California Privacy Policy

Turn Technologies, Inc. Last Updated: March 31, 2026.

1. Scope & Who This Covers

This California Privacy Policy (“CA Policy”) supplements Turn Technologies, Inc.’s Privacy Policy and applies solely to California residents, as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, “CCPA”).

This CA Policy describes how Turn collects, uses, and discloses personal information about the following categories of individuals:

• Consumers: Individuals on whom Turn has been asked to provide a background screening report or other services.
• Partners: Businesses or individuals who have contracted to use Turn’s Services.
• Visitors: Individuals who visit turn.ai or interact with Turn online.

This CA Policy is intended to serve as the notice at collection required under the CCPA. Where this CA Policy conflicts with Turn’s general Privacy Policy, this CA Policy governs for California residents.

2. Important Note on FCRA & CCPA Interaction

Note: As a Consumer Reporting Agency (CRA) regulated under the Fair Credit Reporting Act (FCRA), Turn handles certain personal information that is exempt from the CCPA. The CCPA does not apply to personal information collected, processed, sold, or disclosed in accordance with the FCRA, the Driver’s Privacy Protection Act (DPPA), or other applicable federal laws.

This means that if you submit a CCPA request to delete, correct, or obtain information from a background check report Turn prepared — such as criminal history, motor vehicle records, or employment verification — the CCPA generally does not require Turn to honor that request with respect to that information. Those requests are governed by your FCRA rights instead. You can learn more about your FCRA rights here.

This CA Policy applies to personal information that is not otherwise exempt from the CCPA, including personal information collected from Visitors and Partners in connection with Turn’s website and sales activities.

3. Categories of Personal Information We Collect

In the twelve (12) months preceding the Effective Date of this CA Policy, Turn may have collected the following categories of personal information about California residents:

Turn does not knowingly collect personal information from individuals under the age of 16.

4. Purposes for Collection & Use

Turn collects and uses personal information for the following business purposes:

• Providing our Services: Conducting background screenings, employment verification, drug testing, MVR checks, and related services on behalf of Partners.
• Account administration: Creating and managing Partner accounts, processing payments, and communicating about account activity.
• Communications: Responding to inquiries, sending service notifications, and providing customer support.
• Site improvement & analytics: Understanding how Visitors interact with turn.ai to improve functionality and user experience.
• Security & fraud prevention: Detecting and preventing unauthorized access, fraudulent activity, and security threats.
• Marketing: Sending promotional content and product announcements to Partners and prospective customers who have not opted out.
• Legal compliance: Meeting obligations under the FCRA, DPPA, CCPA, and other applicable federal and state laws.
• AI and automated processing: Applying automated compliance filtering and machine learning to ensure accuracy and compliance in consumer reports, consistent with FCRA requirements and Turn’s Responsible AI Policy.

5. Disclosure of Personal Information

In the twelve (12) months preceding the Effective Date, Turn may have disclosed the following categories of personal information to service providers or contractors for business purposes:

• Identifiers (e.g., name, email, phone) — to marketing and communications vendors
• Background screening data (name, SSN, DOB, employment/education history) — to data furnishers and court record vendors to fulfill background check orders
• Internet activity (IP address, cookie IDs) — to website analytics providers
• Professional and education information — to verification data vendors
• Payment information — to payment processors (Turn does not store full card numbers)

Turn does not disclose personal information to third parties for their own independent marketing purposes without your consent.

6. Selling & Sharing of Personal Information

Turn does not sell personal information in exchange for money. Turn does not sell or share the personal information of Consumers collected in connection with background check reports.

For Visitors and Partners, Turn may make limited personal information available to advertising and analytics platforms (such as cookie identifiers, IP addresses, and referral URLs) for the purpose of targeted advertising. Under the CCPA, these activities may constitute “selling” or “sharing” of personal information.

You may opt out of this activity at any time by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of any page on turn.ai, or by contacting us as described in Section 10 below. Where required, Turn also honors Global Privacy Control (GPC) signals as an opt-out of selling and sharing for targeted advertising.

7. Use of Sensitive Personal Information

Where Turn uses or discloses sensitive personal information (such as Social Security Numbers, driver’s license numbers, or precise geolocation), Turn limits such use to purposes necessary to provide the requested Service, as permitted under the CCPA. Turn does not use sensitive personal information for purposes that would require Turn to offer a right to limit use or disclosure beyond those designated purposes under California law.

8. Retention of Personal Information

Turn retains personal information for as long as necessary to fulfill the purposes for which it was collected, or as otherwise required or permitted by applicable law. For consumer reports and related background screening data, retention is governed by the FCRA and applicable state laws. For Partner and Visitor information, Turn generally retains records for up to six (6) years unless a longer period is required by law or contract.

Once the applicable retention period expires, Turn securely deletes, de-identifies, or aggregates the personal information. De-identified information is maintained in a manner that prevents re-identification.

9. Your California Privacy Rights

Subject to applicable exemptions (including the FCRA exemption described in Section 2), California residents have the following rights under the CCPA:

• Right to Know: You may request that Turn disclose the categories and specific pieces of personal information it has collected about you, the sources of that information, the purposes for which it was collected, and the categories of third parties with whom it was shared.
• Right to Delete: You may request that Turn delete personal information it has collected about you, subject to certain exceptions.
• Right to Correct: You may request that Turn correct inaccurate personal information it maintains about you.
• Right to Data Portability: You may request that Turn provide your personal information in a portable, readily usable format.
• Right to Opt Out of Selling/Sharing: You may direct Turn not to sell or share your personal information for cross-context behavioral advertising, as described in Section 6.
• Right to Non-Discrimination: Turn will not discriminate against you for exercising any of your CCPA rights. Turn will not deny you services, charge different prices, or provide a lesser quality of service as a result of your exercise of these rights.
• Right to Appeal: If Turn declines to act on your privacy rights request, you may appeal that decision by following the process described in Section 10.

Note for Consumers (background check subjects): Your primary rights regarding information in a Turn background check report are governed by the FCRA, not the CCPA. To dispute information in a background check report, please visit turn.ai/dispute-process/.

10. How to Exercise Your Rights

To submit a request to know, delete, or correct personal information, or to appeal a prior decision, California residents may contact Turn through any of the following methods:

• Email: support@turn.ai with the subject line “California Privacy Request”
• Phone: +1 (888) 499-8876
• Mail: Turn Technologies, Inc., Attn: Privacy Requests, 311 West Monroe Street, 3rd Floor, Chicago, IL 60606

Turn will verify your identity before processing your request. We may ask you to provide additional information to confirm your identity. You may designate an authorized agent to make a request on your behalf by providing written authorization signed by you.

Turn will respond to verifiable consumer requests within 45 days of receipt. If more time is required (up to 90 days total), Turn will notify you of the extension and the reason for it.

If Turn denies your request, you may appeal the decision by emailing support@turn.ai with the subject line “California Privacy Appeal.” Turn will respond to your appeal within 60 days.

11. Contact Us

If you have questions about this California Privacy Policy or Turn’s privacy practices, please contact our legal team:

Turn Technologies, Inc.
Attn: Privacy Policy Issues
311 West Monroe Street, 3rd Floor
Chicago, IL 60606
Email: support@turn.ai
Phone: +1 (888) 499-8876