Privacy Policy

Last Updated April 21, 2021


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.

Personal Data is information that identifies, or can be used to identify, a specific person.  Examples of Personal Data are an individual’s name, physical address, or email address, as well as other information when associated with Personal Data, such as purchase transactions and content submitted by users. Personal Data 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. Personal Data 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 Personal Data. For example, Personal Data 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 known 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 Personal Data.

TurnTo Customers transmit Personal Data 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. The TurnTo Customer, has represented to TurnTo that it has the right to transmit this data to TurnTo for purposes of the services TurnTo provides to the TurnTo Customer.

Use And Disclosure of Personal Data

TurnTo functions as an application services provider.  The Personal Data collected by the TurnTo System is used by TurnTo solely to provide the TurnTo Customer with the 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 Personal Data to third parties, except as described in this paragraph. TurnTo may share Personal Data 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 Personal Data 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 Data, will be transferred as part of any (i) merger or acquisition, (ii) creation of a separate business to provide TurnTo System services, (iii) 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’s Privacy

TurnTo expects TurnTo Customers to follow all applicable laws and policies, including policies prohibiting the collection of Personal Data from users that do not meet the age of consent requirements in their respective jurisdictions, 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 applicable the age of consent.

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 the 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.

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  If requested to remove data, we will respond within a reasonable timeframe.


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 Personal Data if you contact us and request us to do so by email at or by mail:

Attn: User Privacy Requests
TurnTo Networks, Inc.
330 7th Avenue., Suite 1203
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.

California Residents

Privacy Notice For California Residents

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.

Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at

Request Additional Information

If you have any questions about this Policy, please contact us at