Privacy - Northshore Capital Investments

Northshore Capital Investments, (“Northshore”) provides a variety of investments and investment related services as described at www.northshoreci.com (“Site”). Throughout this Privacy Policy, “Sites” refers to this Site and, as applicable, any other website, channel, application, mobile feature and/or platform we operate. Under this Privacy Policy, Northshore and its affiliates are referred to as “Northshore” or “we, us, and/or our.” This Privacy Policy is a legally binding agreement between you and Northshore.

PURPOSE

This policy (“Privacy Policy”) describes, among other things:

The Personal Information (as defined below) we collect about you.
How we use the Personal Information we collect.
The categories of third parties with whom we share Personal Information about you.
Your right to review and correct Personal Information we have collected about you.
What we do to protect Personal Information we have collected about you
You have the right to opt out of commercial email messages.
How we interact with linked sites.
Specific terms applicable to California residents.
Specific terms applicable to EU data.
Our right to change the terms of this Privacy Policy.

Our Privacy Policy explains how we handle the Personal Information of all residents, including those from California and the European Union. This includes the reasons and legal basis for collecting such information, the duration of its retention, and your right to object to its collection. This Privacy Policy, in conjunction with the Terms, forms a legally binding agreement between you and Northshore. By accessing or utilizing our Sites, or by requesting information, purchasing, or subscribing to our Services, you agree to the Terms and this Privacy Policy, which includes our collection, usage, and disclosure of your Personal Information as detailed below. Please carefully review this Privacy Policy carefully.

SCOPE

This Privacy Policy pertains solely to Personal Information, which refers to data that can identify an individual. It does not encompass the data we gather that cannot be used to recognize a person, including pseudonymous information, encoded or anonymized data, or aggregated data pertaining to a group or category of services, features, or users, which does not contain personally identifying information. We reserve the right to share aggregate, encoded, or anonymized data with potential partners or other third parties without any limitations.

WHAT IS PERSONAL INFORMATION?

This Privacy Policy defines Personal Information as including your first and last name, email address, physical address such as street name and city or town, phone number, social security number, any payment or financial data, and any other identifier that allows Northshore to contact a natural human person, like you. Additionally, Personal Information encompasses any data that we maintain that could be used to identify you in conjunction with the aforementioned identifying details.

INFORMATION WE COLLECT

Personal Information is gathered by us when you use our Sites and/or Services, as well as when you provide it to us. We collect Personal Information for various purposes, including enhancing our services, fulfilling our obligations under contracts we have with you, complying with our legal obligations, and other purposes as detailed below.

Information You Give Us: Any Personal Information that you provide to us when you contact us, request information, sign up for our newsletters or promotions, purchase Services, or apply for employment is received and stored by us. This may include information such as your name, email address, telephone number, state of residence, and company affiliation. For instance, if you contact us through the Sites to request information about our Services, we may request this information to process your request. We may also use your email address to get in touch with you regarding your request, and if necessary, may use the other information to assist in processing your request. However, if you choose not to provide such Personal Information, certain portions of the Sites or some of their features may not be accessible or available for use.

Automated Collection: When you visit the Sites, we automatically collect and store certain types of information such as the name of the domain and host from which you access the Internet, your computer’s IP address, the browser and operating system you are using, the date and time you access the Sites, the website address from which you linked to the Sites, any search terms used to find the Sites, and information about your device and network. If we link or combine this information with any identifying information, it will be treated as Personal Information. Otherwise, this information will be considered as aggregate information.

Log Data: Our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Sites. This log data is used for troubleshooting and to monitor the pages people visit, in order to enhance the Sites. We do not link the log data collected to any Personal Information. Additionally, third-party vendors may independently collect aggregate log data.

Cookies and Other Technologies: Certain types of information are automatically received and stored when you visit the Sites, through the use of programs like web beacons, cookies, or similar technologies that collect the information as described previously. Cookies are strings of text that may be stored on your computer by a website. The Sites utilize cookies to keep track of your preferences and activities while using or visiting the Sites. We use cookies for various purposes including authentication, to remember your settings, to monitor your activity during a visit to the Sites, to conduct usability tests, to improve the performance of the Sites, and to implement certain features of the Sites.

The Sites create session cookies for each visit in order to facilitate your visit. The session cookie expires at the end of the session.

