California Privacy Rights
Do Not Sell or Share My Personal Information
Brinley Field does not sell or share your personal information — permanently. This page explains our posture and how to exercise your California privacy rights. Last updated May 14, 2026.
We do not sell or share your data. This is a permanent commitment. There is no opt-out mechanism because there is nothing to opt out of. This policy documents our posture and your rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).
Our Posture: No Sale or Sharing, Permanently
LumaNavi LLC (operating Brinley Field) does not sell, rent, or otherwise make your personal information available to any third party for monetary or other valuable consideration. We do not share your personal information with third parties for cross-context behavioral advertising.
This is a permanent commitment established in our internal governance doctrine (AXR-042, adopted April 27, 2026) — not a policy subject to future revision at our discretion. It applies to all categories of personal information we collect, including account data, usage data, and business operational data.
We do not maintain relationships with data brokers. We do not participate in data cooperatives or exchange networks. We do not share your data with advertising networks, ad exchanges, or retargeting platforms.
What This Means for Your Opt-Out Right
Under CCPA §1798.120 and CPRA, California residents have the right to opt out of the sale or sharing of their personal information. Because Brinley Field does not sell or share personal information, no opt-out mechanism is required — your right is already permanently honored by our posture.
If you wish to receive written confirmation of our no-sale posture, contact us at privacy@brinleyfield.com. We will respond within 45 days.
Your California Privacy Rights
As a California resident, you have the following rights under CCPA/CPRA:
- —Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share information (CCPA §1798.110).
- —Right to Delete. You may request deletion of personal information we have collected from you, subject to exceptions where retention is required by law or is necessary to complete a transaction you have requested (CCPA §1798.105).
- —Right to Opt Out of Sale or Sharing. You have the right to direct us not to sell or share your personal information. As stated above, we do not sell or share — this right is already honored permanently (CCPA §1798.120 / CPRA).
- —Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge different prices, or provide a different level of service because you exercised a privacy right (CCPA §1798.125).
- —Right to Data Portability. You may request your personal information in a portable, readily usable format that allows you to transmit it to another entity (CCPA §1798.100). Organization admins can initiate data exports through the platform's governance controls.
- —Right to Correct. You may request correction of inaccurate personal information we maintain about you (CPRA, effective January 1, 2023).
- —Right to Limit Use of Sensitive Personal Information. If we collect sensitive personal information (as defined by CPRA), you have the right to limit its use to what is necessary to perform the services you requested. We collect sensitive information only as required to operate the platform and do not use it for any other purpose (CPRA).
How to Exercise Your Rights
To submit a verifiable consumer request, use one of these methods:
- —Email: privacy@brinleyfield.com
- —In-platform (for active subscribers): Organization admins may submit data access, export, and deletion requests through the governance controls in the platform.
We will verify your identity before processing a request. We will respond within 45 days. If we need additional time, we will notify you of the reason and extension period in writing. We will not charge you a fee for making a request unless it is excessive, repetitive, or manifestly unfounded.
You may designate an authorized agent to make a request on your behalf. We will require the authorized agent to provide proof of authorization and may require you to verify your identity directly with us.
Third-Party Disclosure Obligations
Brinley Field does not disclose personal information to third parties for their own business purposes, does not participate in data broker exchanges, and does not share personal information for cross-context behavioral advertising. We share personal information only with infrastructure sub-processors who process data on our behalf under contractual obligations that prohibit them from selling or sharing it.
Contact
For privacy questions, to exercise your California rights, or for written confirmation of our no-data-sale posture:
LumaNavi LLC
Attn: Privacy — California Rights Request
Last updated: May 14, 2026