Privacy Policy

TURN TECHNOLOGIES, INC.

Effective Date: November 12, 2020

Turn Technologies, Inc. (“Turn”) is committed to protecting the privacy of Consumers, Partners, and Visitors of our website at turning.io, mobile application (“app”), products, APIs, Worker Sourcing and other services (“Services”). We’re also committed to providing you a rich, intensive experience when you use our Services and are always working to make them better. One of the ways we do that is by analyzing information we collect, to learn, for instance, how to improve your experience, or what Turn Worker Sourcing opportunities might interest you.

Turn reserves the right to change this Privacy Policy (“Policy”) at any time. We reserve the right to update this Policy at any time. Any changes are effective immediately upon posting to www.turning.io. The most recent version of this Policy is the version that applies. We believe privacy policies should be clear, transparent, and accessible. This Policy explains what data we collect, how we use it, and under what limited circumstances we share it; all of which will depend on your use of the Services. Please see below to identify which type of user you are:

Consumer: Consumers are individuals Turn has been requested to provide services or on-demand workers who have expressed interest in working with Turn Partners .
Partners: are companies that have contracted to use, or have agreed to test, Turn’s Services.
Visitors: all those who visit our website or mobile application to learn more about Turn.

What information does Turn collect?
How does Turn use Collected Information?
When does Turn Share your Information?
How can You Change or Delete Information about you?
Will you receive notices and disclosures electronically?
Does this Policy apply to third parties or third-party links?
What choices do you have about promotional or informational email and text communications from Turn?
How is Your Information Protected?
What are my Additional Rights as a California Resident?
International Considerations
Who can use our Services?
How can you Contact Turn for Additional Information?

1. What information does Turn collect?

1.1. Consumer Information: Personal information required to perform Services as well as data from using our website our services, which may include:

Identification information, including name, date of birth, and government issued identification numbers such as Social Security or Individual Taxpayer Identification Number, and driver’s license, among others.
Contact information, including phone number, email and home address.
Education information, such as degrees, certifications, academic records, and other qualifications
Employment information, including previous employers, roles and employee record information.
Financial information, including income, salary, billing rate, payments, and benefits.
Additional information or supporting documentation you provide in connection with the Services, including your communications with Turn.
Personal information may also be collected by Partners and transferred to Turn for the purpose of providing Services. Turn may also receive personal information about Consumers from third parties as described in Third Party information below.
Work metrics such as tenure, cumulative earnings, or task completion information to populate under your worker profile.
Automatically Collected Information: When Consumers visit the website or use the Services, we automatically gather certain technical and usage information, which may be associated with your account or profile. (See 1.5 for more information.)
We may collect information about your device when you use the mobile application including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device's address book solely in order to add someone to your contacts.
Geolocation information - If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the mobile application and make it easier for you to interact with on-demand work opportunities, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.
- If using our mobile application and you have enabled location services, but wish to turn them off, you can do so through your mobile’s settings.

1.2. Partner Information: Certain information is collected by Turn relates to the Partners and their use of the Services. This includes account information necessary to perform and facilitate requested Services and analytics from using the website or Services, which may include:

Due diligence information.
Account and user credential information, including name, email, roles and associated permissions.
Status and instructions for requested Services, including deactivation of Consumer or user credentials.Payment information, including credit card and/or bank account information and billing information. Please note, we do not store the credit card or bank account numbers you may use to make payments for Services.
Account information and user credentials may also be collected by third parties or affiliates of Turn. For example, Turn Services may be offered on third party marketplace platforms.
Automatically Collected Information: When Partners visit the website or use the Services, we automatically gather certain technical and usage information, which may be associated with your account or profile. (See 1.5 for more information.)
We may collect information about your device when you use the mobile application including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the mobile application may access your device's address book solely in order to add someone to your contacts.
Geolocation information - If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the mobile application and make it easier for you to interact with on-demand work opportunities, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.
- If using our mobile application and you have enabled location services, but wish to turn them off, you can do so through your mobile’s settings.

1.3. Visitor Information: Certain information may be collected during visits of the website or mobile application. This includes both manually submitted and automatically collected information:

Submitted information: Visitors may have opportunities to submit information directly to Turn, including contact requests and in browser chat with Turn agents. Visitors may be asked to provide Turn with basic information including name, email address, and general business information. Turn may maintain records of communications submitted through the website and/or mobile application.
Automatically Collected Information: We automatically gather certain technical and usage information, which may be associated with submitted information. (See 1.5 for more information.)
We may collect information about your device when you use the mobile application including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the mobile application may access your device's address book solely in order to add someone to your contacts.

