Privacy Policy

TURN TECHNOLOGIES, INC.
Last Updated: July 07, 2022

Turn Technologies, Inc. (“Turn,” “we,” “our” or “us”) is committed to protecting the privacy of Consumers, Partners, and all other Visitors to and users of our website at or any later website (“Sites”), mobile applications (“Apps”), products, APIs, consumer report, worker-sourcing and other services (“Services”). We’re also committed to providing you a rich, intensive experience when you use our Services and are always working to make them better. One way we do this is by analyzing the information that we collect to learn, for instance, how to improve your experience, or what opportunities might interest you.

This Privacy Policy (this “Policy”) explains what data we collect, how we use it, and under what limited circumstances we share it; all of which will depend on your use of Turn’s Services. Depending on how you use the Sites, Apps, or Services, you may be considered a:

• Consumer: Individuals who intend to order, order, or use our Services, including any person to whom Turn has provided Services or on-demand workers for whom Turn may run a consumer report.
• Partner: Companies that have engaged in any business with Turn, including those that have contracted to use, or have agreed to test, Turn’s Services.
• Visitor: Individuals, businesses, groups, or anyone else that visits our Sites or Apps.

 

1. What information does Turn collect?

1.1. Consumer Information

Turn may collect the following information from Consumers when they interact with or use the Services:

• Identification information, including name, date of birth, and government-issued identification numbers such as Social Security or Individual Taxpayer Identification Number, and driver’s license or state identification.
• Contact information, including phone number, email and home address.
• Education information, such as degrees, certifications, academic records, and other qualifications.
• Employment information, including previous employers, roles and employee record information.
• Financial information, including income, salary, billing rate, payments, and benefits.
• Device information, such as the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the Apps may access your device’s address book to add someone to your contacts.
• Geolocation information – if you turn these features on, when you use your mobile device, we will collect information about Wi-Fi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us to identify your physical location and we may use it to personalize the App and make it easier for you to interact with opportunities, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts. If using our mobile application and you have enabled location services, but wish to turn them off, you can do so through your mobile’s settings
• Additional information or supporting documentation you provide in connection with our Services, including your communications with Turn and your digital signature.

Certain Services require the collection of information from third parties, including Partners. Third-party information may include both public and private records as described below.

• Public Records: Turn may collect public records bearing on a Consumer where appropriately authorized, including civil, and criminal court records and documentation.
• Private Records: Where appropriately authorized, Turn may obtain private records, including educational, employment, financial, and drug test records.
• Work metrics: Turn may collect information from Partners regarding a worker’s tenure, cumulative earnings, or task completion information. This information is used to populate worker profiles.

1.2. Partner Information

Certain information collected by Turn relates to Partners and their use of Turn’s Services. This includes account information necessary to provide requested Services and analytics from using the Sites, Apps or other Services, which may include:

• Account and user credential information, including name, email, roles and associated permissions.
• Status and instructions for requested Services, including deactivation of Consumer or user credentials.
• Payment information, including credit card and/or bank account information and billing information. Please note we do not store the credit card or bank account numbers you may use to make payments for Services.
• Device information, including unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the mobile application may access your device’s address book solely to add someone to your contacts.
• Geolocation information – if you turn these features on when you use your mobile, we will collect information about Wi-Fi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us to identify your physical location and we may use it to personalize the mobile application and make it easier for you to interact with on-demand work opportunities by enabling the information to be displayed and shared with other members choosing to view “nearby” posts. If using our mobile application and you have enabled location services but wish to turn them off, you can do so through your mobile’s settings.

Certain Services require the collection of information from third parties. Third-party information may include both public and private records as described below.

• Public Records: Turn may collect public records bearing on a Partner, where appropriately authorized, including civil and criminal court records and documentation, business filings, and public media articles.
• Private Records: Where appropriately authorized, Turn may obtain private records, including EIN or Tax Information, major shareholder information with contact information, headquarter office location, historical revenues, projected revenues, billing information, key personnel data, and labor needs by geographic market or nationwide.

Partner-user credentials and information about any account you set up with Turn may also be collected by third parties or Turn affiliates. For example, persons may offer our Services on third-party marketplace platforms.

1.3. Visitor Information

Certain information may be collected when individuals visit our Site or use our App. This includes both manually submitted and automatically collected information.

