Business Partner Privacy Policy
This Privacy Policy is effective as of October 15, 2008
Turn Inc. ("Turn") provides advertisers and publishers ("Business Partners") access to a set of technologies and processes designed to display advertisements to consumers viewing a publisher's website(s) (the "Turn Ads").
This Privacy Policy describes Turn's privacy practices as they pertain to our Business Partners. If you'd like to understand our privacy practices as they pertain to our corporate website, located at www.turn.com ("Site") or our ad targeting technology ("Technology"), please click here.
If you have any questions about this Privacy Policy, please feel free to contact us at privacy@turn.com.
Turn is a member of the Network Advertising Initiative ("NAI") and is in compliance with the NAI's Self-Regulatory Principles. If you'd like to get more information about NAI and the NAI's Self-Regulatory Principles, please visit http://www.networkadvertising.org/managing/principles.asp.
Collection Business Partner Information
Business Partners generally provide information to Turn as they register as a Business Partner and create a Business Partner account (an "Account"), and in conjunction with their access to, participation in and use of the Turn advertising network and related Turn technology and services (including but not limited to the Turn Site portal) (collectively, the "Business Partner Services").
During Account registration, Turn will collect Personally Identifiable Information ("PII") from a Business Partner that may include name, company name, address, email address, telephone and fax numbers, bank information, credit-card type, number and expiration date, PayPal account information, social security number and/or Federal Tax ID number and other PII listed in the Turn Business Partner Account registration form (collectively, a "Profile").
Turn's primary goal in collecting a Business Partner's Profile is to communicate with such Business Partner, provide it with a smooth and efficient experience of Business Partner Services and to charge advertisers and pay publishers. To this end, Turn may share Profiles with third-party service providers and Turn-related entities worldwide (e.g., its parents, affiliates and subsidiaries and their successors and assigns) in connection with communications, payments and other aspects of operating and promoting the Site and the Turn advertising network. We require that these entities agree to use such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. Except as explicitly stated herein, Turn does not sell, rent or trade any Profiles to third parties.
Collection of Non-Personally Identifiable Information
Turn automatically collects a Business Partner's IP addresses and website usage information when a Business Partner logs into their Account or while using Business Partner Services. Turn may collect information indirectly and automatically (through the use of cookies) about the Business Partner's Site activity. Turn uses this information to help Turn evaluate how its Business Partners use and navigate the Site on an aggregate basis, including the number and frequency of Business Partner visits, and the length of their visits. Turn also uses session cookies to track and maintain a Business Partner's login status during their session on the site. Turn also uses this information for internal purposes, such as to help Turn diagnose any server problems, administer the Site, improve and customize the Site, or help Turn understand and analyze how the Site is being used.
Use and Transfer of Business Partner Information
Turn may use a Profile in the following ways:
(a) Turn may use a Business Partner's name, address, email address and telephone number: (i) to enable Turn to process, validate and verify an Account; (ii) to contact the Business Partner regarding Account activities or communications relevant to Business Partner Services; and (iii) to contact the Business Partner about new or existing products and services or special offers.
(b) Turn may use a publisher's: (i) name, address, account password, bank information or credit-card number in order to process and remit fees to publisher and/or verify personal information and identity of the publisher; and as appropriate (ii) social security number and/or Federal Tax ID number to prepare Form 1099s if necessary and to help Turn verify such Web Partner's identity.
(c) Turn may use an advertiser's: (i) name, address, account password, bank information or credit-card number in order to process and charge fees to advertiser and/or verify personal information and identity of the advertiser; and as appropriate (ii) social security number and/or Federal Tax ID number to prepare Form 1099s if necessary or to help Turn verify such Web Partner's identity.
(d) Turn uses third-party processing companies (including credit card processing companies) for billing and payment purposes. These third parties may store or retain a Business Partner's PII. Turn may charge or bill a Web Partner's credit card an initial Account activation fee as described during the Account registration process. In certain cases, Turn will also use credit card information to help verify Business Partner's identity. These third parties do not have any right to use the Profile information Turn provides to them beyond what is necessary to assist Turn.
