Privacy Policy

Last Updated: December 10, 2023

PPE Global, LLC dba NorthStar Advisors and its affiliates (“NorthStar,” “we,” “our,” and/or “us”) value the privacy of individuals who use our websites (including https://navigatewithnorthstar.com), applications, or services that link to this Privacy Policy. This privacy policy (the “Privacy Policy”) explains how we collect, store, use, share, transfer, delete and otherwise process information collected from or about users of our Services (“Users”) known as Personal Data (defined below).

Purpose of this Privacy Policy

This Privacy Policy describes the types of Personal Information, as defined below, that NorthStar may collect or process, how we may use and disclose that Personal Information, and how you may exercise any rights you may have regarding our processing of your Personal Information.

This Privacy Policy applies to Personal Information that is collected or processed by us:

Through online activities and Services that we offer (through this and other of our websites, web surveys, newsletters, applications, email, online messaging services or channels, which may include online “chats” with live individuals and artificial intelligence, through social media, through our telephone customer service centers, through email or SMS/text messages, and otherwise) (Online Services);
Through your account and through our products and services;
In other situations where you interact with us, including but not limited to interacting with us by visiting our sites or offices or attending our events (such as tradeshows and conferences) (Events) (our Online Services, Products, and Events are collectively called Services in this Privacy Policy);
When you interact with us in a professional capacity, for example, if you are an employee of a company we do business with or provide Services to;
When we undertake employment recruiting activities; or
Anywhere this Privacy Policy is posted or referenced.

NorthStar may provide you with a different privacy notice in certain specific situations, in which case that privacy notice or policy will apply to the Personal Information collected or processed in that specific situation, rather than this one.

If you provide us with Personal Information related to anyone other than yourself (such as a patient or family member), please note that you are responsible for complying with all privacy and data protection laws prior to providing that information to NorthStar (including collecting consent, if required).

NorthStar is the entity responsible for the collection and use of your Personal Services (known in some jurisdictions as the “data controller”).

Please review this Privacy Policy carefully. To the extent permitted by law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Privacy Policy. If you do not agree with our policies and practices, it is your choice not to use our Services or otherwise engage with us.

Information We Collect

What is Personal Information?

Personal Information, also known as Personal Data, is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual, such as a name, address, email address, or telephone number. Personal Information in some countries can include information that indirectly identifies a person, even absent other identifying information.

Personal Information may include information considered sensitive in some countries, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license number, state identification card number, passport number, and other similar information.

If you are located in the European Economic Area (“EEA”) or the United Kingdom, “Personal Information” means any information relating to an identified or identifiable individual.

We will process any Personal Information that we collect in accordance with law and as described in this Privacy Policy (unless, as explained in this Privacy Policy, a separate policy or notice governs). In some circumstances, if you do not provide us with certain Personal Information, there may be some Services that are unavailable to you.

We may collect a variety of Personal Information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us

Communications. If you contact us directly, we may receive additional Personal Information about you. For example, when you contact us for support, we will receive your name, email address, the contents of your message, and your phone number if you choose to provide it. If you subscribe to our marketing communications, we will receive your name and email address.

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the Personal Information that you choose to provide us as part of your job application, such as your contact information, education, and employment experience. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the Personal Information that you make available to us through such third-party platform.

Sensitive Information. Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Services or otherwise to us.

B. Information We Collect When You Use Our Services

Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region. We may use IP addresses for purposes such as calculating Services usage levels, diagnosing server problems, and administering the Services.

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, device type, and operating system version.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with them, such as the length of time you spend on a page, objects you click on, and the dates, times, and lengths of your sessions. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. You can find more about our use of cookies by visiting our Cookie Policy

C. Personal Information We Receive from Third Parties

Partners. We may receive Personal Information about you from third parties such as data or marketing partners and combine it with other Personal Information we have about you.

How We Use the Personal Information We Collect

We use the Personal Information that we collect:

To provide, maintain, improve, and enhance our Services;
To communicate with you, provide you with updates and other information relating to our Site, provide information that you request, respond to comments and questions, and otherwise provide support;
To process job applications;
To find and prevent fraud, and respond to trust and safety issues that may arise;
For compliance purposes, including enforcing our Legal Notice and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the Personal Information is collected.

Legal Bases for Processing European Personal Information

If you are located in the European Economic Area or the United Kingdom, we only process your Personal Information when we have a valid “legal basis”, including when:

Consent. You have consented to the use of your Personal Information, for example to use cookies.
Contractual necessity. We need your Personal Information to provide you with the Services, for example to respond to your inquiries.
Compliance with a legal or regulatory obligation or defend our legal claims and rights. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.
Legitimate interests. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
Public interest. We may use your Personal Information to protect vital interests or in the public interest.
Public health. We may use your Personal Information for reasons of public health, including ensuring high standards of quality and safety.
Research. We may use your Personal Information for research purposes.

How We Share the Personal Information We Collect

We do not share or otherwise disclose Personal Information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may share Personal Information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any Personal Information we receive with vendors and service providers retained in connection with the provision of our Services.

Marketing. We do not rent, sell, or share Personal Information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission or as provided in this Privacy Policy.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Consent. We may also disclose your Personal Information with your permission.

Your Rights and Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Depending on where you live, you may have the following rights with respect to some or all of your Personal Information:

To request information about whether, and how, we process your Personal Information
To request access to and a copy of your Personal Information, including to provide your Personal Information directly to another organization (called, in some locations, a right to data portability)
To request that we correct or update your Personal Information
To request that we delete your Personal Information
To request that we restrict or block or to object to, opt-out of, or withdraw consent with respect to the processing of your Personal Information, including your sensitive Personal Information
To appeal the denial of a request; and
To lodge a complaint with the data protection authority in your jurisdiction.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. In the event you wish to make a complaint about how we process your Personal Information or to appeal the denial of one of your requests, please contact us. Even if you make a complaint to us, you may always lodge a complaint with the relevant privacy or data protection authority in your location.

We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you with certain Services or it may otherwise affect the way we are able to interact with you.

We will make reasonable efforts to respond promptly to your requests. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. While any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

When we receive your Personal Information from others and process your Personal Information on their behalf, we may do so at their request and subject to their instructions. In that case, we do not have control over their privacy and security practices and processes. If your Personal Information has been submitted to us by a third party, we may need to ask you to contact them directly or we may be able to contact them on your behalf. If we need you to contact them directly, we will let you know.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any personal information you disclose to these third parties. We encourage you to read their privacy policies before providing any personal information to them.

Retention

We take measures to delete your personal information or keep it in a form that does not permit identifying you when this personal information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this personal information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

Security

We seek to use reasonable administrative, technical and physical safeguards and other security measures to protect your personal information from growing threats. However, as no electronic transmission over the internet or data storage system of Personal Information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information. We urge you to exercise caution when transmitting Personal Information over the internet.

Cross-Border Transfer

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may transfer personal information from the European Union or the United Kingdom to the United States as needed to perform the Services that you have requested from us, or with your consent. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.

Please be aware that Personal Information that we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, country, or location where the privacy laws may not be as protective as those in your location, including the United States. NorthStar has put in place lawful transfer mechanisms and appropriate safeguards, in accordance with its legal requirements, to protect your Personal Information, including but not limited to Standard Contractual Clauses where required.

By providing any information, including Personal Information, on or to our Services, you consent to such transfer, storage, and processing.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. We will alert you when changes have been made by indicating the date this Privacy Policy was last updated as the date that the Privacy Policy became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Privacy Policy to learn of any changes.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please submit your inquiry via our website contact us submission form.