Visitors may have opportunities to submit information directly to Turn, including through information requests and in-browser chats with Turn agents. Visitors may be asked to provide Turn with basic information including name, email address, and general business information.

We may collect information about your device when you use the App, including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the mobile application may access your device’s address book to add someone to your contacts.

1.4. Automatically Collected Information

When Consumers, Partners, or other Visitors use any of our Services, Turn automatically gathers certain technical and usage information. This technical and usage information (“Technical Information”) may include information on when, how often, and for how long you use our Services, and server log data such as:

• IP address, browser type, device type, location information, local storage information on your device, operating system and version, or the webpage you were visiting before you came to the Services.
• Cookies or similar technologies to identify your device or browser. Information we collect when you use our Services, in addition to information we obtain about you from our Partners or other third parties, may be associated with any account that you set up with Turn. We treat information associated with such Turn Account as personal information.

You may register with Turn directly or by logging into your account with a third-party social networking service (“ SNS”) (e.g., Facebook, Google, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link any account with Turn to your account with an SNS, we will use the personal information you have provided to the SNS to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your Turn account to your SNS account. Other than what we may share with the SNS as described below in the Social Networking Content section below, the personal information an SNS has about you is obtained by the SNS independent of our Services, and Turn is not responsible for it.

1.5. Contacts

You may choose to provide us with your friends’ contact information, including their names, phone numbers, and email addresses as stored on your phone. We ask your permission before syncing your contacts, and you can use the App without giving it access to your contacts. Our automatic algorithms suggest people to invite to join Turn but we do not contact anyone in your phone’s contact list without your permission. Other than our Service Providers that we describe below, we do not share your contacts with third parties unless required to do so in response to valid legal requests, such as through a court order or search warrant.

1.6. UNLESS YOU REQUEST THAT WE DELETE CERTAIN INFORMATION (SEE SECTION 6.4 BELOW), WE RETAIN THE INFORMATION WE COLLECT FOR AT LEAST SIX YEARS AND MAY RETAIN THE INFORMATION FOR AS LONG AS NEEDED FOR OUR BUSINESS AND LEGAL PURPOSES.

2. How does Turn use Collected Information?

2.1. Turn uses the collected information in the following ways:

• To Provide Services to Consumers, Partners and all other Visitors.
• To Communicate with You. Turn uses your information to communicate with you about our Services, and to offer you our Services and features. Where appropriate, Turn may send you product announcements and special promotions from Turn or our business partners.
• To Administer Participation in Special Events and Surveys. By using our Services, you opt in to receive SMS messaging about all of the above.
• To create a Consumer profile in the Turn Worker Sourcing marketplace.
• To Administer Your Account. Turn uses your information to administer settings for any account you create, to process billing and payment information, manage preferences and troubleshoot problems, and personalize the content that Visitors see based on personal characteristics or preferences.
• To Meet Legal and Compliance Requirements. Turn may use your information (a) to comply with any applicable procedures, laws and regulations, subpoenas, governmental requests or legal process; (b) in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; (c) to protect the rights, property or safety of Turn; (d) to prevent fraud or abuse; or (e) to perform a task carried out in the public interest.
• To Provide Security. Turn may use your information to create Consumer and Partner account credentials, to verify users’ identities before granting access to account information, to validate against existing information maintained by Turn, to protect against duplicate or unauthorized account creation, to secure the Sites, Apps and Services, and to address fraud, abuse or safety concerns. We also use your information to detect security incidents; protect against malicious, deceptive, or illegal activity; and prosecute those responsible for that activity.

2.2. Information that does not identify an individual or cannot otherwise be reasonably linked or connected with them is not considered personal information. Personal information may be aggregated or anonymized to become non-personal information. We may collect, use, and share such non-personal information about Consumers; Partners; and other Visitors, without limitation, including sharing with third parties.

2.3. In some instances, Turn applies software algorithms and machine-learning techniques to information collected from Consumers, Partners, and other Visitors. For example, we apply automated compliance filtering to data collected from third parties to ensure that we are complying with all applicable reporting laws and responsibilities.

3. When does Turn Share your Information?

3.1. As authorized. Turn may share certain collected information when authorized, either expressly or implicitly through the use of the Sites, Apps or other Services. Such authorization includes:

• Consumer authorization to share their personal information, as well as public and private information, with Partners (e.g., background check information, supplemental information, etc.).
• Partner authorization to share certain account information necessary to administer requested Services (e.g., company name and contact information provided to Consumers) or to integrate with third-party service providers (e.g., applicant tracking systems).

