TurnTo Networks, Inc. Privacy Policy

Effective December 1, 2011

This Privacy Policy (“Policy”) describes how the TurnTo System collects and uses personal information. As used in this Policy, “personal information” is information that identifies or is able to identify a particular person. Examples of personal information are an individual’s name, address, or email address, as well as other information when associated with personal information, such as purchase transactions, comments submitted by users. Personal information does not include aggregate information or data from which identifying information has been removed.

How Information Is Collected

  1. TurnTo Customers (organizations that license the TurnTo System for use on their websites or other digital properties) install functions on their websites that communicate with the cloud-based elements of the TurnTo System through one of its APIs. These installed functions may be provided by TurnTo, the TurnTo Customer, or by third parties. Personal Information is collected by the TurnTo System when people interact with the user interface elements provided by those functions and are logged in to the TurnTo System or provide identifying information. For example, personal information is collected when a person uses the TurnTo System to ask a question about a product on an ecommerce site and provides an email address so replies to the question can be sent to them.
  2. TurnTo uses cookies and web beacons (also know as “web bugs”) to make its services work more efficiently, to customize the experience of a user, and to monitor use of the TurnTo System. If the user is not logged in to the TurnTo System, data collected using these cookies and web beacons is not associated with an identified individual and so is anonymous. However, if the user has logged in to the TurnTo System (which requires an affirmative action by the user), data collected through these cookies and web beacons may be associated with that user. Users may log out of the TurnTo System at any time. Users may also refuse to accept cookies by following the procedures specific to their Web browser.
  3. TurnTo Customers transmit personal information that they own to the TurnTo System in order to enable it to perform its functions. This information is transmitted to the TurnTo System through various data feeds. This information remains the property of the TurnTo Customer that provided it.

Use And Disclosure of Personal Information

TurnTo functions as an application services provider; personal information 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 Customer upon request. Use of that information by that Customer is governed solely by that Customer’s privacy policy. TurnTo encourages users of websites (and other digital properties) of TurnTo Customers to review their privacy policies.

TurnTo does not rent, sell or disclose personal information to third parties, except as described in this paragraph. TurnTo may share personal information that is the property of a TurnTo Customer when directed by that Customer to do so or with the permission of that 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 or operation of the TurnTo System or the performance of related services. These third parties may be given or may have access to personal information 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. Information stored in the TurnTo System is a business asset of TurnTo. Therefore, all data stored in the TurnTo System, including personal information, 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 will remove data on individual users if users contact TurnTo and request TurnTo to do so by email at contactus@turnto.com.

Children

TurnTo expects TurnTo Customers to follow all applicable laws and policies, including policies prohibiting the collection of personal information from users under 13 years of age, and TurnTo will not knowingly license the TurnTo System to Customers who do not do so.

Security

TurnTo uses reasonable 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.

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.

Questions/Additional Information

Any questions about this policy may be sent by email to TurnTo at contactus@turnto.com.