Tuurnt Website Privacy Policy

BY USING OR ACCESSING THE WEBSITES, SYSTEMS OR SERVICES OF TUURNT YOU SIGNIFY YOUR ACKNOWLEDGMENT AND ASSENT TO THE PRIVACY POLICY SET FORTH BELOW. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE TUURNT’S WEBSITES, SYSTEMS OR SERVICES. PLEASE CHECK THIS POLICY PERIODICALLY FOR CHANGES.

Tuurnt, Inc., a corporation registered in the State of Delaware (hereinafter referred to as “Tuurnt,” “us,” “we,” or “our”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of the personal information that we receive when you visit or use: (a) the websites owned or operated by Tuurnt or its affiliates (hereinafter referred to as “Sites”), (b) software that may be downloaded to your mobile device (and any updates thereto) (hereinafter referred to as “Apps”), and (c) the services and functionality available through the Sites, Apps and other product offerings of Tuurnt (hereinafter referred to as “Offerings”), including software and web applications offered via the Sites. For ease of reading in this Privacy Policy, such websites, products, software and services (including the Sites, Apps, and Offerings) are referred to collectively as the “Tuurnt Services.”

This Privacy Policy applies only to information that you provide to us when you use the Tuurnt Services. If you are notified that a different privacy policy applies to specific Tuurnt Services, then this Privacy Policy shall not apply to information collected by us relating to such other Tuurnt Services.

Your use of any Tuurnt Services indicates your agreement to this Privacy Policy. If you do not agree to any part of this Privacy Policy, then you should immediately stop accessing all Tuurnt Services and terminate any associated accounts.

1. Tuurnt Platform. Tuurnt is developing a decentralized platform (the “Tuurnt Platform” or “Platform”) that stores information about an individual and his/her interests and activities (collectively, “Platform Data”) using blockchain technology. Users of the Platform may access and use the Platform Data, and the Platform enables certain mechanisms for you to control the disclosure and use of your Personal Data. The Platform Data is collected and stored in the Platform by individual data providers (“Data Providers”). “Third-Party Services” means apps, applications or services created by Data Providers or other third parties to collect, store, extract, or use Platform Data, or to otherwise interact with Platform Data or Tuurnt Services.

2. No Responsibility for Third Parties: Tuurnt has no responsibility for (and will not have any liability for) the actions or omissions of any third-party provider of Platform Data or Third-Party Services. Each Data Provider is solely responsible for the Platform Data it provides, including any usage, permissioning and anonymization of such Platform Data.

Information you provide when interacting with a Data Provider or using Third-Party Services is provided directly to the relevant third-party provider and not to Tuurnt. This Privacy Policy only applies to personal data collected by Tuurnt related to Tuurnt Services—it does not apply to Platform Data obtained by Tuurnt that was collected or provided by other Data Providers. We do not endorse, warrant or guarantee any Third-Party Service, and Tuurnt is not responsible for any such Third-Party Services or their use or disclosure of your Personal Data or any Platform Data. Third-Party Services are not governed by this Privacy Policy. You should carefully review the privacy policy and terms of use applicable to any Third-Party Service before interacting with a Third-Party Service or authorizing such Third-Party Service to collect, access or use your Personal Data.

3. Changes to Privacy Policy. This Privacy Policy may be updated from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email or via the Tuurnt Services or other messaging system, or by means of posting an updated version of this Privacy Policy on the Sites. We encourage you to periodically review this policy for the latest information on our privacy practices.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on Tuurnt Services. In all the above cases, your continued use of Tuurnt Services after any notice or posted modified Privacy Policy indicates acceptance of the modified Privacy Policy.

4. Collection of Personally Identifying Information. While using Tuurnt Services, you may provide, and we may collect, certain personally identifying information that can be used to uniquely identify or contact you (“Personal Data”). Personal Data may include, but is not limited to, your name, photo, phone number, credit card or other billing information, email address, and postal addresses. To use certain Tuurnt Services, you may be required to set up an account with Tuurnt (an “Account”). During this process, we may ask you for certain Personal Data to establish and use your Account. In some cases, we may also request additional information from you for security reasons to provide specific Tuurnt Services. You may at any time refuse to provide the Personal Data that we request; however, this may limit our ability to provide certain Tuurnt Services to you.

We may also obtain Personal Data about you from other users of the Tuurnt Services and from the providers of Third-Party Services in which you participate. If you submit payment card data to the Tuurnt Services, it may be submitted directly to a payment processor (and not to Tuurnt) in which case such information shall not be subject to this Privacy Policy, and Tuurnt will have no responsibility or liability for such information, or for any errors or security breaches involving a payment processor.

