PRIVACY POLICY – TURNING TECHNOLOGIES, LLC

Turning Technologies, LLC (“Turning”) has created this Privacy Policy to demonstrate its commitment to privacy and the transparency of personal data processing.  By accessing and/or using Turning’s website, products, or services you consent to the collection, use and disclosure of your information, including your personally identifiable information as described in this document.

By using any of Turning’s Services, you confirm you have agreed to the End User Subscription Agreement and read and understood this Privacy Policy and our Cookie Policy.

This Privacy Policy describes what we do with personal data that we collect and use for our own purposes (i.e., where we are a controller), such as your account information and information about how you use and interact with our Services, including information you submit to our customer support as well as certain information relating to your End Users (if any).

We also host and process User Content for our Users. Our Users tell us what to do with User Content, and we follow their instructions. This Privacy Policy does not describe what we do with User Content on our Users’ instructions (i.e., as their processor). If you are an End User of one of our User’s sub-domains and want to know how a User handles your information, you should check with that User and their privacy policy. This document describes only how we handle personal data.

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.

1. Types of Personal Data Collected

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:

  • Name
  • Email
  • Physical Address
  • Phone
  • Industry
  • Role
  • Organization Name
  • Country
  • Postal code
  • Attendance data (Snapshot of geolocation when used for GPS attendance and related data.)

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:

  • Payment Data. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
  • Communications Data. The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others. We may also collect Information you share with us in connection with surveys, contests or promotions.
  • Sub-Domain Data. Information from your use of the Services or Users’ sub-domains. This includes: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sub-domains (such as timestamps, clicks, scrolling, browsing times, searches, transactions, load times, and problems you may encounter, such as loading errors).
  • Partner Information. Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
  • Third-Party Services. Other information you submit to us directly or through Third-Party Services if you use a Third-Party Service to create an Account (based on your privacy settings with such Third-Party Service).

2. Collection Personal Information

We obtain personal information from various sources. We do this in three main ways:

  • Personal information you provide
    When you use our Services, we ask you to provide your name and email address to register and manage your Account. We also retain the emails and other communications that you send us, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.

    Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Paid Services to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
  • Personal information obtained from your use of our Services
    When you use our Services, we collect information about your activity on, and interaction with, the Services such as: your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.

    If you are an End User of our Users’ sub-domains, we also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).Some of this information is collected automatically using cookies and similar technologies when you use our Services and our Users’ sub-domains. We control what cookies and similar technologies are used within their sub-domains such that we can provide the Services properly, and for performance or security related reasons. You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.
  • Personal information obtained from other sources
    If you use a Third-Party Service to integrate with your Account, the Third-Party Service may provide us with your Third-Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third-Party Services). Your privacy settings on the Third-Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third-Party Service.

    If you sign up for Paid Services, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance and the expiration date.

3. Using Your Personal Information

We use the personal information we obtain about you to:

  • Provision of the Services. Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.
  • Communicating with you. To respond to communications, reach out to you about your transactions or Account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Turning, you may not opt out of receiving these important notices.
  • Surveys and contests. Administer surveys, contests and other promotions.
  • Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.
  • Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
  • Security and Fraud Protection. To protect individuals, employees, and Turning and for loss prevention and to prevent fraud, including to protect individuals, employees, and Turning for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
  • Third-party relationships. Manage our vendor and partner relationships.
  • Enforcement. Enforce our End User Subscription Agreement and other legal terms and policies.
  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when (Lawful Basis for Processing Your Data):

  • Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
  • Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign into your Turning account.
  • Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
  • Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
    • To operate the Turning business and provide you with tailored advertising and communications to develop and promote our business.
    • To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Turning is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
    • To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
    • To anonymize and subsequently use anonymized information.
  • Protecting you and others. To protect your vital interests, or those of others.

4. Sharing Your Personal Information

We share personal information in the following ways:

  • Business Partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.  Turning will enter into data processing agreements with any such third parties consistent with the requirements of the GDPR.
  • Process payments. We transmit your personal information via an encrypted connection to our payment processor.
  • Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our End User Subscription Agreement) or prevent fraud or abuse of Turning or our Users or End Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
  • Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

5. Your Rights Regarding Personal Data Provided to Turning

  • The right to be informed – meaning Turning must make clear what they are processing, why, and who else the data may be passed to.
  • The right of access – which is your right to see what data is held about you by Turning.
  • The right to rectification – which is your right to have your data corrected or amended if what is held is incorrect in some way.
  • The right to erasure – which is your right, under certain circumstances, to ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
  • The right to restrict processing – which gives you the right to ask for a temporary halt to Turning’s processing of personal data, which may impact your ability to use our software.
  • The right to data portability – which is your right to ask for any personal data supplied to Turning, to be provided in a structured, commonly used, and machine-readable format.
  • The right to object – which is your right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
  • The right to consent and withdraw consent related to how your personal data is used.
  • The right to lodge a complaint with a supervisory authority.

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 privacy@turning.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.

Our Cookie Policy explains how you can manage cookies and similar technologies.

6. Protecting Your Personal Information

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.

7. Retaining Your Personal Information

We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.  

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.

As Users may come back to us after an Account becomes inactive, we don’t immediately delete your personal information when your trial expires, or you cancel all Paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back. You may delete your Account by contacting us at privacy@turning.com and Turning will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).

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.

8. Data Transfers

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:

  • We may transfer personal information to recipients outside the European Economic Area.  In accordance with Article 46 of the GDPR, we will enter into a data processing agreement with any organization receiving personal data outside the European Economic Area.
  • We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

9. End Users’ Personal Information

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.  

You may choose to publish your own privacy policy and comply with 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.

10.  Marketing Communications

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.

11.  California Residents

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: privacy@turning.com.  We will verify your request using the information associated with your account.  Additional identification may be required.

12. Children’s Online Privacy Protection Act (“COPPA”).  

Turning does not market or sell products directly to children under the age of 13.  Turning also does not knowingly collect information about children under 13 without appropriate parental/guardian consent.  Products and services may be provided to organizations who use those products and services with children under the age of 13.  It is the responsibility of the organization to meet parental/guardian consent requirements under COPPA.  Regardless of the source, data is maintained according to the descriptions in this Privacy Policy.

13. Updates to This Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it to our site. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

14.  General Information

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

Email: privacy@turning.com

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
Belfast
BT7 2JB

Telephone: 028 9027 8757 / 0303 123 1114

Email: ni@ico.org.uk

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