Privacy Policy

1. Who We Are

LumaNavi LLC (“Brinley,” “we,” “us,” or “our”) operates Brinley Field, a field service management platform for service businesses. For the purposes of applicable data protection laws, LumaNavi LLC is the data controller for the personal data described in this policy.

To contact us about privacy: privacy@brinleyfield.com

2. What Data We Collect

We collect the following categories of personal data through your use of the Brinley Field platform:

• —Account and registration data. Name, email address, password (stored as a secure hash), and organization details provided when you create an account.
• —Contact information. Name, email address, and any other contact details you or your organization provide during use of the platform.
• —Usage information. How you interact with Brinley Field — features used, session activity, and operational events generated in the course of using the platform. This data is processed through our first-party telemetry system (brinley-ops) and is not transmitted to third-party analytics services.
• —Business operational data. Job records, customer records, scheduling data, and other business data that you and your team enter into the platform. You are the data controller for this information. Brinley processes it on your instruction.
• —Billing data. Payment method details for platform subscription fees. Payment processing is handled by Stripe. Brinley does not store full card numbers.

3. How We Use Your Data

We use your data to:

• —Operate and deliver the Brinley Field platform and its features
• —Process your subscription and manage billing through Stripe
• —Monitor the security and integrity of the platform
• —Detect and prevent fraud, abuse, or unauthorized access
• —Improve the platform through first-party usage analysis
• —Respond to support requests and communications from you

We do not use your data to train AI models, build advertising profiles, or make inferences about you beyond what is necessary to deliver the platform.

4. Who We Share Your Data With

We do not sell your data. We do not share your data with third parties for behavioral advertising. We share data only with infrastructure providers that help us operate the platform, and only under data processing agreements that require them to protect your data equivalently to our own obligations.

A current list of our sub-processors — the infrastructure providers that process data on our behalf — is available at:

brinleyfield.com/legal/subprocessors →

We will provide reasonable advance notice of material additions to this list. Each sub-processor is bound by a data processing agreement that prohibits them from selling your data or using it for behavioral advertising.

5. We Do Not Sell Your Data

Brinley does not sell, rent, or otherwise make your personal data available to any third party for monetary or other valuable consideration. This is a permanent commitment — not a policy subject to future revision at our discretion.

If you are a California resident, you have the right to opt out of the sale of your personal information under the CCPA. Because we do not sell data, no opt-out mechanism is required — but you may contact privacy@brinleyfield.com to confirm this in writing if needed.

6. No Behavioral Advertising

Brinley does not use your data for cross-context behavioral advertising. We do not share your data with advertising networks, ad exchanges, or data brokers. We do not track your behavior across third-party sites or services. This is a permanent commitment.

7. First-Party Telemetry Only

All platform telemetry — error tracking, performance monitoring, and usage analytics — routes through brinley-ops, LumaNavi's internal first-party telemetry system. No third-party analytics SDKs, error tracking SDKs, or behavioral instrumentation SDKs are embedded in the Brinley Field platform. Your usage data does not leave our infrastructure through analytics tools.

8. Your Rights

Depending on your location, you may have rights regarding your personal data, including:

• —Access. Request a copy of the personal data we hold about you.
• —Deletion. Request deletion of your personal data, subject to legal retention requirements.
• —Portability. Receive your data in a machine-readable format.
• —Correction. Request correction of inaccurate personal data.

To exercise any of these rights, contact us at privacy@brinleyfield.com. Organization admins can also manage data access and deletion requests through the platform's governance controls.

8A. California Consumer Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you specific rights regarding your personal information:

• —Right to Know (§1798.110). Request disclosure of the categories and specific pieces of personal information we have collected, the sources we collected it from, the business purposes for collection, and the categories of third parties with whom we share information.
• —Right to Delete (§1798.105). Request deletion of personal information we have collected from you, subject to exceptions where retention is required by law or necessary to complete a requested transaction.
• —Right to Opt Out of Sale or Sharing (§1798.120). You have the right to direct us not to sell or share your personal information. Because we do not sell or share personal information, this right is permanently honored — no action required. See our California Privacy Rights page for full details.
• —Right to Non-Discrimination (§1798.125). We will not discriminate against you for exercising any CCPA/CPRA rights — no denial of service, differential pricing, or reduced service level.
• —Right to Data Portability (§1798.100). Receive your personal information in a portable, readily usable format. Organization admins may initiate data exports through the platform's governance controls.
• —Right to Correct (CPRA). Request correction of inaccurate personal information we maintain about you.

To submit a verifiable consumer request, contact privacy@brinleyfield.com. We respond within 45 days. For additional California privacy information, see our Do Not Sell or Share My Personal Information page.

9. Data Retention

We retain your data for the duration of your subscription to Brinley Field. After your subscription ends, your data is available for export for 30 days. At the end of this window, we delete your data from our systems and instruct our sub-processors to do the same. Certain records may be retained longer where required by law (e.g., billing records for tax compliance).

10. Changes to This Policy

We will provide reasonable advance notice of material changes to this privacy policy. Notice will be delivered via email to the organization admin or via in-platform notification. The “Last updated” date at the top of this page reflects the most recent revision.

11. Contact

For privacy questions, data requests, or to report a concern:

privacy@brinleyfield.com

Last updated: April 30, 2026