Terms and Conditions

Please read these Terms and Conditions carefully before using this Website.

Terms and Conditions The Website and its Content is owned by Spire Investment Properties LLC (“Company”, “we”, or “us”). The term “you” refers to the user or viewer of our Website.

Please read these Terms and Conditions (“T&C”) carefully. We reserve the right to change these Terms and Conditions on the Website at any time without notice, and by using the Website and its Content you are agreeing to the T&C as they appear, whether or not you have read them. If you do not agree with these T&C, please do not use our Website or its Content.

Not an Attorney or Certified Public Accountant (CPA). Michael is not an attorney or CPA and the content of this website has not been reviewed by an attorney or CPA. You should always consult your attorney or CPA.

Real Estate Agency. Michael is a licensed real estate salesperson in the state of MA and affiliated with Jack Gately Real Estate.

Website Use and Consent The words, design, layout, graphics, photos, images, information, materials, documents, data, databases and all other information and intellectual property accessible on or through this Website (“Content”) is our property and is protected by United States intellectual property laws.

If you have purchased a service, program, product or subscription or otherwise entered into a separate agreement with us you will also be subject to the terms of that agreement or those terms of use, which shall prevail in the event of a conflict. Online purchases have additional terms of use relating to the transaction.

By accessing or using this Website and its Content, you represent and warrant that you are at least 18 years old and that you agree to and to abide by these T&C. Any registration by, use of or access to the Website and its Content by anyone under age 18 is unauthorized, unlicensed and in violation of these T&C.

Intellectual Property Rights Our Limited License to You. This Website and its Content is property solely owned by us and/or our affiliates or licensors, unless otherwise noted, and it is protected by copyright, trademark, and other intellectual property laws.

If you view, purchase or access our Website or any of its Content, you will be considered our Licensee. For the avoidance of doubt, you are granted a revocable, non-transferable license for personal, non-commercial use only, limited to you only.

When you purchase or access our Website or any of its Content, you agree that

– You will not copy, duplicate or steal our Website or Content. You understand that doing anything with our Website or its Content that is contrary to these T&C and the limited license we are providing to you herein is considered theft, and we reserve our right to prosecute theft to the full extent of the law.

– You are permitted from time to time to download and/or print one copy of individual pages of the Website or its Content, for your personal, non-commercial use, provided that you give us full attribution and credit by name, keep intact all copyright, trademark and other proprietary notices and, if used electronically, you must include the link back to the Website page from which the Content was obtained.

– You may not in any way at any time use, copy, adapt, imply or represent that our Website or its Content is yours or created by you. By downloading, printing, or otherwise using our Website Content for personal use you in no way assume any ownership rights of the Content – it is still our property.

– You must receive our written permission before using any of our Website Content for your own business use or before sharing with others. This means that you may not modify, copy, reproduce, republish, upload, post, transmit, translate, sell, market, create derivative works, exploit, or distribute in any manner or medium (including by email, website, link or any other electronic means) any Website Content because that is considered stealing our work.

– We are granting you a limited license to enjoy our Website and its Content for your own personal use, not for your own business/commercial use or in any that earns you money, unless we give you written permission that you may do so.

As a Licensee, you understand and acknowledge that this Website and its Content have been developed or obtained by us through the investment of significant time, effort and expense, and that this Website and its Content are valuable, special and unique assets of ours which need to be protected from improper and unauthorized use. We clearly state that you may not use this Website or its Content in a manner that constitutes an infringement of our rights or that has not been authorized by us.

The trademarks and logos displayed on our Website or its Content are trademarks belonging to us, unless otherwise indicated. Any use including framing, meta tags or other text utilizing these trademarks, or other trademarks displayed, is strictly prohibited without our written permission.

All rights not expressly granted in these terms or any express written license, are reserved by us.

Your License to Us. By posting or submitting any material on or through our Website such as comments, posts, photos, images or videos or other contributions, you are representing that you are the owner of all such materials and you are at least 18 years old.

When you submit to us or post any comment, photo, image, video or any other submission for use on or through our Website, you are granting us, and anyone authorized by us, an unlimited, royalty-free, perpetual, irrevocable, non-exclusive, unrestricted, worldwide license to use, copy, modify, transmit, sell, exploit, create derivative works from, distribute, and/or publicly perform or display such contributions, in whole or in part, in any manner or medium, now known or developed in the future, for any purpose, and granting us the right to make it part of our current or future Website and its Content. This right includes granting us proprietary rights or intellectual property rights under any relevant jurisdiction without any further permission from you or compensation by us to you.

