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Privacy Policy

Last 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 CHILDREN

Northstar 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.

If you are located within the EU and have any questions regarding the processing of your personal information, you can also contact our European privacy representative via email to northstar-euprivacy@german-law.com or postal mail to Brödermann Jahn Rechtsanwaltsgesellschaft mbH - Northstar EU Privacy -, ABC-Strasse 15, 20354 Hamburg, Germany. Our European representative is authorized to act on behalf of Northstar regarding matters concerning the EU GDPR, including dealing with any EU based supervisory authorities.

 

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.

Shine the Light
Residents of California have the right to request a disclosure describing the categories 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 as set out in the “Contact Us” section above and specifying that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Notice of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: Identifiers, including name, alias, postal address, email address, phone number, account name, IP address, and other similar identifiers and certain demographic information.

The only personal information Northstar collects, processes and maintains is business information in which you have communicated with us concerning a business transaction, asked us to perform a service or provide you with a product, or which is otherwise excluded from the definition of “personal information” and most of the requirements with regard to that information within the California Consumer Privacy Act (CCPA ). The business basis for, and the manner in which, such business information is collected and processed is set forth within this Privacy Notice.

Northstar does not “sell” personal information as the terms “sell” or “sale” are defined within the California Consumer Privacy Act (CCPA), as revised by the California Consumer Privacy Rights Act (CPRA). Northstar shares the personal information it collects with business partners who are its “Service Providers” as that term is defined by California Law. Service Providers are business partners who perform business functions for Northstar, as the term ”Service Provider” is defined within CCPA. These Providers agree to use information only for these business purposes and not to redisclose it except as permitted or required by law as set out in our contracts with them. The nature of the services provided by these business partners and a description of the categories of these service providers is set forth within this Privacy Notice. Northstar may also disclose personal information with program sponsors where you have consented to disclosure of that information when you register for an event, webinar, educational program, downloadable guide or other sponsored programs. Northstar may provide personal information to its business partners for cross-contextual behavioral advertising, which disclosure is within the definition of Sharing of Personal Information within CPRA.

Do Not Sell or Share My Personal Information
If you have questions regarding collection of your business or personal information or believe that information that identifies you and has been collected by Northstar and was sold or shared within the meaning of CCPA or CPRA or is not provided to a Service Provider as stated above, and you wish to advise us of these beliefs and ask that we not sell or share that information please contact Northstar Privacy or 1 800 776 0720. As required by law, we may not discriminate against you in any way by virtue of your request that we not sell or share your personal information, or exercising other rights provided by CCPA or CPRA.