We may also use “persistent” cookies, which remain on your device for much longer. Cookies do not corrupt or damage your computer or computer files.

We use analytics and customization cookies, including third party cookies, to gather information on how our Sites are being used by our visitors and to measure how popular our marketing campaigns are. We use the data we get to help customize our Sites and services for you and make the content you see as relevant as possible. We may also use the data we collect to help identify and prevent fraud, and to track visits from our affiliates or partners.

Social networking cookies allow visitors to share our pages and content through third-party social networking websites.

The use of cookies can be controlled at the individual browser level. You will be asked for your consent for the placement of cookies and, should you choose to give it, you can later withdraw your consent by adjusting your preferences on our Site or within your browser settings. Although it is possible to use our Sites without accepting cookies, doing so may limit your ability to use certain features or areas of the Sites. If you prefer not to receive cookies, you may set your browser to reject them (consult your browser’s instructions for guidance on how to do this), but keep in mind that this may impact your ability to perform certain transactions on the Sites.

Web Beacons: Some pages on the Sites may contain electronic images known as web beacons that allow us to count the number of users who have visited those pages. These collect only limited information such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These web beacons do not carry any personal Information and you cannot opt-out or refuse them. However, where they operate with cookies, you can render them ineffective by opting out of cookies or changing the cookie setting in your browser.

Advertisements: We might use third party service providers to serve and host our advertisements. You may receive our ads on these third-party sites. These third parties use persistent cookies to track the number of times our site is accessed and whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain Personal Information and may remain on your hard drive for three or more years unless you delete them. If you do not want Personal Information about you used for this purpose, you may opt out by following the procedure described below. Note, however, that where we use a third party to provide advertising, email marketing or similar services, each such third party will have its own opt-out process, which it will manage and control. You will need to follow those procedures to opt out of the services they provide.

OUR USE OF PERSONAL INFORMATION

We may use the Personal Information provided or obtained through the Sites to:

Tailor your user experience.
Communicate with you by email, regular mail, telephone, or mobile devices, about services that may be of interest to you.
Process applications for employment.
Develop and deliver a newsletter.
Enforce our Terms.
Manage our business.
Notify you of changes to our services.
Send you the information you have requested.
Perform research and analysis about your use of, or interest in, our services, or content.
Perform functions as otherwise described to you at the time of collection.
In connection with the processing of your requests for information; and
In connection with the processing and fulfillment of services you purchase.

We generally store Personal Information in the United States as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, as we determine is necessary for business records, and as required under applicable law. However, we may transfer your Personal Information from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our business. By providing any information to Northshore, you consent to such transfer, storage, and processing.

Disclosure of Personal Information to Third Parties

General: We do not share the Personal Information provided or obtained through the Sites with third parties, except as described below and as otherwise specified in this Policy. We may share Personal Information as follows:

With other third parties that perform services or functions on our behalf. We do not authorize such third parties to use your Personal Information for any other purposes. With the third parties that perform(s) maintenance and operation of the Sites on our behalf. These parties are bound by a confidentiality agreement prohibiting the unauthorized disclosure and/or use of your Personal Information.
As we believe is necessary to comply with applicable laws, statutes, or regulations, and/or to enforce this Privacy Policy and the Terms and to protect our rights and the rights of others.
With third parties, such as social sites (including Facebook and Instagram), to which you subscribe in order for you to link to them through our site and view our content through those sites.
As required by a court or government agency or to respond to a claim by you or a third party.
As part of a transfer of our assets, for example in the event of a merger, acquisition, corporate change or, in the unlikely event of a bankruptcy, involving Northshore.
As you may otherwise request or agree.

Affiliates: We share much of our data, including Personal Information about you, with our affiliated entities and joint ventures when it is reasonably necessary for the purposes otherwise permitted in this Privacy Policy. This includes the owners of the Properties we manage or operate.

Service Providers: We use third party service providers to provide specific business support services to us which may involve limited access to Personal Information. We require these companies to use the information only to provide the contracted services and prohibit them from transferring the information to another party except as needed to provide the contracted services. Examples of such services include sending emails, conducting, and administering promotions, executing surveys, providing customer service, performing business analysis, and processing payments. When we employ another company to perform a function for us, we only provide them with the information that they need to perform their specific function. We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.