5. Collection of Usage Information.Our systems automatically record certain information about how a person uses Tuurnt Services (we refer to this information as “Usage Information”), including both Account holders and non-account holders. Usage Information may include information such as a user’s Internet Protocol (IP) address, location, domain name, referring web page, device and browser type, operating system, device settings, the pages or features of Tuurnt Services to which a user browsed and the time spent on those pages or features, frequency with which Tuurnt Services are used by a user, search terms, the features and links on Tuurnt Services that a user clicked on or used, and other statistics.

We use this information to administer and provide Tuurnt Services and we analyze (and may engage third parties to analyze) this information to provide, improve and enhance Tuurnt Services and to tailor them to our users’ needs and preferences. Usage Information does not, in and of itself, identify you personally, but we may link it to Personal Data for Account holders.

  • a. Service Data. We may collect and record information relating to the setup, general performance, usage, and operation of Tuurnt Services, including data that an Offering or App records. We may store this data along with your Personal Data and other information about your use of Tuurnt Services. We use this information to allow you (and us) to operate and monitor Tuurnt Services. We may use third-party analytics providers, including Google® Analytics, in connection with collecting and analyzing information about usage of Tuurnt Services.
  • b. Location and Mobile Data When you use certain features of Tuurnt Services, in particular our Offerings or Apps, we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code), diagnostic information, and direction of travel, and more specific GPS location information that is provided to us by your mobile device.
  • c. Cookies and Beacons.We may collect Usage Information through the use of “cookies,” which are small text files that are saved by your browser or device when you access Tuurnt Services. We (and our third-party analytics providers, such as Google® Analytics) may use both session cookies and persistent cookies to identify that you’ve logged in to the Tuurnt Services and to tell us how and when you interact with Tuurnt Services. We may also use cookies to monitor aggregate usage and web traffic routing for Tuurnt Services and to customize and improve Tuurnt Services.

    Unlike persistent cookies, session cookies are deleted when you log off from Tuurnt Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of Tuurnt Services. We may also employ, and/or our third-party providers may employ, software technology called tags or web beacons (a.k.a. pixel tags or clear gifs), that help us better manage Tuurnt Service content and communications by informing us what content is effective and how it is used.

    These beacons (or other tracking technology) may be included in or associated with e-mails or other communications that you receive from us (or our partners) in order to help us track your response and interests and to deliver you relevant content and services. For Account holders we may link information gathered by web beacons or other tracking technology to Personal Data.

6. Authorized User Information. . In connection with use of the Tuurnt Services, you may grant others (“Authorized Users”) permission to access the Tuurnt Services on your behalf. You must be careful of the Authorized Users that you invite and the access that you give them. You are responsible for all uses of your Account, including those by Authorized Users. Additionally, certain portions of your Personal Data, Usage Information and Tuurnt Service information may be shared with the people to whom you give access to your Account. The Tuurnt Services may collect Personal Data and Usage Information about your Authorized Users in connection with their access to the Tuurnt Services. All such collected information is subject to, and will be used and disclosed as set forth in, this Privacy Policy.

. All Authorized Users expressly consent to such use and disclosure. Any Authorized User who does not consent to such use, should not use the Tuurnt Services or provide any Personal Data. You agree to provide adequate notice to your Authorized Users (including notice about location tracking) regarding the collection of Personal Data and Usage Information and its use and sharing in accordance with this Privacy Policy. We will have no liability for the failure to provide notice or obtain the consent of any Authorized User.

7. Use of Personal Data. We use Personal Data for the following purposes: (i) to facilitate your purchase and use of the Tuurnt Services; (ii) to provide content, products and services you authorize; (iii) to transfer funds associated with your use of Tuurnt Services; (iv) to provide, administer and improve Tuurnt Services; (v) to better understand your needs and interests; (vi) to personalize your experience; (vii) to provide Tuurnt Service announcements and communicate with you regarding Tuurnt Services; (viii) to provide you with further information and offers from Tuurnt or its affiliates; (ix) to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Tuurnt or its affiliates; (x) to respond to comments, questions or support requests; and (xi) to comply with our legal obligations, resolve disputes with users, enforce our agreements and to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

We may combine the Personal Data we collect with publicly available information and information we receive from our business partners and other third parties, including Data Providers and providers of Third Party Services.