1.4. Third Party Information: Certain Services require the collection of information from third parties. Third party information may relate to either Consumers or Partners. It may include both public and private records as described below:

Public Records: Turn may collect public records bearing on a Consumer or Partner, where appropriately authorized, including civil, and criminal court records and documentation, business filings, and public media articles.
Private Records: Where appropriately authorized, Turn may obtain private records, including educational, employment, financial, and drug test records.

1.5. Automatically Collected Information: When Consumers, Partners, or Visitors utilize any of our Services, Turn automatically gathers certain technical and usage information. This technical and usage information (“Technical Information”) may include information on when, how often and for how long you use the Services; and server log data such as:

IP address; browser type; device type; location information; local storage information on your device; operating system and version, or the webpage you were visiting before you came to the Services.
Cookies: We use various technologies to collect and store information when you visit our Services, and this may include using cookies or similar technologies to identify your device or browser. Information we collect when you use our Services, in addition to information we obtain about you from our partners or other third parties, may be associated with your Turn account. We treat information associated with your Turn Account as personal information.
Carrier Consent: You authorize your wireless carrier to disclose information about your account, such as subscriber status, payment method, and device details, if available, to support identity verification, fraud avoidance, and other uses in support of transactions for the duration of your business relationship with us. This information may also be shared with other companies to support your transactions with us and for identity verification and fraud avoidance purposes.
Social Networking: You may register with Turn directly or by logging into your account with a third- party social networking service (“SNS”) (e.g., Facebook, Google, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link your Turn account to your account with an SNS, we will use the personal information you have provided to the SNS to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your Turn account to your SNS account. Other than what we may share with the SNS as described below in the Social Networking Content section below, the personal information an SNS has about you is obtained by the SNS independent of our Services, and Turn is not responsible for it.

1.6. Contacts: You may choose to provide us with your friends' contact information as stored on your phone. We ask your permission before syncing your contacts, and you can still use the app without giving it access to your contacts.

We store your contacts’ name, phone number(s), email address(es), and/or birth day.
Our automatic algorithms suggest people to invite to join Turn but we do not contact anyone in your phone’s contact list without your permission. Other than our Service Providers that we describe below, we do not share your contacts with third parties unless required to do so in response to valid legal requests, such as through a court order or search warrant.

1.7. UNLESS YOU REQUEST THAT WE DELETE CERTAIN INFORMATION (SEE SECTION 4 BELOW), WE RETAIN THE INFORMATION WE COLLECT FOR AT LEAST FIVE (5) YEARS AND MAY RETAIN THE INFORMATION FOR AS LONG AS NEEDED FOR OUR BUSINESS AND LEGAL PURPOSES.

2. How does Turn use Collected Information?

2.1. Turn uses the collected information in the following ways:

To Perform Services to Consumers, Partners and Visitors.
To Communicate with You: Turn uses collected information to communicate with you about the Services, including by phone, postal service, email, live in-browser chat, or SMS regarding the status of certain requested Services, to provide updates on changes or modifications to the Services, to facilitate the delivery of information authorized or required through the Services or to offer you our Services and features. Where appropriate, Turn may send you product announcements and special promotions from Turn or our business partners, or to administer participation in special events, surveys, contests and sweepstakes. By using our Services, you choose to Opt-in to receipt of SMS messaging regarding all of the above.
To create a Consumer profile in the Turn Worker Sourcing marketplace.
To Administer Your Account: Turn uses collected information to administer account settings, to process billing and payment information, manage preferences and troubleshoot problems, and personalize the content that account Consumers and Partners’ users see based on personal characteristics or preferences.
To Meet Legal and Compliance Requirements: Turn may use the collected information to (1) comply with any applicable procedures, laws,and regulations, subpoenas, governmental requests or legal process; (2) in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; (3) protect the rights, property or safety of Turn, our Consumers, our Customers, or third parties; (4) prevent
fraud or abuse of Turn or our users; or (5) perform a task carried out in the public interest.
To Provide Security: Turn uses collected information to create Consumer and Partner account credentials, to verify identity prior to granting access to account information, to validate against existing information maintained by Turn, to protect against duplicate or unauthorized account creation, to secure the Site and Services, and to address fraud, abuse or safety concerns of Turn, our Partners or Consumers , including investigation of complaints or suspected fraud or wrongdoing.