You also grant us, and anyone authorized by us, the right to identify you as the author of any of your comments, posts, photos, images, videos or other contributions by name, email address, or screen name. You acknowledge that we have the right but not the obligation to use any contributions from you and that we may elect to cease the use of any such contributions on our Website or in our Content at any time for any reason.

Request for Permission to Use Content Any request for written permission to use our Content, or any other intellectual property or property belonging to us, should be made BEFORE you wish to use the Content by completing the “Contact Us” form on this Website, or by sending an e-mail to [email protected].

We very clearly state that you may not use any Content in any way that is contrary to these T&C unless we have given you specific written permission to do so. If you are granted permission by us, you agree to use the specific Content that we allow and ONLY in the ways for which we have given you our written permission. If you choose to use the Content in ways that we do not specifically give you written permission, you agree now that you will be treated as if you had copied, duplicated and/or stolen such Content from us, and you consent to immediately stop using such Content and to take whatever actions as we may request and by the methods and in the time frame that we prescribe to protect our intellectual property and ownership rights in our Website and its Content.

Personal Responsibility and Assumption of Risk As a Licensee, you agree that you are using your own judgment in using our Website and its Content and you agree that you are doing so at your own risk. You agree and understand that you assume all risks and no results are guaranteed in any way related to this Website and/or any of its Content. This Website and its Content are merely to provide you with education and tools to help you make your own decisions for yourself. You are solely responsible for your actions, decisions and results based on the use, misuse or non-use of this Website or any of its Content.

Disclaimer Our Website and its Content are for informational and educational purposes only. To the fullest extent permitted by law, we expressly exclude any liability for any direct, indirect or consequential loss or damage incurred by you or others in connection with our Website and its Content, including without limitation any liability for any accidents, delays, injuries, harm, loss, damage, death, lost profits, personal or business interruptions, misapplication of information, physical or mental disease, condition or issue, physical, mental, emotional, or spiritual injury or harm, loss of income or revenue, loss of business, loss of profits or contracts, anticipated savings, loss of data, loss of goodwill, wasted time and for any other loss or damage of any kind, however and whether caused by negligence, breach of contract, or otherwise, even if foreseeable. You specifically acknowledge and agree that we are not liable for any defamatory, offensive or illegal conduct of any other Website participant or user, including you. Legal and Financial Disclaimer. This Website and its Content are not to be perceived or relied upon in any way as business, financial or legal advice. The information provided through our Website and its Content is not intended to be a substitute for professional advice that can be provided by your own accountant, lawyer, or financial advisor. We are not giving financial or legal advice in any way. You are hereby advised to consult with your own accountant, lawyer or financial advisor for any and all questions and concerns you have regarding your own income and taxes pertaining to your specific financial and/or legal situation. You agree that we are not responsible for your earnings, the success or failure of your business decisions, the increase or decrease of your finances or income level, or any other result of any kind that you may have as a result of information presented to you through our Website or its Content. You are solely responsible for your results.

Earnings Disclaimer. You acknowledge that we have not and do not make any representations as to the health physical, mental, emotional, spiritual or health benefits, future income, expenses, sales volume or potential profitability or loss of any kind that may be derived as a result of your use of this Website or its Content. We cannot and do not guarantee that you will attain a particular result, positive or negative, financial or otherwise, through the use of our Website or its Content and you accept and understand that results differ for each individual. We also expressly disclaim responsibility in any way for the choices, actions, results, use, misuse or non-use of the information provided or obtained through the use of our Website or its Content. You agree that your results are strictly your own and we are not liable or responsible in any way for your results. Warranties Disclaimer. WE MAKE NO WARRANTIES AS TO OUR WEBSITE OR ITS CONTENT. YOU AGREE THAT OUR WEBSITE AND ITS CONTENTS ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE WEBSITE OR ITS CONTENT WILL BE FUNCTIONAL, UNINTERRUPTED, CORRECT, COMPLETE, APPROPRIATE, OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT ANY PART OF THE WEBSITE, CONTENT ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. WE DO NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF OUR WEBSITE OR ITS CONTENT OR ON THIRD-PARTY WEBSITES IN TERMS OF THEIR CORRECTNESS, ACCURACY, TIMELINESS, RELIABILITY OR OTHERWISE.

