Northstar Commercial Partners (“NCP,” “we” or “us”) is committed to safeguarding the personal information that you provide to us. This Privacy Policy describes how we handle and protect the personal information we collect about individuals who use our website, applications or services. If you have any questions that this policy does not address, please contact us at support@northstarcp.com or (303)893-9500.

As explained below, we collect information from you in various ways when you interact with our website. By using our website, you consent to our collection and use of information as explained in this Policy and agree to be bound by our Terms of Use. Please note that if you choose to invest in any NCP offering promoted on our website, you may be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use.

COLLECTION OF INFORMATION

NCP collects non-personally identifiable information from you regarding your usage of our website (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your computer, search criteria used and results, date, time, connection speed, and other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communication and interaction with that website. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

NCP also collects information from you when you sign up for an account, make an investment, verify your identity or accredited investor status, provide payment instructions or send us an email through the NCP website which may enable us to identify you personally, such as your email address, name, phone number, birthday, age, Social Security number and/or taxpayer identification number, assets and income, information from your transactions with us, such as your account balance and account usage, information obtained from others, such as the Internal Revenue Service and credit reporting agencies, physical address such as home or business address, or internet protocol (“IP”) address, which may also be contained on server logs, or other information you provide or upload to the website, answers to questionnaires or surveys, or responses filled in on blank forms made available on the site. (“Personally Identifiable Information” and collectively with the Non-Personally Identifiable Information, the “Data”)). We may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.

We use analytics programs and service providers that can use first party cookies to report on your interactions with the NCP website. These programs collect information including, but not limited to, the time of each of your visits to the NCP website, whether you have visited the NCP website before, what site referred you to the NCP website, and what pages you viewed on the NCP website.

This Privacy Policy does not cover the collection of information by cookies or other methods by third parties, such as our business partners. We do not control how such third parties collect information or by what means as such third parties may use their own cookies to collect information about you.

USE OF INFORMATION

NCP uses the Data you provide in a manner that is consistent with this Privacy Policy. If you provide Data for a certain reason, we may use the Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Data you provide to answer your question or resolve your problem. Also, if you provide Data in order to obtain access to our services, we will use your Data to provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.

NCP will use your Data (1) to market our products and services to you, (2) to provide services and products requested by you, (3) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our website and other services, (4) to meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members, (5) to engage in any other lawful activities we believe are consistent with the foregoing, and (6) to protect against legal liability. We may provide any of these services through third parties, which may necessitate sharing your Data with them.

NCP and its affiliates (the “Affiliated Companies”) may also use your Data collected through the Site to help us improve the content and functionality of the Site, to better understand our users and to improve our services. NCP and its Affiliated Companies may use this information to communicate with you regarding our services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as user of our service we will send you administrative communications that are reasonably necessary. If NCP or its Affiliated Companies intend on using any Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Data is collected.

OUR DISCLOSURE OF YOUR DATA AND OTHER INFORMATION

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Related Companies: We may also share your Personal Data with our Affiliated Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: NCP, like many businesses, sometimes hires other companies to perform certain business-related services. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, sending postal mail and e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your Data. These companies are authorized to use your personal information only as necessary to provide these services to us.

Legal and Regulatory Requirements: NCP may disclose your Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal or regulatory obligation, (ii) protect and defend the rights or property of NCP, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability.

YOUR CHOICES

If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, by emailing our Customer Support at support@northstarcp.com or by contacting us at the contact information listed below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

When you sign up for our services, we may send periodic emails to you regarding our services or to tell you about services we believe will be of interest to you. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at unsubscribe@northstarcp.com .   Please note that opt-out requests may take up to two (2) weeks to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

NCP does not and will not sell any of your Personally Identifiable Information to any third party for purposes of advertising, soliciting, or telemarketing.

THIRD PARTY WEBSITES AND SERVICES

The NCP website may contains links to other websites and services not maintained by NCP. In addition, other websites and services may also reference or link to the NCP website. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

MESSAGING

The NCP website may permits users to communicate with companies and other users posting information on the website. We may read, collect and analyze information transmitted between users for regulatory compliance and marketing purposes. However, as explained in our Terms of Service, we rely on the affirmations of investors that they are “Accredited Investors” as defined in the Terms of Service. We do not guarantee that information provided by website visitors or investors is accurate or complete. NCP assumes no liability or responsibility for any errors or omissions in the content of its website.

EXCLUSIONS

This Privacy Policy does not apply to any Data collected by NCP other than Data collected through the website. This Privacy Policy shall not apply to any unsolicited information you provide to NCP through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and NCP shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

BLOG

Our website offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at support@northstarcp.com , we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

SOCIAL MEDIA FEATURES

Our website may include social media features such as the Facebook “Like” button, Twitter, and other “share this” buttons. These features are interactive mini-programs and may collect your IP address, which page you are visiting on our site, 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 our website. Your interactions with these features are governed by the privacy policy of the company providing it.

SECURITY

We use reasonable efforts to secure access to Personally Identifiable Information in our possession, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Personally Identifiable Information is also stored with third parties who have informed us that they also use reasonable efforts to secure access to Personally Identifiable Information, but we will not be liable for the failure of any third party to safeguard Personally Identifiable Information, whether inadvertent or otherwise.

We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer; however, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer.

CHILDREN’S PRIVACY POLICY

The NCP website is not intended for use by children. No one under eighteen (18) years of age is allowed to use the site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children or teenagers under the age of thirteen (18). If you believe that a minor has disclosed Personally Identifiable Information to NCP, please report this to us immediately by emailing us at: support@northstarcp.com .

CHANGES TO THIS PRIVACY NOTICE

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Policy at any time. Any changes or updates will be effective immediately upon posting to the website and sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our website following the posting of any changes to this notice means you accept such changes.

APPLICABLE LAW AND JURISDICTION

The NCP website is maintained in the United States of America. By accessing the NCP website, you consent to and authorize the export of Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Notice.

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Illinois applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the Colorado State Courts located in the county of Denver, CO or the federal district court for the District of Colorado. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

EFFECTIVE DATE

This Privacy Notice was last updated on May 4, 2017.