If you are a User, see our Data Processing Addendum to learn more about how we process User Content on your instructions or with your permission.
In the course of setting up and using an account or completing a form via our website, Turning may collect the following personal information as you provide it to us:
We may also collect information when you voluntarily complete customer surveys, send us email, participate in contests or promotions, or provide feedback to us.
Additional Personal Information We May Collect:
We obtain personal information from various sources. We do this in three main ways:
We use the personal information we obtain about you to:
We process your personal information for the above purposes when (Lawful Basis for Processing Your Data):
We share personal information in the following ways:
These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you may make such a request at email@example.com. We may request specific information from you to confirm your identity. Requests will be responded to without delay and, barring unusual circumstances, within one month of request being submitted. In some circumstances we may charge a reasonable fee for access to your information. You have the right to receive your personal data in a structured, commonly-used and machine-readable format.
We maintain administrative, technical, and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for, and protecting against, network vulnerabilities.
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.
Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the United States or other countries in the EU. We also may store personal information locally on the devices you use to access the Services.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. Turning complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.
We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
Our customers may establish a sub-domain using Services and are responsible for what they do with the personal information they collect about their End Users. This section is directed to such customers.
If you’re one of our Users, you may collect personal information about your End Users. For example, you may ask your End Users to provide their name, and email address in order to establish an account for them.
You're solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them.
We are not liable for your relationship with your End Users or how you collect and use personal information about them (even if you collect it through the use of Turning functionality) and we won’t provide you with any legal advice regarding such matters nor will we defend or represent you in any way with regard to any disputes with your End Users.
Turning may use the personal data that you provide through an online form to send information to you, for example, information about our company and products. Your personal data may also be used to contact you when necessary or desirable. You may opt-out of receiving marketing information.
Our emails provide users the opportunity to opt-out of receiving Turning’s marketing communications. Please keep in mind that, even if you choose not to receive marketing communications, you will continue to receive account communications related to services or products that you are using (e.g., purchase confirmation and receipts) and/or important product and legal updates related to those services and products.
California residents have certain rights spelled out in the California Consumer Privacy Act or “CCPA”.
Turning does not sell the personal information we collect. The types of personal information we collect in order to set up an account are described above. The purposes for sharing any information we collect are also described above. Turning does use third-party cookies as described here.
California consumers may make a request regarding the types of data disclosed and information about the third-party to whom data was disclosed under the CCPA by contacting us at: firstname.lastname@example.org. We will verify your request using the information associated with your account. Additional identification may be required.
Turning Technologies, LLC is headquartered in the United States at 255 West Federal Street, Youngstown, OH 44503. Any questions or concerns regarding this document and your privacy rights may be directed to:
Data Protection Officer
Turning Technologies, LLC
255 West Federal Street
Youngstown, OH 44503
Turning Technologies, LLC is registered with the Information Commissioner’s Office as our Supervisory Authority. Concerns about our efforts to maintain your privacy in the EU can be directed to:
The Information Commissioner’s Office – Northern Ireland
14 Cromac Place, 3rd Floor
Telephone: 028 9027 8757 / 0303 123 1114