8. Disclosure to Third Parties. Under this Privacy Policy you and your Authorized Users hereby consent to our sharing of Personal Data under the following circumstances:

  • a. Platform Users: We may share your Personal Data with any Third-Party Services or users of the Platform whom you have authorized to receive, access or use your Personal Data, including those Third-Party Services and Platform users who are allowed to access your Personal Data through the authorization mechanisms and settings built into the Platform or Tuurnt Services.
  • b. Our Affiliates. We may share your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under common control that we may have now or in the future, in which case we will require them to honor this Privacy Policy.
  • c. Our Service Providers. We may employ third-party companies and individuals to administer and provide Tuurnt Services on our behalf and to fulfill requests and orders you may make (including maintenance, administration, support, hosting and database management services and billing and credit card payment processing). These third parties may have access to your Personal Data reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
  • d. Special Cases. Tuurnt cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will use, and disclose to government or law enforcement officials or private parties, such information about you as we, in our discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Tuurnt or a third-party, to enforce our legal agreements, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, fraudulent, inappropriate or legally actionable.
  • e. Corporate Transactions. In the event Tuurnt or its affiliates or their assets are sold, merged or otherwise involved in a corporate transaction or bankruptcy, your Personal Data will likely be transferred as part of that transaction. We reserve to right to transfer your information without your consent in such a situation.
  • f. Specific Terms. Specific portions or pages of our Sites or the Tuurnt Services may notify you of additional or different provisions relating to collection and disclosure of Personal Data. In the event of a conflict between such provisions and this Privacy Policy, such specific terms shall control. Except as noted above, we do not share or sell the Personal Data that you provide to us with other organizations without your consent.

9. Use of Aggregate and Non-Personally Identifying Information. Tuurnt may anonymize, aggregate or de-personalize Personal Data and/or Usage Information to create non-personally identifiable information. Tuurnt may freely disclose and use non-personally-identifying information for industry analysis, statistical purposes, demographic profiling, marketing and advertising, and other business purposes (which may include reporting on trends in the usage of its Apps, Sites or Tuurnt Services).

10. Marketing Messages. If you submit your email address or other contact information to us we may use this information to send you news about services, products or promotions of Tuurnt and its affiliates. We may use one or more affiliates or service providers to administer these messages, but we do not share your email address with spammers or any other third parties for their own use without your permission. You may opt-out of receiving marketing-related e-mails from us by logging in and changing your Account settings or by using the opt-out method detailed in any message that you receive.

11. Security. We use appropriate security measures consistent with industry practice to protect against the loss, misuse and alteration of your Personal Data under our control. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of Personal Data. We will comply with all applicable privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of Personal Data consistent with our ability to determine the scope of a breach and our obligations to law enforcement.

12. Social Media Widgets. Our Site and Tuurnt Services may include social media features, such as the Facebook “like” button and widgets such as the “share this” button. These features may collect your Personal Data and track your use of Tuurnt Services. Your interactions with these features are governed by the privacy policy of the company providing such functionality.

13. Minors. The Sites and Tuurnt Services are not directed to children under 13 and we do not knowingly collect Personal Data from children under 13. If you are under 13 years of age, then please do not use or access the Tuurnt Services at any time or in any manner. If we learn that we have collected Personal Data of a child under 13 we will take steps to delete such information from our files as soon as possible.

14. Changing or Deleting Your Information. You may review, update, correct or delete the Personal Data associated with your account by logging into your Account. If you wish to update or delete other Personal Data, you can contact us using the contact points specified below. We’ll take steps to modify or delete your Personal Data as soon as is practical, but some information may remain in archived/backup copies for our records or as otherwise required by law. Upon termination of your Account, we will retain all Personal Data only as long as necessary for to fulfill our obligations in connection with the Tuurnt Services and for any period of time necessary to comply with applicable law, including any applicable statute of limitation.

15. Your California Privacy Rights.Our Sites do not collect personally identifiable information about an individual user’s online activities across third-party web sites (and thus do not monitor your browser’s Do Not Track indicator). We do not provide Personal Data collected by Tuurnt to organizations for their own direct marketing purposes.

16. International Transfer.Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to Tuurnt, please be advised that we transfer Personal Data to the United States and process it there (and possibly other countries). You hereby consent to the transfer of your information and Personal Data in accordance with this section.

17. Jurisdictional Issues. Tuurnt makes no makes no representation that any Tuurnt Service operates (or is legally permitted to operate) in all geographic areas, or that the Tuurnt Services are appropriate or available for use in all locations. Accessing the Tuurnt Services from territories where the Tuurnt Services, or any content or functionality of the Tuurnt Services or portion thereof, is illegal is expressly prohibited. If you choose to access the Tuurnt Services, you agree and acknowledge that you do so on your own initiative and at your own risk and that you are solely responsible for compliance with all applicable laws.

18. Contact Information: : if you have any questions or concerns regarding this Privacy Policy you may contact us as set forth below:

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