3.2. To Provide Services. We may share Consumer personal information, including Social Security or Individual Taxpayer Identification Numbers, and driver’s license or state identification numbers, with Partners that use Turn’s Services to facilitate the provision of services to Consumers.

3.3. To Perform Services. Certain Services necessitate sharing collected information (e.g., to perform a background check). Turn may share or transfer certain collected information to third parties, affiliates or external processors who perform services on behalf of Turn, including but not limited to data storage, analysis, and processing.

3.4. To Provide Security. Turn may share information between relevant Partners or third parties to verify account credentials and to address fraud or safety concerns.

3.5. To Analyze Usage of Services. We use analytics services for purposes of analyzing usage of the Services.

3.6. To Transfer Business. In the event of a merger, sale of capital stock or assets, corporate reorganization, consolidation or similar transaction involving Turn, the information we possess may be transferred as a corporate asset to the acquiring or successor entity.

3.7. To Conduct Research and Marketing. We may disclose information to affiliates, Partners or other non-affiliated third parties for research and marketing purposes. Notwithstanding the foregoing, information obtained through the short code program will not be shared with any third parties for their marketing purposes.

3.8. To Meet Legal Requirements or for Compliance Reasons. Turn may disclose certain collected information where, in good faith, we believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or, in other circumstances, where we believe it is necessary to protect the rights or property of Turn. Additionally, we may share non-personal information publicly and with our Partners or potential partners like publishers, advertisers, investors or connected websites. For example, we may share non-public information publicly to show trends about the general use of our Services.

4. Does this Policy apply to third parties or third-party links?

Our Services may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. We don’t exercise control over third-party websites and are not responsible for how these websites collect, share, or use your information. Because Turn has no control over the privacy practices or content of these linked sites, we encourage you to read the privacy policies or statements of the other websites you visit, including any third parties you interact with on our website.

Our Services may interact with a third-party website, service, or other content provider, such as enabling you to “like” or share content to a third-party SNS. Your interactions with third parties through an SNS or similar features are governed by the respective privacy policies of those third parties.

5. Cookies and other tracking technologies

We, our third-party service providers, advertisers or our Partners may also use “web beacons” or clear gifs, tags and scripts, or similar technologies, which are small pieces of code placed on a web page, to analyze, collect and aggregate data about your use of our Services. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Turn uses various cookie-based analytics services. Editing your tracking and cookie preferences will limit analytic tracking. To prevent Google Analytics from using your information for analytics, as an example, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Web Beacons. We, our third-party service providers, advertisers or our Partners may also use “web beacons” or clear gifs, tags and scripts, or similar technologies, which are small pieces of code placed on a web page, to analyze, collect and aggregate data about your use of our Services. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Do Not Track Policy. At this time, the Services do not currently respond to “do not track” browser headers. But you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored. If you disable cookies, you may be prevented from taking full advantage of the Services because they may not function properly without cookies.

6. What are my rights & choices?

6.1. General Privacy Rights. You may have certain rights in addition to the rights set out in the rest of this Policy, such as the right to know, access, transfer, and restrict the processing of your personal information. If you choose to exercise these privacy rights, you may have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from Turn.

To the extent provided by the law of your jurisdiction, you may exercise your privacy rights and choices by sending your request by email to support@turn.ai or call +1 (888) 499-8876. We will verify your request and may request additional information to do so. You may designate an authorized agent to exercise these rights on your behalf.

Turn does not sell your personal information to non-affiliated third parties (including for their own direct marketing purposes) without your consent. In addition, Turn has not sold your personal information to non-affiliated third parties in the last 12 months. If you are entitled to any disclosure rights in your jurisdiction regarding our sale of your personal information to non-affiliated third parties or our disclosure of your personal information to third parties for their own direct marketing purposes, this disclosure satisfies those requirements. If you still wish to learn more about our compliance with this requirement, please use the contact information identified in Section 12 below.

6.2. California Resident Additional Privacy Rights. Pursuant to California’s “Shine the Light” law, California residents may request, once per calendar year, certain information regarding our disclosure of your personal information to third parties for their own direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To make such a request, please use the contact information listed below. In the last 12 months, we have not disclosed your personal information to any third parties for their own direct marketing purposes.

