Last Updated December 31, 2019
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.
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 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.
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.
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 email@example.com. 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 firstname.lastname@example.org 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.
EU-US and Swiss Privacy Shield
In compliance with the Privacy Shield Principles, TurnTo commits to resolve complaints about your privacy and our collection or use of your Personal Data. European Union and Swiss individuals with inquiries or complaints regarding this Policy should first contact TurnTo via email at email@example.com or by postal mail:
Attn: User Privacy Requests
TurnTo Networks, Inc.
330 7th Avenue, Suite 1203
New York, NY 10001
TurnTo has further committed to refer unresolved privacy complaints under the 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).
Request Additional Information
If you have any questions about this Policy, please contact us at firstname.lastname@example.org.