2.2. Data Retention: Turn will retain collected information in accordance with applicable laws and agreements between Turn, its Partners, and affiliates.

2.3. Sale of Information: The California Consumer Privacy Act (CCPA) sets forth certain obligations for businesses that “sell” personal information. Please see Section 10.

2.4. Anonymized Information: We may use and share anonymized information without limitation, including sharing with third parties. This includes aggregated, de-identified information about Consumers, Partners, Visitors, and information collected from third parties such as public records.

2.5. Machine Learning: In some instances, Turn applies software algorithms and machine learning techniques to information collected from Consumers, Partners, Third Parties, and Site Visitors. For example, we apply automated compliance filtering to collected data from third parties to ensure we are complying with all applicable reporting laws and responsibilities. To improve accuracy and safeguard consumer rights and interests, our approach is to apply automated methods of processing in targeted instances and to implement thoughtful human review and supervision as needed. Consumers also reserve the right to dispute the accuracy of all reported information that applies to them.

3. When does Turn Share your Information?

3.1. As authorized: Certain collected information may be shared when authorized, either expressly or implicitly through the use of the Site or Services. Such authorization includes:

Consumer authorization to share collected personal information, as well as public and private information with Partner (e.g., background check information, supplemental information, etc.).
Partner authorization to share certain account information necessary to administer requested Services (e.g., company name and contact information provided to Consumers) or to integrate with third party service providers (e.g., applicant tracking systems).Visitor authorization through the submission of contact information.

3.2. With Partners: We may share information with our Partners that offer Worker Sourcing or related services.

3.3. To Perform Services: Certain Services necessitate sharing collected information (e.g.., to perform a background check). Turn may share or transfer certain collected information to third parties, affiliates or external processors who perform services on behalf of Turn, including but not limited to data storage, analysis, and processing.

3.4. To Provide Security: Turn may share information between relevant Partners or third parties to verify account credentials and to address fraud or safety concerns.

3.5. To Analyze Usage of Services: We use analytics services for purposes of analyzing usage of the Services.

3.6. To Transfer Business: In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Turn, the information we possess may be transferred as a corporate asset to the acquiring entity.

3.7. To Conduct Research and Marketing: We may disclose information to Partners or non-affiliated third parties for research and marketing purposes.

3.8. To Meet Legal Requirements or Compliance Reasons: Turn may disclose certain collected information where, in good faith, we believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Turn, our Consumers, our Customers, or third parties. Additionally, we may share non-personal information publicly and with our Partners or potential partners like publishers, advertisers, investors or connected websites. For example, we may share information publicly to show trends about the general use of our Services.

4. How can You Change or Delete Information about you?

If you delete certain personal information from your Turn account or profile, then the account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use our Services. Some information may actively persist in our systems even if you close your account. In addition, your personal information may remain in our archives and information you update or delete, or information within a closed account, may be preserved internally for our administrative purposes, or for legitimate business or legal purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove any information you posted publicly through or using our Services.

4.1. Consumers: may access and control the contents and use of their information as described below.

To request deletion of your information, contact support@turning.io.
Disputing Incorrect Information: If at any time you believe Turn possesses or has communicated incorrect information about you to Partners, please contact us at compliance@turning.io.
Submitting Supplemental Information: In certain instances, Consumers may be requested or given the opportunity to share additional information or context to collected information. This information will only be shared with third parties (such as employers) where directed by the Consumer.

4.2. Partners: Customers may access and control the contents and use of their information as described below.

Account information: some requests to update Partner account information can be done from the Turn Dashboard. Other requests should be directed to your account representative or emailed to support@turning.io.

5. Will you receive notices and disclosures electronically?

Yes. The Services are offered through Turn’s website, mobile site, and application. To obtain Services from Turn, you must create an online account and (1) be able to access Services on a computer or other device that is capable of accessing the Internet, (2) have an active email account, and (3) consent to our use of our website, application, or email to provide you any written information that we may be required to send you in connection with the Services, your account, and/or background checks and reports. However, you may still exercise your rights under the Fair Credit Reporting Act by contacting us through non-electronic means such as mail or a phone call. See Section 12 to contact Turn.