Business Transactions: We may disclose your Personal Information as part of any merger, sale of company assets or acquisition, as well as in the event of insolvency, bankruptcy, or receivership. The recipient of Personal Information following such actions may have privacy policies that differ from those in this Policy. You will be notified via email and/or a prominent notice on the website, and you may opt- out of the use of your existing information in a new manner.

Other purposes: We may use and share Personal Information for other purposes with your consent.

Disclosure: Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at [email protected].

Other Privacy Policies: Any third parties to whom we may disclose Personal Information may have their own privacy policies that describe how they use and disclose Personal Information. Those policies will govern the use, handling, and disclosure of Personal Information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

CHILDREN

The Sites are not directed at children, and we do not knowingly collect Personal Information directly from users under the age of 13 or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly request or collect Personal Information from any child under age 13 without obtaining the required parental consent.

CORRECTIONS AND UPDATES

If you want to view your Personal Information, or delete or modify such information that is inaccurate, you may do so by sending an email to [email protected]. In making modifications you must provide only truthful, complete, and accurate information. We may limit your right to make changes to Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the legitimate interests of other persons may be violated.

Please note that notwithstanding your request to change or delete Personal Information, we may be required to keep this information and not modify or delete it, or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from the active database, but may remain in our archives. In some instances, however, Personal Information that you requested to be removed may be retained in certain files for a period of time in order to troubleshoot problems. In addition, some types of Personal Information may be stored indefinitely on back-up systems or within log files due to technical constraints or financial or legal requirements. Therefore, you should not always expect that all of your Personal Information will be completely removed from our databases in response to your request.

In addition to deleting Personal Information, you may choose to opt-out of receiving future newsletters, promotions, or any other email communications from us by following the unsubscribe instructions included in the communications, or by contacting us via email as provided above. All promotional emails from us include an opt-out link which can be processed within 24 hours. You may also opt-out of promotions by sending us an email in response with “unsubscribe” or “opt-out” in the subject line of the email. Opting out of promotional communications does not affect our communications with you via telephone or email related to any business we may have with you or other transactional emails.

We reserve the right to verify the identity of any person making a request to opt-out or to delete or modify incorrect Personal Information, to charge you a fee before providing access and to deny such requests, except as prohibited by law; provided, however, that we will have no liability of any kind resulting from false or erroneous requests or any change or deletion we make for any reason.

STORING YOUR PERSONAL INFORMATION

We will retain the Personal Information you give us or we collect for as long as you maintain your User Account or subscription to our newsletters or other content, participate in any of the features on the Sites, enter any promotions or use any of our other Services, and for a reasonable time thereafter. We will retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Otherwise, we will retain Personal Information for up to twenty- four (24) months and thereafter may store it in aggregate. If you would like us to delete the Personal Information you have provided to us, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of this information may be required in order for you to make use of services and features available via the Sites. If you remove this information, you may no longer be able to use these features.

SECURITY

We utilize a combination of reasonable physical and electronic security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. While we strive to safeguard your Personal Information, we cannot guarantee or warrant the security of any information you disclose or transmit to us.

SOCIAL MEDIA

The Sites may include social media features, such as the Facebook Like button, and widgets such as the “Share” button or interactive mini programs that run on the Sites. These features may collect your IP address, which page you are visiting on the Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy policy of the company providing each feature.

THIRD PARTY WEBSITES

The Sites may contain links to other websites. We do not control, and make no representations whatsoever regarding, such other websites or the products and services offered by or through websites accessed through links on the Sites, even those with which we may have an affiliation. If you decide to access third party websites linked through the Sites you do so at your own risk. You should carefully review the privacy policy and terms of these websites.

COMMERCIAL ELECTRONIC MESSAGE CONSENT

By providing your email address to us through the Sites, you affirmatively and expressly consent to receiving commercial emails from Northshore, and those parties that process email communications on our behalf. Northshore and these third parties may send you commercial emails in order to deliver the Newsletter, to provide you with more information about available services you have purchased, and to provide you with updates, and other information, including but not limited to Site updates.

If you have any questions about this Privacy Policy or our privacy practices, contact us at [email protected]. We will respond to your request within 30 days.

HOW TO EXERCISE YOUR RIGHTS

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Email us at [email protected];
Mail us at 1718 Capitol Ave. Cheyenne, WY 82001.