Technology Disclaimer. We try to ensure that the availability and delivery of our Website and its Content is uninterrupted and error-free. However, we cannot guarantee that your access will not be suspended or restricted from time to time, including to allow for repairs, maintenance or updates, although, of course, we will try to limit the frequency and duration of suspension or restriction. To the fullest extent permitted by law, we will not be liable to you for damages or refunds, or for any other recourse, should our Website or its Content become unavailable or access to the them becomes slow or incomplete due to any reason, such as system back-up procedures, internet traffic volume, upgrades, overload of requests to the servers, general network failures or delays, or any other cause which may from time to time make our Website or its Content inaccessible to you.

Errors and Omissions. We make no warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information on our Website or its Content. Every effort has been made to present you with the most accurate, up-to-date information, but because the nature of scientific research is constantly evolving, we cannot be held responsible or accountable for the accuracy of our content. We assume no liability for errors or omissions on the Website, its Content, or in other information referenced by or linked to the site. You acknowledge that such information may contain inaccuracies or errors to the fullest extent permitted by law.

Links to Other Websites. We may provide links and pointers to other websites maintained by third parties which may take you outside of our Website or its Content. These links are provided for your convenience and the inclusion of any link in our Website or its Content to any other website does not imply our endorsement, sponsorship, or approval of that website or its owner. We do not endorse and we are not responsible for the views, opinions, facts, advice, statements, errors or omissions provided by external resources referenced in our Website or its Content, or their accuracy or reliability. We have no control over the contents or functionality of those websites and so we accept no responsibility for any loss, damage, or otherwise that may arise from your use of them. It is your responsibility to review the terms and conditions and privacy policies of those linked websites to confirm that you understand and agree with those policies.

Limitations on Linking and Framing. You may establish a hypertext link to our Website or Content so long as the link does not state or imply any sponsorship, endorsement by, or ownership by in our Website or Content and does not state or imply that we have sponsored, endorsed or have ownership rights in your website. However, you may not frame or inline link our Content without our written permission.

Indemnification, Limitation of Liability and Release of Claims Indemnification. You agree at all times to defend, indemnify and hold harmless our Company, as well as any of our affiliates, agents, contractors, officers, directors, shareholders, employees, joint venture partners, successors, transferees, assignees, and licensees, as applicable, from and against any and all claims, causes of action, damages, liabilities, costs and expenses, including legal fees and expenses, arising out of or related to our Website, its Content or your breach of any obligation, warranty, representation or covenant set forth in these T&C or in any other agreement with us.

Limitation of Liability. We will not be held responsible or liable in any way for the information, products or materials that you request or receive through or on our Website and its Content. We do not assume liability for accidents, delays, injuries, harm, loss, damage, death, lost profits, personal or business interruptions, misapplication of information, physical or mental disease, condition or issue, or otherwise, due to any act or default of anyone or any business, whether owners, staff, agents, joint venture partners, contractors, vendors, affiliates or otherwise, affiliated with us. We do not assume liability for any owners, staff, agents, joint venture partners, contractors, vendors, affiliates or otherwise who is engaged in rendering our Website or its Content, or in any way or in any location. In the event that you use our Website and its Content or any other information provided by us or affiliated with us, we assume no responsibility.

Release of Claims. In no event will we be liable to any party for any type of direct, indirect, special, incidental, equitable or consequential damages for any use of or reliance on our Website and its Content, or on those affiliated with us in any way, and you hereby release us from any and all claims; including, without limitation, those related to lost profits, personal or business interruptions, personal injuries, accidents, misapplication of information, or any other loss, physical or mental disease, condition or issue, or otherwise, even if we are expressly advised of the possibility of such damages or difficulties.

Your Conduct You are agreeing that you will not use our Website or its Conduct in any way that causes or is likely to cause the Website, Content, or access to them to be interrupted, damaged or impaired in any way. You understand that you are solely responsible for all electronic communications and content sent from your computer to this Website and its Content and to us.

