Privacy Policy

Last Updated January 4, 2017

Introduction

Your privacy is very important to us.  TurnTo Networks, Inc. is committed to respecting the privacy of all users of the TurnTo System and visitors to websites where the TurnTo System is employed.

For purposes of this Privacy Policy (“Policy”), the terms “TurnTo”, “we”, “us”, and “our” refer to TurnTo Networks, Inc. “TurnTo System” refers to the applications and web services that encompass the software that TurnTo licenses to organizations. “TurnTo Customers” are organizations that license use of the TurnTo System for their websites and other digital properties such as mobile applications. “You” refers to you, as a user of the TurnTo System or visitor to websites where the TurnTo System is employed.

The purpose of this Policy is to describe how the TurnTo System collects and uses information about you when you use the TurnTo System or visit websites where the system is employed and the choices you have regarding our use of, and your ability to review and correct, the information we collect.

Personally Identifying Information” (“PII”) is information that identifies, or can be used to identify, a specific person.  Examples of PII are an individual’s name, physical address, or email address, as well as other information when associated with PII, such as purchase transactions and content submitted by users. PII does not include aggregate information or data from which identifying information has been removed.

How Information Is Collected

TurnTo Customers install functions on their websites that communicate with the cloud-based elements of the TurnTo System through its APIs. These installed functions may be provided by TurnTo, the TurnTo Customer, or by third parties. PII is collected by the TurnTo System when you interact with the user interface  provided by those functions and are logged in to the TurnTo System or when you explicitly provide PII. For example, PII is collected when you use the TurnTo System to ask a question about a product on an ecommerce site and provide an email address so replies to the question can be sent to you.

TurnTo uses cookies and tracking beacons (also know as “tracking pixels”) to make its services work more efficiently, to customize your experience, and to monitor use of the TurnTo System. If you are not logged in to the TurnTo System, data collected using these cookies and web beacons are not associated with an identified individual and therefore remain anonymous. However, if you log in to the TurnTo System, either directly or by logging in to a website employing the TurnTo System, data collected through these cookies and web beacons may be associated with your PII.

TurnTo Customers transmit PII that they own to the TurnTo System to enable it to perform its functions. This information is transmitted to the TurnTo System through various secure data feeds. This information remains the property of the TurnTo Customer that provided it.

Use And Disclosure of PII

TurnTo functions as an application services provider.  PII stored in the TurnTo System is the property of the TurnTo Customer on whose website, or other digital property, the information was collected or that provided it to the TurnTo System through a feed mechanism. This information is used by TurnTo solely to provide the TurnTo Customer with the TurnTo System services purchased.

It is the obligation of the TurnTo Customer to ensure that the services purchased from TurnTo and provided by the TurnTo System comply with the Customer’s privacy policies. TurnTo will provide any information stored in the TurnTo System that is the property of a TurnTo Customer to that TurnTo Customer upon request. Use of that information by that TurnTo Customer is governed solely by that Customer’s privacy policy. TurnTo encourages users of TurnTo Customers’ websites and other digital properties to review their respective privacy policies.

TurnTo does not rent, sell or disclose PII to third parties, except as described in this paragraph. TurnTo may share PII that is the property of a TurnTo Customer when directed by that TurnTo Customer to do so or with the permission of that TurnTo Customer, when required by law, or when required to protect TurnTo’s rights or property. TurnTo may use third party service providers to assist with the administration and operation of the TurnTo System or the performance of related services. These third parties may be given or may have access to PII when required to enable the performance of their services, but they agree to receive and use such information solely to provide their services to TurnTo or on TurnTo’s behalf and within the restrictions of this Policy.

If TurnTo ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

Information stored in the TurnTo System is a business asset of TurnTo. Therefore, all data stored in the TurnTo System, including PII, will be transferred as part of any (i) merger or acquisition, (ii) creation of a separate business to provide TurnTo System services, (ii) debt financing, sale or pledge of company assets, or (iv) insolvency, bankruptcy or receivership in which personal information would be transferred as one of TurnTo’s business assets.

TurnTo may release personal information when TurnTo believes release is appropriate to (i) comply with the law, (ii) enforce or apply TurnTo policies, (iii) protect TurnTo rights or property, (iv) protect users from fraudulent, abusive or unlawful use of the TurnTo System or TurnTo services (v) or if TurnTo reasonably believes that an emergency involving immediate danger of death or serious physical injury to any person requires the disclosure of communications or justifies disclosure of records without delay. TurnTo may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

TurnTo’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, TurnTo remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless TurnTo proves that it is not responsible for the event giving rise to the damage.

Children Under 13 Years of Age

TurnTo expects TurnTo Customers to follow all applicable laws and policies, including policies prohibiting the collection of PII from users under 13 years of age, and TurnTo will not knowingly license the TurnTo System to customers who do not do so.  TurnTo will immediately delete data that it has discovered to have been collected and associated with any user under the age of 13.

Protecting Your Data

TurnTo takes reasonable and appropriate security measures to endeavor to prevent loss, misuse and alteration of information under its control. TurnTo cannot however, guarantee protection of all information against interception, misappropriation, misuse or alteration, or that personal information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

Accessing Your Data

You may access the data held by TurnTo for a particular TurnTo Customer and associated with your email address at any time by accessing “My Profile” from any product page on that Customer’s website or from http://www.turnto.com.

TurnTo acknowledges that EU individuals have the right to access the personal information/data that we maintain about them.  An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to support@turnto.com.  If requested to remove data, we will respond within a reasonable timeframe.

Choice/Opt-Out

You may log out of the TurnTo System at any time. You may also refuse to accept cookies by following the procedures specific to your Web browser.

TurnTo will remove the data it has collected and identified with your email address and opt you out from any further collection or disclosure of PII if you contact us and request us to do so by email at support@turnto.com or by mail:

Attn: User Privacy Requests
TurnTo Networks, Inc.
150 W. 30th St., Suite 1200
New York, NY 10001

Please allow up to 72 hours to process an email request after it has been acknowledged or 14 business days upon receipt by postal mail.

EU-US Privacy Shield

TurnTo complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  TurnTo has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the EU-US Privacy Shield Principles, TurnTo commits to resolve complaints about your privacy and our collection or use of your PII.  European Union individuals with inquiries or complaints regarding this Policy should first contact TurnTo via email at support@turnto.com or by postal mail:

Attn: User Privacy Requests
TurnTo Networks, Inc.
150 W. 30th St., Suite 1200
New York, NY 10001

TurnTo has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.  TurnTo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Policy Changes

TurnTo may modify this policy if TurnTo’s privacy practices materially change in the future. TurnTo will communicate notice of such changes only by posting the new policy on its website and indicating at the top of the policy the last date it was updated. TurnTo encourages review of TurnTo’s Privacy Policy on a regular basis.

Request Additional Information

If you have any questions about this Policy, please contact us at contact@turnto.com.