(e) Turn may combine the information collected from Web Partners on the Site with information that Business Partners provide to Turn in connection with their use of other Turn products and services.
(f) Dispute Resolution. Turn may use and disclose Profiles and other information Turn obtains from a Business Partner's current and past activities on the Site in special circumstances, if Turn is required to do so, if Turn reasonably believes that such disclosures will potentially mitigate its liability, or for Turn to enforce its rights. For example, Turn may disclose Profiles: (i) to appropriate authorities and to banks associated with a Web Partner's Account in order to prevent or report suspected fraud and illegal activities; (ii) where it is necessary for Turn to enforce the applicable Web Partner agreements; (iii) to resolve disputes, including disputes involving other Business Partners or consumers, in connection with actual or potential parties to a lawsuit or actions that Turn is or may become involved in, and to identify potential liabilities and troubleshoot problems; or (iv) in order to prevent harm to any persons. In some cases, the government can compel the disclosure of information about a Business Partner, and Turn will need to comply, in which case Business Partner authorizes Turn to do so.
(g) Surveys. From time to time Turn may ask Business Partners to participate in surveys. These surveys are entirely voluntary and a Business Partner may decline to participate. If you choose to provide some of your Profile information in response to a survey, such information will be used for purposes of monitoring or improving the Site or the use and satisfaction of the Turn services.
(h) Adherence to Law. Turn may share an information provided by or collected from Business Partners when reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Business Partner agreements, including investigation of potential violations thereof, or detect, prevent or protect Turn against or otherwise address criminal activity, fraud, security or technical issues.
(i) Storing and Processing Profiles. Profiles collected during a Business Partner's use of the Business Partner Services may be stored and processed in any country in which Turn maintains facilities. Consequently, Turn has the right to transfer information outside of a Business Partner's country, and you consent to such transfer. If a Business Partner registers an Account on any website controlled by Turn or a Turn-related entity located outside of the United States, such Profile must be disclosed to Turn, which is located inside the United States, in order for the Business Partner to access or use any Web Partner Services. Therefore, Business Partner acknowledges and consents to the sharing of its Profile with Turn and Turn-related entities worldwide.
(j) Business Continuity. We may transfer any Business Partner information, including but not limited to Profiles, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
Finally, if you send Turn email correspondence, or if consumers or other third parties send Turn email or other correspondence regarding a particular Business Partner's activities, Turn may collect such information.
Controlling the use of your information
Opt-Out from receiving emails from Turn
If a Business Partner does not wish to receive communications from Turn as contemplated under this Privacy Policy, such Business Partner has the ability to stop receiving these mail communications by logging into their Account and accessing the "Account Settings" screen in the Turn Site portal. Business Partner will, however, always receive administrative emails from Turn that are related to Business Partner Services.
Correcting/Updating Business Partner Information
Business Partners can review, update and edit their Profile by logging into their Account and accessing the "Account Settings" screen in the Turn Site portal.
Removing Business Partner's Transaction History
A Business Partner may unsubscribe from the Business Partner Services and request that Turn remove their Profile from the Turn databases. However, in order to resolve disputes, assist with any applicable law, regulation, legal process or governmental requests or investigations, and due to technical constraints (including the fact that Turn backs up its systems), a Web Partner's information and transaction history are never completely removed from the Turn databases.
Information Security
The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
If you have any questions about our security practices, please send an email to us at privacy@turn.com.
Changes to this Privacy Policy
This privacy policy is subject to change. If we make any material or substantive changes in the way that we use Business Partner PII, we will post a clear and conspicuous notice of those changes on this Privacy Policy.
Contact Information
For questions or concerns relating to privacy, please send us an email at privacy@turn.com. Alternatively, you may contact us at: Privacy Officer, Turn Inc., 1600 Seaport Boulevard, Suite 300, Redwood City, CA 94063.
Copyright © 2010 Turn Inc.
