Privacy Policy

PRIVACY POLICY

Northstar Investment Partners (operating as Stoehr Advice LLC)

Northstar Investment Partners, operating as Stoehr Advice LLC, a registered investment adviser (“Northstar,” “we,” “us,” or “our”), has adopted this Privacy Policy out of concern for the privacy of our website users, clients, and visitors (“Users” or “you”) to our website at www.northstarinvestment.com (the “Site”) and in connection with our investment advisory services. This Privacy Policy explains our practices with respect to the collection, use, and disclosure of personal and non-personal information, and is designed to comply with SEC Regulation S-P, SEC Regulation S-ID, the Investment Advisers Act of 1940, the Georgia Personal Identity Protection Act, and applicable wireless carrier and CTIA guidelines governing text message communications. By using the Site or engaging our services, you agree to the terms of this Privacy Policy.

1. INFORMATION WE COLLECT

We may collect the following categories of personal information in connection with providing advisory services to you:

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● Identifying information such as your name, address, date of birth, Social Security number, and government-issued identification

● Financial information such as income, net worth, account balances, holdings, and transaction history

● Contact information such as mailing address, email address, and telephone/mobile number, which we collect directly from you by phone or in person — not through our website

● Information you provide on account applications, advisory agreements, and related forms

● Information about your transactions with us, our affiliates, or others

● Information we receive from consumer reporting agencies, custodians, and other financial institutions

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2. HOW WE USE AND SHARE YOUR PERSONAL INFORMATION

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Consistent with Regulation S-P, we do not sell personal information about current or former clients to third parties. We do not disclose nonpublic personal information about you to nonaffiliated third parties, except as permitted by law or as described below. Where required, we obtain your consent before sharing your personal information with third parties. We may share personal information as follows:

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● With affiliates and service providers who perform services on our behalf (e.g., custodians, portfolio management systems, back-office support), under contractual obligations to safeguard your information and use it only for the purposes for which it was disclosed

● With consumer reporting agencies, to the extent necessary to process a request or verify eligibility

● With regulators, including the SEC and the Georgia Secretary of State, and with law enforcement, in response to subpoenas, court orders, or as otherwise required by law

● With your accountant, attorney, or other professionals, at your direction

● With service providers who support our operations (e.g., compliance consultants, IT providers), under confidentiality obligations

We do not share your personal information with marketing firms, other financial institutions, or affiliates for their own marketing purposes without your prior opt-in consent.

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3. TEXT MESSAGE (SMS) COMMUNICATIONS

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3.1 How We Obtain Consent

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Northstar does not collect phone numbers through its website. Instead, consent to receive text messages is obtained directly from you in one of the following ways:

● Verbal consent during a phone call with a Northstar representative, followed immediately by a text message inviting you to confirm by replying YES. Consent is only treated as given once you reply YES to that message

● You may also opt in by texting us directly. If you text us first, we will reply with a message confirming that you may opt out at any time and directing you to this Privacy Policy and our SMS Terms and Conditions

Consent to receive text messages is not a condition of purchasing any advisory services.

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3.2 No Sharing of Mobile Information

Mobile opt-in, SMS consent, and phone numbers collected for SMS communication purposes will not be shared with any third party or affiliates for marketing purposes. All mobile information collected in connection with our text messaging program is used solely to communicate with you directly and is not sold, rented, licensed, or disclosed to any third party for their own marketing purposes. This restriction applies notwithstanding any other data-sharing provision of this Privacy Policy.

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3.3 Message Frequency, Fees, and Opt-Out

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● Message frequency varies based on your account activity and communications with your advisor

● Message and data rates may apply, depending on your mobile carrier and plan

● Reply STOP at any time to opt out of receiving text messages from Northstar

● Reply HELP for assistance, or contact us at 770.559.6220

● Carriers are not liable for delayed or undelivered messages

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3.4 Types of Messages

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Messages you may receive include appointment reminders and scheduling confirmations, account or service-related notifications, and responses to inquiries you initiate with Northstar. We do not send promotional or marketing text messages.

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3.5 Records of Consent

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Records of SMS consent are maintained within our messaging platform, including the date, time, and content of the opt-in exchange associated with your phone number.

3.6 Full SMS Terms

For complete details on our text messaging program, including message types, frequency, and opt-in/opt-out procedures, please see our SMS Terms and Conditions.

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4. COOKIES, TRACKING PIXELS, AND RELATED TECHNOLOGIES

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If you visit our Site, we may use first- and third-party cookies, tracking pixels, and related technologies to help us understand how visitors interact with our Site and to improve its functionality. You may use your web browser settings to block or delete cookies. Mobile phone numbers and SMS consent data are never collected or shared through cookies or tracking technologies for advertising purposes.

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5. HOW WE PROTECT YOUR PERSONAL INFORMATION

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We limit access to your personal information to employees, affiliates, and service providers who need it to perform their job functions or provide services to you. We maintain administrative, technical, and physical safeguards

reasonably designed to comply with Regulation S-P and to protect your personal information from unauthorized access, use, or disclosure. Northstar maintains a Written Incident Response Program addressing detection, containment, and notification in the event of a data security incident.

We select third-party service providers carefully and require contractual assurances that they will safeguard your personal information consistent with our policies and applicable law.

If we discover a breach of the security of your personal information, we will notify you in accordance with applicable law, including the Georgia Personal Identity Protection Act, as promptly as possible under the circumstances.

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6. RETENTION OF PERSONAL INFORMATION

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We retain personal information as necessary to fulfill our business purposes, comply with our legal and regulatory recordkeeping obligations under the Investment Advisers Act of 1940, resolve disputes, and enforce our agreements.

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7. USE OF SERVICES BY MINORS

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Northstar does not knowingly collect, use, or share personal information from children under thirteen (13) years old. We ask that any person under age 13 refrain from using our Site or services. If we learn we have collected personal information from a child under 13, we will take steps to delete it as soon as possible.

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8. YOUR CHOICES AND RIGHTS

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● You may opt out of text messages at any time by replying STOP

● You may request access to, correction of, or deletion of your personal information, subject to our recordkeeping obligations under applicable securities law

● You may decline to provide certain information, though this may limit our ability to provide advisory services to you

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9. HOW TO CONTACT US

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Northstar Investment Partners

Telephone: 770.559.6220

Location: Alpharetta, Georgia

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10. REVISIONS TO THIS PRIVACY POLICY

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Northstar reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time. Material changes will be reflected by an updated “Last Revised” date below. Your continued use of our Site and services following notice of such changes constitutes acceptance of the revised Privacy Policy.

Last Revised: 07-08-2026

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