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Privacy PolicyLast
updated August 2, 2023
We are concerned about your privacy and are committed to
protecting your personal information. We know you share our concerns, and in
the interests of letting you know how we protect the privacy and security of
the personal information you provide to us, we provide the information below. ACCEPTANCE OF THIS PRIVACY
POLICY
In order to run our business and to provide you with our products and services, we require
certain personal information (your "personal information") that
includes information that identifies you and, with regard to the need to meet
certain legal requirements, the location from which you send us your personal
information. We will take commercially reasonable measures to protect the
privacy and security of your information, but if you do not agree with this
Privacy Policy or the additional descriptions of how we process your personal
information (how we use, share, disclose, store and delete it), you should
not use our Services. If you register for an event and we seek to share your
personal information with the event sponsor and/or other third parties we will,
depending upon your jurisdiction, request your affirmative consent to do so
on the registration form. PERSONAL INFORMATION WE
COLLECT OR RECEIVE
In the course of providing our products and services, and as
required for us to provide our products and services to you, we receive,
collect store and use your personal information, as described below. This
information may include your name, address, telephone number, email address
and the IP address of the device you used to contact us. The ways in which we
obtain your information may include: a)
Your orders for products, subscriptions or
services. b)
Your inquiries sent to our offices or our
website. c)
Your registration for an event, including
webinars, conferences and meetings. d)
Data obtained through use of "cookies"
and other related analytics and technologies described in our Cookies and
Other Related Technologies policy, if you consent as set out below in further
detail. e)
Apps or other software created or developed
for use in connection with our products and services. If you sign up for an event for which registration is open to
the public, your name, company name and other identifying information may be
viewed by others (though in certain jurisdictions we would only make it
available in this way with your consent). The legal bases for our uses, sharing and disclosures
("processing") of your personal information include, as pertinent,
where: a)
Necessary to perform the contractual
obligations in agreements with you to provide products or services; b)
You have consented to the processing as set
out in this Policy, which consent you can revoke at any time; c)
Necessary to comply with a legal obligation, a
court order or to exercise or defend a legal claim; d)
Necessary for the purposes of our or a
third-party's legitimate business interests (so long as those interests do
not override personal rights as indicated by law); e)
You have expressly made your personal
information public; and f)
Necessary to protect your vital interests or
other of others. FINANCIAL INFORMATION WE COLLECT
OR RECEIVE
If you choose to purchase services, products or subscriptions
we may collect credit card information, bank account information and
information necessary to verify your identity, such as date of birth. In
certain countries, national identifier numbers (similar to Social Security
Numbers in the US) may also be collected or received if needed to verify your
identity. We use commercially reasonable standards to protect this
information. Depending upon your
wishes, we may retain this information or arrange for it to be securely
stored in order to facilitate your future purchases. USES OF PERSONAL INFORMATION BY
NORTHSTAR FOR NORTHSTAR's BUSINESS PURPOSES
If you elect to provide us personal information, we may use it
as needed to deliver products and/or services to you. Northstar may use
personal information in a variety of ways to meet our obligations to you to
provide you with a variety of services and products. These uses are based in
our legitimate business interests in providing products and services to you
and/or fulfillment of our contractual obligation to deliver products and
services you have requested. We have
balanced these business needs carefully with your privacy rights and these
uses do not improperly infringe on your privacy and confidentiality
rights. These business uses for your
personal information include the following: a)
Northstar may combine information about you
that we have with information we obtain from business partners or other
companies in order to better deliver products and services that may be of
interest and benefit to you. b)
We may use your personal information for
security, including analysis of the personal information to pursue our
legitimate business interest in protecting our customers and website visitors
against malware, cyber-attack and other crime and security risks. c)
Northstar may use personal information to
contact users regarding renewal of subscriptions to Northstar services and
products and to send product announcements or special edition e-letters to
online registrants. d)
Northstar may use personal information to send
notification of Northstar's or our partners' products and services by such
methods as email and/or postal mail. e)
We may aggregate and anonymize personal
information provided under this Privacy Policy to create anonymized data sets
which will then be used to improve our and our affiliates' products and
services. We may also share aggregated anonymized personal information with
clients, customers, prospective clients and customers or business partners in
order to demonstrate usage of the services, or to identify industry and
advertising trends. f)
If you provide financial information, we use
that information primarily to verify your credit card information and collect
payments for your purchases, orders, subscriptions, etc. g)
If you participate in a Northstar educational