You agree to only purchase goods or services for yourself or for another person for whom you are legally permitted to do so or for whom you have obtained the express consent to provide their name, address, method of payment, credit card number, and billing information.

You agree to be financially responsible for all purchases made by you or someone acting on your behalf through the Website or its Content. You agree to use the Website and its Content for legitimate, non-commercial purposes only and not for speculative, false, fraudulent, or illegal purposes.

You must use the Website and its Content for lawful purposes only. You agree that you will not use the Website or its Content in any of the following ways:

For fraudulent purposes or in connection with a criminal offense or otherwise carry out any unlawful activity To send, use or re-use any material that is illegal, offensive, abusive, indecent, harmful, defamatory, obscene or menacing, threatening, objectionable, invasive of privacy, in breach of confidence, infringing of any intellectual property rights, or that may otherwise may injure others To send, negatively impact, or infect our Website or its Content with software viruses or any other harmful or similar computer code designed to adversely affect the operation of any computer software or hardware, commercial solicitation, chain letters, mass mailings or any spam, whether intended or not To cause annoyance, inconvenience or needless anxiety To impersonate any third party or otherwise mislead as to the origin of your contributions To reproduce, duplicate, copy or resell any part of our Website or its Content in a way that is not in compliance with these T&C or any other agreement with us.

Online Commerce Certain sections of the Website or its Content may allow you to make purchases from us or from other merchants. If you make a purchase from us on or through our Website or its Content, all information obtained during your purchase or transaction and all of the information that you give as part of the transaction, such as your name, address, method of payment, credit card number, and billing information, may be collected by both us, the merchant, and our payment processing company.

Your participation, correspondence or business dealings with any affiliate, individual or company found on or through our Website, all purchase terms, conditions, representations or warranties associated with payment, refunds, and/or delivery related to your purchase, are solely between you and the merchant. You agree that we shall not be responsible or liable for any loss, damage, refunds, or other matters of any sort that incurred as the result of such dealings with a merchant.

Payment processing companies and merchants may have privacy and data collection practices that are different from ours. We have no responsibility or liability for these independent policies of the payment processing companies and Merchants. In addition, when you make certain purchases through our Website or its Content, you may be subject to the additional terms and conditions of a payment processing company, Merchant or us that specifically apply to your purchase. For more information regarding a Merchant and its terms and conditions that may apply, visit that merchant’s Website and click on its information links or contact the Merchant directly.

You release us, our affiliates, our payment processing company, and merchants from any damages that you incur, and agree not to assert any claims against us or them, arising from your purchase through or use of our Website or its Content.

Termination We reserve the right in our sole discretion to refuse or terminate your access to the Website and its Content, in full or in part, at any time without notice. In the event of cancellation or termination, you are no longer authorized to access the part of the Website or Content affected by such cancellation or termination. The restrictions imposed on you in these T&C with respect to the Website and its Content will still apply now and in the future, even after termination by you or us. If you have any questions about these T&C, please contact us at [email protected].

Privacy Policy

Last Updated: March 2, 2024

 

Your privacy is important to Spire Investment Properties LLC and its affiliates (“Spire Investment Properties”, “we”, “us”, “our”). This Privacy Policy applies to our websites (including www.spireinvestmentproperties.com, www.investor.avestorinc.com/navigatorwealth, and www.navwf.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 Spire Investment Properties’ 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, 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 a better website or app experience ·         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 Information. 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 requests.
• 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, etc.
• 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.

 

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.

 

Your Personal Information Rights

As a current or prospective customer, you have a number of rights with respect to your Personal Information collected by Spire Investment Properties. 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 consideration. 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 Spire Investment Properties is relying on its legitimate interests.

 

• Right to Non-Discrimination: Spire Investment Properties will not discriminate against those who exercise their rights. 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 [email protected]. 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.

 

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 regulations.

 

International Visitors

Spire Investment Properties 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. Spire Investment Properties 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 information deleted from our records. If you believe that we might have any information from a child under the age of sixteen (16), please tell us by emailing [email protected]. We will take all reasonable steps to delete the child’s information as soon as possible except where necessary to protect the safety of the child or others as required by law.

Spire Investment Properties 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 Spire Investment Properties 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
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 Spire Investment Properties. 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

Spire Investment Properties 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 [email protected].