5.1. Method of Providing Communications to You in Electronic Form: All Communications that we provide to you in electronic form will be provided either (1) via email, telephone or text, (2) by making it available online and accessible via the Services, or (3) by requesting you download a PDF file containing the Communication.

5.2 Your Consent to Electronic Disclosures. By creating an account and/or authorizing a background check or other Services, you acknowledge and agree that:

You can access and read the information we post on our website or mobile app
To provide an email address that is active and effective for receiving emails from us
To receive electronically on our website, app, or via email notices and disclosures, required by law related to your account and the Services; and
You have received the following disclosures as required by the federal Electronic Signatures in Global and National Commerce Act (“ESIGN”). Please read this Federal ESIGN disclosure and consent carefully and keep a copy for your records. Your consent is voluntary, but we cannot provide
the Services to you if you do not consent. If you are unwilling to receive these disclosures and notices electronically, you may terminate the creation of your account by closing your browser at any time before you create an account and/or authorize a background check.

5.3. Accurate Contact Information: It is your responsibility to provide us with true, accurate and complete contact information, such as email address, and other information related to your account, and to maintain and update promptly any changes in this information. If you give us an incorrect email address or fail to update or correct your email address, an electronic communication will be deemed provided to you if we use the email address in our records for the electronic communication.

5.4. Scope of Communications to Be Provided in Electronic Form: Your consent to receive electronic communications and transactions includes, but is not limited to, all legal and regulatory notices or disclosures and communications associated with your account, the Services, your request for a background check, and any product or service we agree to provide you (each, a “Communication”).

5.5. How to Withdraw Consent: You may at any time withdraw your consent to receive Communications in electronic form. To begin receiving Communications in paper form, please contact us at the following address: toTurn Technologies, Inc., Attn: Privacy Policy Issues, 20 West Kinzie Street 17th Floor, Chicago, Illinois 60654. Please specify the information you wish to receive in paper form. Be sure to state that you are requesting a copy of the disclosures, notices, etc., and include your name and mailing address. Your request will apply only to those specific items you designate. We will not impose any fee to process the withdrawal of your consent to receive electronic Communications. Any withdrawal of your consent to receive electronic Communications will be effective only after we have a reasonable period of time to process your withdrawal.

5.6. Required Equipment: In order to use the Services and to view and retain a copy of this Policy and certain Communications, you understand that you must have a computer or device equipped with at least: a browser with 128-bit encryption, a current version of a software that can open and display PDF files (e.g., Adobe), and either a printer or other electronic storage device.

6. Does this Policy apply to third parties or third-party links?

6.1. No. Our Services may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We don’t exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

However, we may keep track of how you interact with links available on Turn Sites including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such ashow many times a particular link was clicked on.

6.2. Social Networking: Our Services may interact with a third-party website, service, or other content provider, such as enabling you to “like” or share content to a third-party Social Networking Service (“SNS”). If you choose to “like” or share content, or to otherwise share information from or via our Services with a third-party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of our Services (and we may have access to information about you from them). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with third parties through an SNS or similar features are governed by the respective privacy policies of those third parties.

You represent that you are entitled to use your SNS account for the purposes described herein without breach by you of any of the terms and conditions that govern the SNS, and without obligating Turn to pay any fees or making Turn subject to any usage limitations imposed by such SNS. Please note that your relationship with any SNS is governed solely by any agreement with such SNS. If your SNS account terminates, then functions that are enabled through the link between your Turn account and your SNS account may terminate as well.

7. What choices do you have about online tracking, web beacons, promotional or informational email and text communications from Turn?

7.1. Online Tracking and Cookies. At this time, the Services do not currently respond to “do not track” browser headers. But you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored. If you
disable cookies, you may be prevented from taking full advantage of the Services because they may not function properly without cookies. Turn uses various cookie-based analytics services. Editing your tracking and cookie preferences will limit analytic tracking. To prevent Google Analytics from using your information for analytics, as an example, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

7.2. Web Beacons: We, our third-party service providers, advertisers or our Partners may also use "web beacons" or clear gifs, tags and scripts, or similar technologies, which are small pieces of code placed on a web page, to analyze, collect and aggregate data about your use of our Services. For example, web beacons may be used to count the users who visit a web pageor to deliver a cookie to the browser of a visitor viewing that page.

