Privacy Guidelines

Turn takes protecting consumer privacy seriously. Our leadership role puts Turn at the forefront of establishing safety mechanisms, industry best practices and self-regulatory solutions to reduce consumer anxiety and foster trust in digital channels.


Turn’s Privacy Policy

This privacy policy is subject to change. If we make any material or substantive changes in the way that we use the PII collected through this Website, we will post a clear and conspicuous notice of those changes on the Website and in 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.
835 Main St.
Redwood City, CA 94063-1901

Table of Contents
  1. Site Privacy Policy
  2. Information Collection and Use
  3. Information Storage and Security
  4. Access/Information Sharing and Disclosure
  5. Enforcement, Questions and Complaints
  6. Partnerships and Associations

Privacy Policy

This privacy policy is effective as of 15 November 2010

Turn Inc. (“Turn”) provides advertisers and publishers (“Business Partners”) with 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 (i) visitors to our website located at www.turn.com (our “Site”), and (ii) our targeted advertising technology service (“Technology”). If you’d like to understand our privacy practices as they pertain to information collected from and about our Business Partners, 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.

Turn is a member of the Network Advertising Initiative (“NAI”) and is in compliance with the NAI’s Self-Regulatory Principles.

Site Privacy Policy

The Site is intended primarily to offer information about Turn and the services we provide.

Information Collected via the Site

We collect Personally Identifiable Information (“PII” or “Personal Information”) from the Site when you choose to provide it to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, postal address, telephone number, or email address. For example, you may choose to send us PII about yourself in an email or by completing an online form on this Site. We use this information only to contact you to respond to your enquiry. Once collected, we will store your PII for a reasonable time for record keeping purposes. The information that we store is usually deleted as space requires or in the normal course of business.

We also collect Non-Personally Identifiable Information (Non-PII) via the Site. Non-PII cannot be used to contact any single person or entity and may include your IP address, pages viewed on this Site, browser type, Internet Service Provider, the time/date of your visit to this Site, and your computer’s operating system (e.g., Windows XP). Turn uses this information for internal purposes such as to administer the Site, improve and customise the Site, help Turn understand and analyse how the Site is being used and to track aggregate Site usage.

Cookies and Web Beacons

We use “cookies” and web beacons to help us manage this Site. Cookies are small text files that contain a string of alphanumeric characters. We also use persistent cookies on this Site in order to help us manage the opt-out process for our Technology. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Web beacons (also known as “1X1 pixels” or “clear GIFs”) are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For more information about cookies and web beacons please visit http://www.allaboutcookies.org/cookies/.

Third Party Websites

The Site may contain links to other websites. Such websites may use cookies and/or other data collection tools. Turn is not responsible for the privacy practices, policies or content of such other websites. Turn encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Turn has no control over the use of information by third party websites, and you should exercise caution when deciding to disclose any PII to those websites.

Access / Updating / Deleting your PII

If you’d like us to update, correct, delete, or deactivate any PII that you have provided to us on this Site, please send your request to us at privacy@turn.com and we will process your request within a reasonable period of time after receipt.


Information Collection and Use

Turn is a member of the Network Advertising Initiative (“NAI”) and is in compliance with the NAI’s Self-Regulatory Principles.

Overview of Turn’s Technology

Our Technology collects information about the website(s) that you visit and the advertisements that you see while online. You may encounter our Technology: when Turn or one of our Business Partners purchase online advertisements on a website that you visit; and/or when one of our Business Partners places one of our web beacons on its website, which you visit.

We use the information collected by our Technology in order to help make the Turn Ads you see more relevant to you, and for ad delivery and reporting purposes.

What information is collected?

Turn does not collect PII via our Technology. Our Technology does collect and use Non-PII, including: the IP address used to access the Internet, the type of browser used, which and how many Business Partner web pages have been viewed, search terms entered on Business Partner websites, referring/exit pages, and the date and time a Turn Ad was viewed.

Turn uses this information to analyse trends, identify the audience most likely to respond to an advertisement and to tailor advertisement placement for our Business Partners accordingly. We may also aggregate this information and share it with Turn’s affiliates, advertisers, employees, customers and Business Partners.

Turn does not create nor use any sensitive data segments to tailor ads on behalf of our advertiser clients. However, we recognise that consumers may have differing opinions regarding which data segments are sensitive. In order to provide transparency around potentially sensitive data segments collected and used by Turn, we will provide examples of them here. For example, we may collect health related segments of consumers that we believe may have an interest in healthy living because they have visited websites that are focused on health related topics such as yoga and healthy living. Similarly, we may collect financial related segments of consumers that we believe may have an interest in investing because they’ve visited websites that are focused on investment strategies or searched for ”investment tips.”

While we don’t consider any of the above data segments to be sensitive, we think it’s important to provide this transparency to help you have a better idea of which segments might be collected by us, so you can make informed decisions.

