Privacy Policy

Your privacy is important to Navigator Wealth Fund LLC and its affiliates (“Navigator Wealth Fund”, “we”, “us”, “our”). This Privacy Policy applies to our websites (including www.navwf.com, www.investor.avestorinc.com/navigatorwealth, www.starcmg.com, and www.spireinvestmentproperties.com) (together, our “Sites”). The purpose of this Privacy Policy is to disclose to you what Personal Information we may collect, how we may collect it, with whom we may share it, and certain other matters related to such information, including the choices you have regarding our collection of Personal Information and our use and disclosure to other parties of Personal Information we may have collected from you.

Please read this Privacy Policy carefully before using the Sites. We want you to be fully aware of how your Personal Information is collected and used because we appreciate the trust you have placed in us. By using the Sites or otherwise providing Personal Information to us, you consent to Navigator Wealth Fund’ data collection, use, processing, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy notices that may be posted on an applicable part of the Sites. If you do not agree and consent, please discontinue use of the Sites and do not submit any Personal Information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated. The chart below summarizes the types of Personal Information we may collect from you and why we collect it:
Category       of       Personal Information Examples Purpose(s) for    Collection, Use, and Disclosure
Contact Information Name, telephone number, e- mail address, home or business mailing address
  • To register you when you access certain areas of our Sites that require registration
  • To provide you more information about our
  • products or Sites if you request it.
Other Identifiers Username and password for our Sites, security question/answer combinations, IP address
  • To maintain your account with us
  • To recognize you when you use our Sites
  • To show you relevant ads while you browse the internet or use social media
  • To allow you to participate in promotions, sweepstakes, and contests
  • To detect and prevent fraud against you and/or us
Commercial Information Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, information from surveys, promotions and product reviews
  • To provide you with appropriate products and recommendations
  • To help you find relevant products more quickly
  • To provide customer service and support
  • To allow you to participate in                    promotions, sweepstakes, and contests
  • To improve our Sites, products, marketing and advertising
Internet or Other Electronic Network Activity Information

Browser type and language, operating system or internet network  provider,  website access time, duration of visit, referring  website  address,

  • To provide you with a better website or app experience
  browsing and search history, webpages                     viewed immediately before and after our Sites, information related to your interactions with our Sites, social media pages, emails, online chat, text message communications, and advertisements
  • To provide you with appropriate products and recommendations
  • To show you relevant ads while you browse the internet or use social media
  • To improve our Sites, marketing, and advertising
  • To allow you to participate in                    promotions, sweepstakes, and contests
  • To detect and prevent fraud against you and/or us
Geolocation Data Your physical location based on information you provide directly or inferred from your IP address
  • To tailor content, marketing, or advertising
Audiovisual Information Audio data collected when you call our customer service numbers
  • To    provide you with customer service
  • To improve our products and our Sites
Communications with Us The contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our blog and social media pages)
  • To communicate with you, including about our products, to provide answers to your questions, and to obtain your feedback
  • To provide customer service and support
  • To maintain product warranties
  • To improve our Sites, products, and marketing
  • To allow you to participate in                    promotions, sweepstakes, and contests
  • To detect and prevent fraud against you and/or us
Inferences About You from Any Other Category of Information We Collect
Information reflecting your preferences, characteristics, trends, or attitudes

  • To provide you with appropriate products and recommendations
  • To improve our Sites, products, and marketing
  • To provide you with a better website experience
  • To detect and prevent fraud against you and/or us
In addition to the information identified above, like many websites, we use “cookies,” and may use analytics, and other tracking technologies to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them.
We monitor website traffic using analytics tools, such as those offered by Google, and have enabled features that allow us to collect anonymous demographic data, such as data made available via the DoubleClick cookie. We make no attempt to merge Personal Information with non- personally identifiable information under any circumstances, and that applies to data collected from any source, such as the demographic data available by the DoubleClick cookie. We use demographic and interest reporting data to evaluate whether the content of our Sites is attracting our target audience. If you choose, you may opt out of providing this anonymous demographic information using tools that Google makes available, such as the Google Ads Settings or Google’s currently available opt outs for the web.
Your personal information is not used for other purposes, unless we obtain your consent, or unless otherwise required or permitted by law or professional standards. Our goal is to collect and use only that information that we think is necessary for our legitimate business interests.

HOW DO WE COLLECT PERSONAL INFORMATION?