program, webinar, virtual tradeshow, or other time-sensitive programs, we use
personal information to contact you to remind you of upcoming deadlines or
additional information concerning these programs. h)
Northstar occasionally conducts subscriber and/or
user surveys to better target our content to our audiences. The aggregated
information collected is anonymized (identifying information removed) and
sometimes shared with our advertisers, however, we do not share specific
individual information with third parties. i)
Northstar operates several websites featuring
its travel-related content and services. Northstar may share personal
information collected from users of its websites internally across these
websites to better serve its users by permitting us to reference services
across our spectrum of offerings and point you toward the best products and
services for your needs. j)
We may share personal information where we
have a good faith belief that such action is necessary to comply with a
judicial proceeding, a court order, or legal process served on Northstar, or
to establish or exercise our legal rights or defend against legal claims. k)
We may share such information where we have a
good faith belief that it is necessary in order to investigate (or assist in the
investigation of), prevent, or take action regarding illegal activities,
suspected fraud, cyber attack, situations involving potential threats to the
physical safety of any person, violations of Northstar's terms of use, or as
otherwise required by law. l)
If Northstar is acquired by or merged with
another company, we will transfer information about you to this other company
in connection with the acquisition or merger. m)
Northstar has numerous products and services
and therefore numerous email and promotion lists. In an effort to allow users
to tailor their participation in Northstar services and promotions, Northstar
provides users the ability to choose specific lists or products of interest
and opt-out options are product and use/list specific. All email promotions
sent from Northstar provide an opt-out link at the bottom of the email
pursuant to which users can opt-out of specific products and promotions. If
you receive one of these emails and wish to object to this processing of your
information or unsubscribe please follow the instructions given in each email
or contact us at Northstar Privacy n)
For consumers requesting to be
connected with a travel advisor, the data provided in the sign up form
will be sent to advisors that serve your interests. From time to time we may use customer information for new,
unanticipated uses not previously disclosed in our Privacy Policy. If our
information practices change at some time in the future, we will post the
policy changes to our website. Right to object. You may object to Northstar using your personal information for the above purposes at any time by contacting Northstar Privacy . If you do so, Northstar will cease using your personal information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such personal information is permitted to be used by Northstar for another purpose set out in this Privacy Policy or Northstar determines and demonstrates a compelling legitimate interest to continue in processing your personal information. PRIVACY OF MINORS AND CHILDRENNorthstar complies with the Children's Online Privacy Protection Act, which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age. Northstar does not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. However, it is possible that we may inadvertently receive information pertaining to children under 13. If you believe that we have received information about your child that is under the age of 13, please do not hesitate to notify us at Northstar Privacy When we receive your notification, we will obtain your consent to retain the information or will delete it permanently SHARING OF PERSONAL INFORMATION
WITH THIRD PARTIES
In general, Northstar does not rent, sell, or share personal
information about you with other people or nonaffiliated companies except to
provide products or services you have requested, when we have your consent as
indicated in Section I of this Policy, as follows: a)
Northstar may use personal information
collected through its website to send out targeted email promotions on behalf
of its advertisers and industry partners. b)
We may provide personal information about our
users to trusted partners and vendors who work on behalf of or with Northstar
under written confidentiality and similar agreements prohibiting such
parties' further use of the information. These companies may use your
personal information to help Northstar communicate with you about offers from
Northstar and our marketing partners. However, these companies do not have any
independent right to use or share this information. c)
When you register for an
educational program, contest, event, virtual tradeshow or other
promotion that is sponsored by a third party, your personal information
will be provided to that third-party sponsor unless you are a resident
of one of the countries within the European Union (EU). If you are an
EU resident, we will seek your affirmative consent to provide the
third-party sponsor with your personal information in a manner clearly
specified on the registration materials, unless otherwise posed in
connection with the promotion.
d)
Northstar may from time to time share limited
personal information such as email addresses, company name, job title and
state of business or residence with trusted third parties who deliver content
that is likely to be of interest to you. COOKIES
With your consent, the personal information that Northstar may
collect using cookies or other automated methods may include, for example,
your IP address, cookie information, a unique device or user ID, browser
type, system type, the content and pages that you access on the Northstar
websites, the frequency and duration of your visits to our website, the page
from which you navigated to the Website. Northstar may also use cookies to
store session validators on your hard drive.