7.3. Promotional Emails: Subject to any restrictions under applicable laws, we may send periodic promotional or work opportunity emails to you. You may opt-out of such communications by clicking unsubscribe in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about promotions or other Worker Sourcing opportunities, we think may interest you, we may still send you emails about your account or any services you have requested or received from us.7.4.Opting Out of Turn Text Messages: The number of text messages you receive may depend upon how you use our Services and whether you take steps to generate additional text messages from us. If you no longer want to receive Turn text messages, you may reply STOP to our messages at any time. If you have revoked consent and want to re-enroll in our text message program, you can re-enroll by emailing us at support@turning.io.

8. How is Your Information Protected?

8.1. We work hard to protect Turn and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. For example:

We encrypt many of our Services using 256-bit SSL bank-level encryption.
We offer you two step verification when you access your Turn account.
We regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
We regularly analyze our Services for possible vulnerabilities.
We restrict access to personal information to Turn employees, partners, contractors and agents who need to know that information to process it for us or for other business reasons, and who are subject to contractual confidentiality obligations and may be reprimanded or terminated if they fail to meet these obligations.

8.2. Note: no security measures are 100% effective and we cannot guarantee your information will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your information, passwords, accounts, phones, computers, and other devices. Turn is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords or other authentication information, or for any activity on your account via unauthorized activity.

8.3. DISCLAIMER: WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL INFORMATION.

9. What are my Additional Rights as a California Resident?

Consumers in California, have the following rights.

9.1. Right to access: You have the right to know and see what data we have collected about you over the past 12 months, including:categories of personal information we have collected about you;categories of sources from which the personal information is collected;the business or commercial purpose for collecting your personal information;the categories of third parties with whom we have shared your personal information; and the specific pieces of personal information we have collected about you.

9.2. Right to deletion: You have the right to request that we delete in certain circumstances the personal information we have collected from you.

9.3. Right not to be discriminated against: You have the right not to be discriminated against for exercising any of these rights. To request access to or deletion of your personal information, or to exercise any other data rights under the CCPA, please contact us at privacy@turning.io or 1-888-499-8876.

10. International Considerations

Turn is a United States company. If you are located outside the U.S. and choose to provide information to us, we may transfer personal information to the U.S. for processing. The U.S. may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the U.S., we will protect it as described in this Privacy Policy. By using our Services, or providing us with any personal information, you fully understand and consent to this transfer, processing and storage of your information in the U.S.

10.1. Additional Information for Canadian Users: This Policy applies to Partners, Consumers and Visitors in Canada. However, to the extent that this Policy is inconsistent with any applicable Canadian laws, Turn will comply with the applicable law for Partners, Customers and Visitors in Canada. For example, Turn will only send commercial electronic messages to persons located in Canada with explicit, opt-in consent, unless otherwise permitted pursuant to Canadian legislation that is applicable to such activities. Consumer information will be used for screening and worker sourcing purposes.

Consumers who are located in Canada should also understand that the nature of the Services will involve Turn obtaining potentially sensitive personal information about them, including consumer reports, criminal record, driving record, as well as education and employment records, from third parties such as consumer reporting agencies, police services and government agencies (e.g., provincial transportation ministries).
Turn will also share Consumers’ personal information with a third-party service provider in Canada, for the purpose of completing or facilitating the background checks described in this Policy.
In addition, personal information that is collected in the course of providing the Services will be transferred outside Canada. Therefore, such information may be accessible to law enforcement and national security authorities in the jurisdiction(s) where it is stored or processed.
Canadian Partners, Consumers, and Visitors will be notified of any material changes to this Policy, where such a change would result in use or disclosure of their personal information by Turn in a manner not contemplated by this Policy or reasonably expected by the individual.10.2Turn protects personal information from residents of the European Union, other European Economic Area countries, and Switzerland in accordance with applicable law (including, as applicable, reliance upon your consent and EU-approved standard contract clauses).

11. Who can use our Services?

You must be 18 years of age or older to use our Services. If you are a parent or guardian and believe that your child under the age of 13 has provided personally identifiable information to us through the Services, please contact us at the contact information listed below. If we discover that an individual under 13 has provided us with personal information, we will take steps to delete the account and any such personally identifiable information to the extent required by applicable law.

12. How can you Contact Turn for Additional Information?

If you have any questions about this Privacy Policy, you may contact our Legal Team at compliance@turning.io, or (888) 499-8876, or mail addressed to Turn Technologies, Inc., Attn: Privacy Policy Issues, 20 West Kinzie Street 17th Floor, Chicago, Illinois 60654.