Do Not Sell or Share My Personal Information

01Our Posture: No Sale or Sharing, Permanently

LumaNavi LLC (operating Brinley Encore) 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 LumaNavi's internal governance doctrine — not a policy subject to future revision at our discretion. It applies to all categories of personal information we collect, including account data, connected-platform analytics, and usage data.

We do not maintain relationships with data brokers, do not participate in data cooperatives or exchange networks, and do not share your data with advertising networks, ad exchanges, or retargeting platforms.

02What This Means for Your Opt-Out Right

Under CCPA §1798.120 and the CPRA, California residents have the right to opt out of the sale or sharing of their personal information. Because Brinley Encore 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, contact privacy@brinleyatlas.com. We will respond within 45 days.

03Your California Privacy Rights

As a California resident, you have the following rights under CCPA/CPRA:

• Right to Know (§1798.110). Request disclosure of the categories and specific pieces of personal information we collect, the sources, the business purposes, and the categories of third parties we share with.
• Right to Delete (§1798.105). Request deletion of personal information we collected from you, subject to legal exceptions.
• Right to Opt Out of Sale or Sharing (§1798.120). Already permanently honored — we do not sell or share.
• Right to Non-Discrimination (§1798.125). We will not deny service, charge different prices, or provide a different level of service because you exercised a privacy right.
• Right to Data Portability (§1798.100). Receive your personal information in a portable, readily usable format. You can export your data from Settings.
• Right to Correct (CPRA). Request correction of inaccurate personal information we maintain about you.
• Right to Limit Use of Sensitive Personal Information (CPRA). We collect sensitive information only as needed to operate the platform and do not use it for any other purpose.

04How to Exercise Your Rights

To submit a verifiable consumer request:

• Email: privacy@brinleyatlas.com
• In-platform: export and deletion are available directly from Settings.

We verify your identity before processing a request and respond within 45 days. If we need additional time, we will notify you in writing. You may designate an authorized agent to make a request on your behalf.

05Third-Party Disclosure

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. See our sub-processor list.

06Contact

For privacy questions, to exercise your California rights, or for written confirmation of our no-data-sale posture:

privacy@brinleyatlas.com

LumaNavi LLC — Attn: Privacy, California Rights Request