On our website, Northstar may use this passively collected data to: a)
remember your information so that you will not
have to re-enter it during you visit or the next time you visit our website. b)
monitor your participation in various sections
of our website. c)
customize services to you. d)
monitor website usage metrics such as total
visitors and pages viewed e)
administer, operate and improve our website
and our other products and services, including those tailored to you. For more information please see our Cookie Policy CHOICE AND CONTROL
You may withdraw your consent or otherwise object to uses of your information as described above by contacting Northstar Privacy You may also withdraw your consent to email marketing by unsubscribing, using the unsubscribe link in such communications. If you do so, Northstar will cease using your personal information for the above purposes and remove it from its systems unless such personal information is permitted to be used by Northstar for another purpose set out in this Privacy Policy or Northstar determines and demonstrates a compelling legitimate interest to continue in processing your personal information In case of withdrawal of consent, Northstar will not process your personal information subject to this consent any longer unless legally required to do so. In case Northstar is required to retain your personal information for legal reasons your personal information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal information by Northstar up to the point in time of your withdrawal. Furthermore, if your use of a Northstar offering requires your prior consent, Northstar will not be (any longer) able to provide the relevant product, service, offer, or event to you after your withdrawal. Please direct any such request for withdrawal to, or write to Northstar at Northstar Privacy You can request from Northstar, at any time, information about which personal information Northstar processes about you and the correction or deletion of such personal information. If Northstar uses your personal information to perform a contract with you, you may further request a copy of the personal data that you have provided to Northstar. To make such a request, please contact the email set forth below and specify in detail the information or the activity to which your request relates, the format in which you would like the personal data returned and the recipient, you or your designee. Furthermore, you may contact Northstar if you believe that the personal information that Northstar has is incorrect. Depending upon your location, you may benefit from a number of
rights with regard to your personal information that we process. These rights
are defined and, in some cases limited, by the laws of your jurisdiction.
These rights include (a) data portability, including the right to obtain a
copy of the personal information you have provided to Northstar; (b) data
correction (also known as rectification, including the ability to request
correction or amendment of your personal information and (c) data deletion,
including the right to have Northstar delete your personal information except
for information that we are required to retain. You also have the right to have Northstar cease processing your
personal information is dependent upon the following events: (i) you state
that the personal information Northstar has about you is incorrect; but
Northstar may retain the information
for as long as it requires to check the accuracy of the relevant
personal information; (ii) there is no legal basis for Northstar's processing
of your personal information and you demand that Northstar restrict your
personal information from further
processing, (iii) Northstar no longer requires your personal information but you claim that you require such data in
order to claim or exercise legal rights or to defend against third party
claims; or (iv) in case you object to the processing of your personal information
by Northstar it may retain and process the information for as long as it is
required to review as to whether Northstar has a prevailing interest or legal
obligation in continuing to process your personal information. You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting Northstar Privacy. SECURITY
The security of your personal information is very important to us. We utilize commercially reasonable information security standards to protect your personal information from unauthorized access, use or disclosure. Northstar supports online security using appropriately secure technology because we want your data to be safe. We bind our employees and data processors to written agreements to observe your privacy and confidentiality rights. Unfortunately, no method of internet transmission is one hundred percent secure. While we strive to protect your personal information, we cannot guarantee its security. DURATION AND RETENTION
Northstar will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or as required or permitted by law, and then will delete it as required by law. For example, Northstar will retain your information as long as required to comply with applicable tax/revenue laws, cybersecurity and privacy laws, laws and regulations that affect the conduct of our business; to resolve disputes, enforce our agreements, cooperate with law enforcement requests or to meet other legal obligations. We may also retain log files for internal analysis purposes, though we would retain them for only a brief period except in cases where we are legally required to retain them for longer periods, and in cases where they are used for site safety and security or to improve website functionality. INTERNATIONAL TRANSFERS
Northstar operates on a global basis. By using our products and services you understand and agree that your personal information may be transferred from the European Economic Area (EEA, which comprises the European Union countries plus Norway, Iceland, Liechtenstein) to a country that does not have an equivalent level of data protection, such as the United States. When your personal information is transferred from your home country to another country, the laws and regulations that protect your personal information may be different than those in your home country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law. To the extent that Northstar is deemed to transfer your
personal information outside the EEA, Northstar relies upon data transfer
agreements with Model Contract Clauses, which the European Commission has
adopted to provide safeguards for personal information that is transferred
outside the EEA. You may obtain a copy of the Model Clauses by contacting Northstar Privacy. CALIFORNIA RESIDENTS
Residents of California have the right to request a disclosure describing what types of Personal Information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us at Northstar Privacy or 1 800 776 0720
The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know how your information is collected and shared; to request deletion of your personal information; to opt out of communications, sale or sharing of your personal information and to request access to your personal information. CCPA requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. |
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