Cookies and Web Beacons

Turn uses cookies and web beacons in connection with our Technology. Cookies help Turn better understand the effectiveness of a Turn Ad (for example, by tracking the way in which you may respond to, select and interact with a Turn Ad or any content provided therein, or the location and context in which you view a Turn Ad). Turn’s cookies also help control the number of times you view a Turn Ad. Most Internet browsers automatically accept cookies. By editing its options, you can instruct your browser to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to enjoy the full functionality of many of the websites you visit. As an alternative to deletion/disabling of cookies, you can also choose to opt out of cookie-based data collection.

Turn also uses web beacons, in combination with cookies, to analyse usage patterns. The use of a web beacon allows Turn to record that someone has visited a particular webpage, along with additional Non-PII that the website may choose to include with the beacon.

Third Party Links and Websites

Turn Ads may contain links to other websites, including those of our Business Partners. Such websites may use cookies and/or other data collection tools. Turn is not responsible for the privacy practices, policies or the content of such websites. Turn encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Turn has no control over the use of any information by third party websites, and you should exercise caution when deciding to disclose any PII. Similarly, Turn does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third-party, including those of our Business Partners, and this Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.

Information Relating to Children

Our products and services are designed for those 13 years of age and older. We do not knowingly collect PII from anyone under the age of 13. If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.



Info Storage / Security / Integrity

Storage of Non-PII

We retain the Non-PII collected via our Technology for up to 180 days in order to ensure that our Technology is functioning properly. After 180 days, we render this information anonymous and store it for up to three years.

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.

Data Integrity

Turn processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.



Access/ Info Sharing/ Disclosure

Turn will allow an individual access to their Personal Information to the extent it is available and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. If you’d like us to update, correct, delete or deactivate any PII that you have provided to us, please send your request to us at privacy@turn.com and we will process your request within a reasonable period of time after receipt.

Information Sharing and Disclosure

Disclosure of Information to Third Parties

We do not collect PII via our Technology, and we do not sell, rent or share PII collected on the site with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.

We may share Non-PII collected via our Technology with Web Partners. Similarly, we may enhance the Non-PII collected via our Technology with Non-PII collected from Business Partners. This information cannot be used to contact or identify any person individually.

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Finally, we may transfer information, including any PII collected via the Site, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.



Enforcement, Questions and Complaints

Turn uses myriad processes to ensure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

To address any issues regarding our compliance with the NAI Self-Regulatory Principles, Turn, along with the NAI and other NAI members, have created a compliance programme that incorporates attestation reviews, a consumer complaint process, sanctions and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI’s Self-Regulatory Code of Conduct. Please refer to the NAI site for more information.

Privacy Complaints by European Union Citizens:

In compliance with the Safe Harbour Principles, Turn commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union citizens with enquiries or complaints regarding this privacy policy should first contact Turn at:

Privacy Officer
Turn Inc.
835 Main St.
Redwood City, CA 94063-1901
privacy@turn.com

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Turn commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact privacy@turn.com. Turn has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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 by Turn, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Council of Better Business Bureaus, Inc.
www.bbb.org/us/safe-harbor-complaints/


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Partnerships and Associations

DAA

The Digital Advertising Alliance (DAA) is a coalition of digital advertising companies that have created a self-regulatory code for online behavioral advertising alliance. Turn is in compliance with the DAA Self-Regulatory Code.

NAI

 

The Network Advertising Initiative (NAI) is a coalition of online advertising companies committed to complying with tough self-regulatory standards that establish and reward responsible business and data management practices. Turn is a participating member of NAI and compliant with NAI self-regulation principles.

 

We self-certify compliance with U.S.-EU Safe Harbour Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries. Turn has certified that it adheres to the Safe Harbour Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbour programme, and to view our certification page, please visit http://www.export.gov/safeharbor/

IAB

The Interactive Advertising Bureau is comprised of more than 500 leading media and technology companies that are responsible for selling 86% of online advertising in the United States. On behalf of its members, the IAB is dedicated to the growth of the interactive advertising marketplace, of interactive’s share of total marketing spend, and of its members’ share of total marketing spend.

Center for IPL

Turn is a member of The Centre for Information Policy Leadership at Hunton & Williams LLP, a member-driven privacy think-tank that provides leadership in developing policy to ensure privacy and information security while balancing economic and societal interests. The Centre’s membership includes more than 40 companies from multiple sectors. Turn participates in industry discussion groups that bring thought leaders, consumer advocates, technical experts and policymakers together to discuss policy topics and encourage responsible information governance in today’s digital society.

Evidon

Turn also partners with Better Advertising, whose mission is to enable advertisers, their partners and industry associations to be more transparent in how consumer data is collected and used for online advertising. Working with Better Advertising’s industry leading partners, Turn help develop tools and practices for marketers to ensure consumer privacy protection by providing consumers access to clear information and choices.


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