When you contact us, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number, and country and/or state of residence);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change or modify this Privacy Policy as we deem necessary or appropriate due to changes in our business practices or changes in the law. If you have provided us with your email address, we will attempt to notify you by that address of any material changes to how we use your Personal Information.

CALIFORNIA PRIVACY RIGHTS

The following provisions apply to residents of the State of California.

Under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s Personal Information to a third party and knows or should have known that such third party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared.

Any request for a disclosure required under this California law should be sent to us via email at [email protected] or via regular mail at 1718 Capitol Ave. Cheyenne, WY 82001.

Please note that under this law, you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period and we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above. The California Consumer Privacy Act of 2018 (“CCPA”) provides you with specific rights regarding your Personal Information, including information that could be linked with or used to identify your household. You have the right under the CCPA and certain other privacy as data protection laws, as applicable, to exercise the following rights free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

The categories of Personal Information we have collected about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purpose for collecting or selling Personal Information;
The categories of third parties with whom we share Personal Information, if any; and
The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained.
Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
Provide the Personal Information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any Personal Information, we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
The categories of Personal Information that we disclosed about you for business purposes.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your Personal Information from our records; and
Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary to:

Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with an existing legal obligation; or
Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

Deny goods or services to you.
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
Provide a different level or quality of goods or services to you; or
Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

“Do Not Track”

Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. We support and honor “Do Not Track” web browser settings. If you enable Do Not Track settings in the browser you are using, we will not collect, store, or use Personal Information about websites you visit using that browser other than www.Northshore.com and our other Sites. Other parties, however, may not honor Do Not Track signals. These parties may collect Personal Information about your online activities over time and across different web sites when you visit the Sites, for example by using cookies on our Sites. We have no access to or control over other parties’ Personal Information collection practices, even those with which we may have an affiliation. You should carefully review the privacy policy and terms of any website you visit. For more information about Do Not Track, please visit www.allaboutdnt.org.

INTERNATIONAL VISITORS

The Sites are hosted in and provided from the United States and are intended for those visiting the United States. If you use the Sites from the European Union (EU), Canada, or other countries or regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States for storage and processing. The United States does not have the same data protection laws as the EU, Canada, and other countries or regions.

EU PRIVACY RIGHTS

The Sites are directed at consumers in the United States and the Properties we own or operate are located in the United States. In most cases, the Personal Information we collect is stored and used in the United States.

While we do not direct our Services to residents of the EU, it is possible that EU residents may access and use the Sites. If we collect Personal Information from EU residents in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:

Basis for Collection: As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection. For example, we collect Personal Information when you elect to participate in one of our promotions. We also collect and process Personal Information in order to improve our Services, to deliver Services and perform obligations under contracts we have with you, and to comply with our own legal obligations.

Sensitive Data: We do not collect sensitive data, (as defined in General Data Protection Regulation 2016/679) for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to the Sites.

Onward Transfer: Except as otherwise provided in this Privacy Policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide Services or to perform tasks on our behalf or under our instruction. All such third parties must agree to use such Personal Information we provide to them only the purposes for which we have engaged them and they must either: (a) comply with the EU-US Privacy Shield Principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Information; or (b) agree to provide adequate protections for the Personal Information that are no less protective than those set out in this Privacy Policy. Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.

Authorized Transfer: We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.

Data Processors: We may retain third parties to process or analyze Personal Information we collect from the Sites. For example, a Site may be maintained or hosted by a third-party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler. These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize.

Profiling: We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use Personal Information about you to detect and reduce fraud and credit risk.

Your Rights: Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have any incorrect part of the Personal Information about you corrected or removed. If you wish to exercise any of these rights, send an email to us at [email protected].

If you request to have incorrect Personal Information removed, we may retain some of your Personal Information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with the Privacy Shield Principles. Any Personal Information you have shared publicly with others may continue to be publicly visible on the Sites.

You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a reasonable fee for this depending on the nature and frequency of your request(s) and our cost to provide the information.

Questions and Complaints: If you have questions or complaints regarding this Privacy Policy or our handling of Personal Information about you, you can exercise your rights or contact us as described above.

Enforcement and Disputes: We commit to resolve complaints about your privacy and our collection or use of your Personal Information in a timely and reasonable manner. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at [email protected].

In addition to the above, you may lodge a complaint with your home data protection authority and can invoke binding arbitration for residual claims not resolved by other redress mechanisms. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.