6.3. Opting Out. Subject to any restrictions under applicable laws, we may send periodic promotional or work opportunity emails to you. You may opt out of such communications by clicking unsubscribe in the email. Please note that it may take up to ten business days for us to process opt-out requests. If you opt out of receiving emails about promotions or other opportunities we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

If you want to opt-out of (a) Turn using information that it received about you from an affiliate for marketing purpose or (b) Turn providing information about you to affiliates, Partners or other non-affiliated third parties for marketing purposes, please send an email to support@turn.ai with the subject line “Marketing Opt-Out” that specifies how you want Turn to stop using your information. Turn will honor your request unless an exception under applicable law authorizes Turn to continue using or disclosing your information for marketing purposes.

You may also withdraw your consent to receive communications in electronic form. To begin receiving communications in paper form, please contact us at support@turn.ai. Please specify the information you wish to receive in paper form. Be sure to state that you are requesting a copy of the disclosures, notices, or other documents, and include your name and mailing address. Your request will apply only to those specific items you designate. We will not impose any fee to process the withdrawal of your consent to receive electronic communications. Any withdrawal of your consent to receive electronic communications will be effective only after we have a reasonable period of time to process your withdrawal.

6.4. Consumers may access and control the contents and use of their information as described below:

• To request deletion of your information, contact support@turn.ai. If you delete certain personal information from any account or profile you set up with Turn, then the account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use our Services. Some information may actively persist in our systems even if you close your account. In addition, your personal information may remain in our archives and information you update or delete, or information within a closed account, may be preserved internally for our administrative purposes, or for legitimate business or legal purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove any information you posted publicly through or using our Services.
• Disputing Incorrect Information. If at any time you believe Turn possesses or has communicated incorrect information about you to Partners or other third parties, please contact us at support@turn.ai.
• Submitting Supplemental Information. In certain instances, Consumers may be requested or given the opportunity to share additional information or context to collected information. Turn may share this information with third parties (such as Partners) unless you direct Turn not to do so.

Partners may access and control the contents and use of their information as described below.

• Account information. Some requests to update Partner account information can be done from the Turn Dashboard. Other requests should be directed to your account representative or emailed to support@turn.ai.

7. How is your information protected?

No security measures are 100%-effective and we cannot guarantee that your use of our Sites and Services will be completely safe. You should take steps to protect against unauthorized access to your information, passwords, accounts, phones, computers, and other devices. You should use secure methods when transmitting sensitive information to us.

8. What is the FCRA?

The federal Fair Credit Reporting Act (the “ FCRA”) is a federal law that regulates how credit reporting agencies such as Turn collect your information. Here are links to helpful information about your rights under the FCRA and how to remedy a possible identity theft:

• You can view a “Summary of Your Rights” by clicking here.
• You can view the obligations of users of consumer reports under the FCRA here.
• If you believe your identity has been stolen, you can find information about how to remedy the identify theft here.

9. International considerations

Turn is a United States company. If you are located outside the United States and choose to provide information to us, we may transfer personal information to the United States for processing. The United States may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the United States, we will protect it as described in this Policy. By using our Services or providing us with your information, you fully understand and consent to this transfer, processing and storage of your information in the United States.

Additional Information for Canadian Users: This Policy applies to Partners, Consumers and other Visitors in Canada. However, if this Policy is inconsistent with any applicable Canadian laws, Turn will comply with any applicable laws for Partners, Customers and other Visitors in Canada.

10. Updates to this Policy

Turn may need to update this Policy from time to time. If so, we will post the updated Policy on our Sites, Apps and Services. If the changes being made are material, we may send Partners and Consumers a notice that this Policy has been changed. Your continued use of the Sites, Apps and our Services, or your provision of personal information after any such notices, will let us know that you agree to these changes.

11. Who can use our Services?

You must be 18 years of age or older to use our Services. Please contact us using the contact information in Section 12 below if you are a parent or guardian who believes your child under the age of 13 has provided personal information to us via the Services. If we discover that an individual under 13 has provided us with personal information, we will take steps to delete any such personal information if required by applicable law.

12. How can you contact Turn for Additional Information?

If you have any questions about this Policy, you may contact our legal team at support@turn.ai, or +1 (888) 499-8876, or mail addressed to Turn Technologies, Inc., Attn: Privacy Policy Issues, 333 N Green St, Convene, 8th Floor Chicago, IL. 60607, US.