SMS PRIVACY & DATA PROTECTION POLICY
NorthStar Asset Management, Inc.
NorthStar Asset Management, Inc. (“NorthStar”, “NorthStar Asset Mgmt.”) is committed to safeguarding personal data collected through our SMS communications. This SMS Privacy and Data Protection Policy serves to assure compliance with global data protection laws such as the General Data Protection Regulation (GDPR), Telephone Consumer Protection Act (TCPA), and other applicable regulations, specifically addressing the unique aspects of data handling within SMS services.
How we use SMS
NorthStar does not use SMS for marketing purposes or promotional purposes. SMS is used only for as-needed communications with clients, prospective clients or third parties (consultants, vendors, etc). The nature of these communications is informational in nature and not meant to replace regular email or phone communication.
Collection of Phone Numbers
For clients:
– We collect your phone number{s} at the time you onboard with us to be your investment manager.
– Clients opt-in to receive text messages when they sign our client management agreement and provide us with their mobile phone number(s). The management agreement requires that a phone number be entered and that the client check a box agreeing to receive SMS messages.
– The agreement states that the client may opt out of SMS by texting STOP to any message. Upon our first contact, we ask our clients if they want to keep receiving text messages from us. Clients are directed to our privacy policy (https://northstarasset.com/nsam-sms-privacy-policy/) and SMS Terms & Conditions (https://northstarasset.com/nsam-sms-terms-conditions/), which state that no information will be shared with third parties for marketing purposes.
For prospective clients / third parties:
– Recipients message us first after getting our number from our website located at https://northstarasset.com/ or in the signature of our emails. We do not initiate SMS communications before being contacted first. It is at this time we collect your phone number.
– Upon our first contact, we ask our clients and third parties if they want to keep receiving text messages from us.
– Our website contains our privacy policy (https://northstarasset.com/nsam-sms-privacy-policy/) and SMS Terms & Conditions, which state that no phone number or consent is shared with third parties (https://northstarasset.com/nsam-sms-terms-conditions/)
– You may opt out of SMS communication in written communication to us or by texting STOP.
Information we Collect
This includes mobile phone numbers, text message content, account information, transaction details, and, depending on the context, may include other personal identifiers.
How we Use Your Information
Personal data collected via SMS will only be used to:
– Provide you with financial information and services
– Respond to your inquires and provide customer support
– Send important account-related updates
– Provide timely customer support
– Ensure compliance with applicable laws and regulations.
Sharing your Information
– We do not share your information with third parties, except when required by law, such as responding to a legal request, court order, or governmental agency.
– SMS consent and phone numbers will not be shared with third parties or affiliates for marketing purposes.
Consent
By using our SMS services, you consent to the terms and conditions outlined in this SMS Privacy Policy. If you do not agree with these terms, please refrain from using our SMS services. Message and data rates may apply.
Unsubscribing from SMS messages:
Subscribers can opt out of receiving SMS messages at any time by:
– Replying with the word “STOP” to any of our SMS communications.
– All Parties: Requesting in writing to info@northstarasset.com not to be contacted by SMS.
– Clients only may also request directly to our client services team or investment advisor (clientservices@northstarasset.com) in writing not to be contacted by SMS.
Managing subscriber list
– We ensure that all individuals on our subscriber list have agreed to receive messages. Regular checks are conducted to maintain compliance with legal standards.
– We maintain the accuracy of our subscriber lists by updating them regularly to remove opt-outs and correct any errors in subscriber information.
– All subscriber data is securely stored and protected against unauthorized access, use, or disclosure.
– Once you have opted out, we will not send you any more SMS messages, nor will we sell or transfer your phone number to another party.
Protection measures
Strong security measures, including encryption and secure data storage, are implemented to protect data from unauthorized access or breaches.
Data subjects have the right to:
– Access, correct, and request the deletion of their personal data.
– Withdraw consent at any time by opting out of SMS communications.
– Lodge a complaint with a data protection authority if they believe their data is not being handled appropriately.
In the event of a data breach, NorthStar will promptly notify affected individuals and relevant authorities, providing details of the breach and any actions taken to address it.
Changes to this Policy
NorthStar will regularly review and update this policy to comply with new regulations and ensure the highest level of data protection. Compliance with this policy will be monitored and enforced by the COO.
This policy will be reviewed and updated annually or as needed to meet regulatory requirements and address emerging privacy challenges.
Contact Us
If you have any questions or concerns, please contact us at:
617.522.2635
Effective: 27 November 2024