We collect your Personal Information through various means, including when you directly provide it to us and automatically through your use of our Sites. We may also collect Personal Information about you from our service providers and from third parties. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Sites.
We may collect Personal Information like name, telephone number, e-mail address, home or business mailing address, when you access certain areas of the Sites that require registration, or if you request more information about our products. We may also collect Personal Information from you when you enter a contest or sweepstakes, respond to a survey or communication such as e- mail, or participate in another feature on our Sites.
We may also automatically collect certain Personal Information about you when you access or use the Sites (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, and information about your use of the Sites.
The methods used to collect Usage Information include:

  • Log Log information is data about your use of the Sites, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
  • We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our Sites, including information about your browsing behavior. Our Sites also support third-party cookies placed by our service providers, affiliates, and advertising partners.
Our service providers may collect Personal Information on our behalf in the course of providing their services to us. For example, when you place an order through one of our delivery partners, the delivery service may provide us with information about you and your order. We also may obtain your Personal Information from our affiliates. In some circumstances, we obtain Personal Information about you from business partners, retailers and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use the Personal Information we collect from you when you enter a contest or promotion, respond to a survey or marketing communication, surf the Sites, or use certain other features on the Sites in the following ways:

  • To personalize your Site experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To allow us to better service you in responding to your customer service
  • To administer a contest, promotion, survey or other features on our Sites. Your Personal Information may be used to contact you for winner notification, prize delivery confirmation or other related purposes (see the rules of each contest for details about how your Personal Information will be used).
  • If you have opted-in to receive our e-mail newsletter, we may send you periodic e- mails. If you would no longer like to receive promotional e-mail from us, please refer to the “Your Choices” section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other Site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.

HOW DO WE SHARE YOUR PERSONAL INFORMATION?

We do not sell, trade, or otherwise transfer your Personal Information to outside parties, except as described in this Privacy Policy, or unless we provide you with advance notice.
We may disclose your Personal Information for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we share Personal Information with the following parties:

  • Within our group of companies including with our affiliates, brands,
  • With our agents, retailers, vendors, consultants, and other service providers (collectively, “Service Providers”) in order for them to provide their services to us. For example, we may share your Personal Information to provide customer service, operate and improve our business, Sites, improve our products and customer service, help run our promotions, perform marketing and advertising services on our behalf, perform auditing and quality control, to communicate with you, and to otherwise operate our business.
  • With third parties for marketing purposes, to improve our products and Sites, or to provide you with other products that may interest you
  • With our advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
  • As necessary, for the following purposes: (1) to comply with any legal process; (2) to respond to requests from public and government authorities; (3) to enforce our terms and conditions; (4) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (5) to allow us to pursue available remedies or limit the damages that we may sustain.
  • With our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising, or defending against legal claims, etc.
  • With third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Notwithstanding our efforts, the internet and online services have inherent security risks. You should take care with regard to how you handle and disclose your Personal Information or any username or password that you are required to use to access our Sites.
Notwithstanding our efforts, the internet and online services have inherent security risks. You should take care with regard to how you handle and disclose your Personal Information or any username or password that you are required to use to access our Sites.

DO WE USE “COOKIES”?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables our Sites’ or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current website activity, which enables us to provide you with improved Sites. We also use cookies to help us compile aggregate data about website traffic and website interaction so that we can offer better site experiences and tools in the future.
We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (Internet Explorer or Google Chrome) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your site experience more efficient and some of our Services will not function properly. For more information about cookies, visit: http://www.allaboutcookies.org.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (Internet Explorer or Google Chrome) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your site experience more efficient and some of our Services will not function properly. For more information about cookies, visit: http://www.allaboutcookies.org.

YOUR PERSONAL INFORMATION RIGHTS

As a current or prospective customer, you have a number of rights with respect to your Personal Information collected by Navigator Wealth Fund. These rights, subject to applicable law, include:
  • Right to Access/Know: You have the right to request what Personal Information we have collected, used, shared for a business purpose, and sold about you.
  • Right to Rectification: You have the right to correct inaccurate or incomplete Personal
  • Right to Deletion: You have the right to request the deletion of some or all the Personal Information that we collected about you, for example where the information is no longer necessary for business purposes, subject to certain exceptions.
  • Right to Opt-Out of Sale or Sharing of Personal Information: You have the right to opt-out of the sale of your Personal Information by us to third parties for monetary or other valuable You also have the right to opt-out of the “sharing” of your information relating to online targeted advertising (or cross-context behavioral advertising).
  • Right to Object: You have the right to object to the processing of your Personal Information where Navigator Wealth Fund is relying on its legitimate interests.
  • Right to Non-Discrimination: Navigator Wealth Fund will not discriminate against those who exercise their Specifically, if you exercise your rights, we will not deny you goods or services, charge you different prices or rates for goods or services or provide you a different level or quality of goods or services. You are not obliged to provide the Personal Information as may be required by us. If you do not provide the information requested, we may be unable to process your requests or provide you with our products and services or information, sales and marketing materials.
To exercise your privacy rights, submit a request by e-mail to Michael@navwf.com and Jeremy@navwf.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you live in a state or country that gives you enhanced privacy rights – such as the California Privacy Rights Act (CPRA) – we will respond to all requests as required by law. If you live in a state or country that does not give you enhanced privacy rights, we will respond to all requests at our earliest opportunity.

