EU Consent Policy

As a TurnTo Customer using the TurnTo System, you must ensure that certain disclosures are given to, and consents obtained from, end users in the European Economic Area. If you fail to comply with this policy, TurnTo may limit or suspend your use of the TurnTo System and services and/or terminate your agreement.

Properties under your control

When features of the TurnTo System (e.g. widgets, API, or behavioral tracking) are used on any site, app, email delivery service, or other property that is under your control, or that of your affiliate, the following duties apply for end users in the European Economic Area.

You must obtain end users’ legally valid consent to:

  • the use of cookies or other local storage where legally required; and
  • the collection, sharing, and use of personal data in accordance with how you have configured and use the TurnTo System

When seeking consent, you must:

  • retain records of consent given by end users; and
  • provide end users with clear instructions for revocation of consent.

You must clearly identify each party that may collect, receive, or use end users’ personal data as a consequence of your use of the TurnTo System. You must also provide end users with prominent and easily accessible information about that party’s use of end users’ personal data.

Properties under a third party’s control

If personal data of end users of a third-party property is shared with TurnTo due to your use of, or integration with, a feature of the TurnTo System, then you must use commercially reasonable efforts to ensure the operator of the third-party property complies with the above duties. A third-party property is a site, app or other property that is not under your or your affiliate’s control and whose operator is not already using the TurnTo System under an Agreement that incorporates this policy.