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.
1.1. Consumer Information: Personal information required to perform Services as well as data from using our website our services, which may include:
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:
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:
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:
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:
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.
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.
2.1. Turn uses the collected information in the following ways:
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.
3.1. 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:
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.
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.
4.2. Partners: Customers may access and control the contents and use of their information as described below.
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:
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”).
5.6. 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.
6.1. 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.
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.
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 email@example.com.
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:
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.
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 firstname.lastname@example.org or 1-888-499-8876.
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.
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.