YOUR CHOICES

To unsubscribe from our marketing-related e-mails, please select the unsubscribe link in the footer of the e-mail. If you opt-in for particular services or communications, you will be able to unsubscribe at any time by following the instructions included in each communication.
Please note that due to email production schedules you may receive any e-mails already in production. Also, if you request your registration information be deleted or you opt-out of other communications, we may maintain information about an individual service inquiry for future service and record keeping purposes.
Please note that due to email production schedules you may receive any e-mails already in production. Also, if you request your registration information be deleted or you opt-out of other communications, we may maintain information about an individual service inquiry for future service and record keeping purposes.
Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

DO NOT TRACK

Our Sites do not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (e.g, by disabling cookies).

THIRD-PARTY LINKS

Please be aware that our Sites contain links to other websites. These linked sites have separate and independent privacy policies. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. Nonetheless, we seek to protect the integrity of our Sites and welcome any feedback about these linked sites (including if a specific link does not work).

DATA RETENTION

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. This generally means we will retain your Personal Information for as long as one of the following apply:

  • Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
  • Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
  • Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; or
  • We are otherwise required or permitted to keep your information by applicable laws or

INTERNATIONAL VISITORS

Navigator Wealth Fund is headquartered in the United States. If you access the Sites from outside of the U.S., please be aware that Personal Information collected through the Sites may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Sites or provision of any Personal Information constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. as set forth in this Privacy Policy.
Applicable legal and regulatory requirements are taken into consideration before any cross border transfer of your Personal Information. Navigator Wealth Fund will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

CHILDREN’S PRIVACY

Our Sites are not intended to be used by children. We do not knowingly solicit or collect any Personal Information about children under the age of sixteen (16) nor knowingly allow children to order our products, communicate with us, or use any of our Sites. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have that
Our Sites are not intended to be used by children. We do not knowingly solicit or collect any Personal Information about children under the age of sixteen (16) nor knowingly allow children to order our products, communicate with us, or use any of our Sites. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have that
Navigator Wealth Fund does not have actual knowledge that it sells Personal Information of minors under the age of sixteen (16) years.

CALIFORNIA RESIDENTS

This section supplements the other parts of our Privacy Policy, and provides additional information for California residents pursuant to applicable California laws and regulations. If you are a job applicant or employee, please see the California Associate Privacy Notice to learn more about your California privacy rights.

What Personal Information Do We Collect?

The Personal Information we collect about you, the sources from which we collect it, and how we use and disclose it are described elsewhere in this Privacy Policy. Below we identify the Personal Information categories defined by the California Consumer Privacy Act (“CCPA”) that Navigator Wealth Fund collected from users of its Sites in the preceding 12 months.
Personal Information Collected Examples Collected
Identifiers Name, home or business mailing address, telephone number, email address, username and password for our Sites, security question/answer combinations, Internet Protocol address, Yes
Personal Information categories listed in the CCPA Name, home or business mailing address, telephone number Yes
Characteristics of protected classifications under California and federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) No
Commercial Information Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, information from surveys, promotions and product reviews Yes
Biometric Information Audio data collected when you call our customer service numbers Yes
Personal Information Collected Examples Collected
Internet or other similar network activity Browser type and language, operating system, internet network provider, website access time, duration of visit, referring website address, browsing and search history, webpages viewed immediately before and after our Sites, information related to your interactions with our Sites, social media pages, emails, online chat, text message communications, and advertisements, the contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our social media pages) Yes
Geolocation data Your physical location based on information you provide directly or inferred from your IP address Yes
Sensory data Audio data collected when you call our customer service numbers Yes
Professional or Employment-Related Information Current or past job history or performance evaluations No
Non-Public Education Information Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records No
Inferences Drawn from Other Personal Information Information reflecting your preferences, characteristics, trends, or attitudes Yes

Rights Under the CCPA

As set forth elsewhere in this Privacy Policy, you have a number of rights with respect to your Personal Information collected by Navigator Wealth Fund. If you are a California resident, you also have the following rights:
  • Right to Know: You have the right to request more information regarding (1) the categories and/or specific pieces of Personal Information we have collected about you, (2) the categories of sources for that Personal Information, (3) the purposes for which the we use that information, (4) the categories of third parties to whom we disclosed the information, and (5) the categories of information that we sell or disclose to third parties.
  • Right to Limit Use and Disclosure of Sensitive Personal Information. You may direct us to limit the use and disclosure of your Sensitive Personal Information (e.g., an account log-in; contents of mail, email, and text messages; biometric information processed to identify a consumer) to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices.
We will not share any Personal Information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless we have received your prior written consent.

CHANGES TO OUR POLICY

Navigator Wealth Fund reserves the right to amend this Privacy Policy and each of our Privacy Notices at our discretion and at any time. If the changes allow us to use Personal Information in ways that materially affect your rights, we will post a special note on our digital platforms and, if required by law, will prompt you for your consent for certain changes. When we make changes to this Privacy Policy or any of our Privacy Notices, we will post the updated Privacy Policy or Privacy Notices and update the “Last Updated” date. Each version of this Privacy Policy and any of our Privacy Notices will be identified by their Last Updated date.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue by e-mail to michael@navwf.com and jeremy@navwf.com.