rights requests received, and the practice-wall certification.

      Semiannual, from January 2027
    • Kill-log summary PDF

      Every model retired at the publish gate or in field during the year, in aggregate, with the reasons.

      Annual
    • Security summary PDF

      Independent security reporting, residency and replication attestations, restoration tests.

      Under agreement
    • Methodology notes PDF

      How the holdout is drawn, how lift is estimated, how the baselines are constructed — the standard of proof, written down.

      Published with the Review
    • Diligence pack PDF

      For prospective clients under non-disclosure agreement: wall certification, a redacted sample proof report and kill log, the processor list, a sample provenance record, a sample model card, the independent-review summaries, and the carrier's certificate for the performance assurance.

      On request, under NDA
    • The compliance packs PDF

      Free summaries of the privacy, political-advertising and communications rules in the United States, Canada, Europe and the rest of the world.

      September 2026; reviewed with each release
    • Policies and disclosures

      Privacy, data use, governance, political and foreign-agent disclosures, cookies, terms and accessibility — this page.

      Effective September 18, 2026
    ReturnThe firm

    Brief us.

    Tell us the race, the calendar and the margin. Within a week we will tell you whether we can move it and what it would take. Candidate work and independent-expenditure work are taken by separate teams; say which you are. Governments and institutions: tell us the mandate and the jurisdiction, and we will tell you what registration it requires before we say anything else.

    Send a brief

    brief@brwrks.com
    Candidate practice
    Independent-expenditure practice
    International practice
    Brushworks, Inc. — a Wyoming corporation
    Washington, New York, Ottawa, London, Munich, Dubai, Tokyo