Last Updated: February 24, 2017
Turn Inc. provides its business partners—advertisers and their agencies, website and app publishers, other ad inventory providers, and data vendors—with technologies that enable the serving and display of relevant advertisements to individuals who access a publisher’s website, mobile app, or other online content. Turn’s technology also helps its partners collect and manage the data generated by such advertisements as well as data that its business partners may already have and data that they collect regarding visitors to their digital properties, including websites and mobile applications.
Turn advertising technology collects and uses data to help make online advertising more relevant, and for ad delivery and reporting purposes. By delivering more relevant advertisements, Turn plays an important role in keeping the Internet free, dynamic, and vibrant. That’s because advertisers will pay more when their ads are tailored to an audience’s interests, and publishers of websites and apps get more money when their audiences receive tailored advertisements instead of generic ones. That helps publishers continue to provide great content at a great price—often free.
The Turn privacy guidelines explain the various ways individuals may interact with Turn and Turn advertising technology, and the ways in which individuals may exercise control over the use of information collected by Turn.
Here’s how Turn may interact with individuals and data about them:
Data Collected Through Turn Advertising Technology. The Turn privacy guidelines describe Turn’s privacy practices relating to its tailored advertising technology. Learn about Turn’s privacy practices as they pertain to information collected through its advertising technology.
Data Collected Through Turn.com and from Turn’s Customers. The Turn privacy guidelines also describe Turn’s privacy practices as they pertain to visitors to the turn.com website as well as data collected from Turn’s customers. Learn about how Turn uses information collected on turn.com and from Turn's Customers.
General Privacy Guidelines That Apply to Data Collected Through Turn.com, from Turn’s Customers, and Through Turn Advertising Technology. Many of Turn’s privacy guidelines—including Turn’s data security, integrity, and transfer provisions—are applicable to data collected through its website, from its customers, and through Turn advertising technology. Learn about these generally applicable privacy practices.
Opt Out of Tailored Advertising from Turn Advertising Technology
To opt out of receiving the tailored advertising made possible by Turn advertising technology in your current browser or mobile applications on your current device, please visit Turn’s Consumer Opt-Out page.
Partnerships and Associations
Turn participates in a number of self-regulatory organizations and adheres to those organizations’ self-regulatory codes in the jurisdictions in which Turn operates. See a list of some of Turn’s partnerships and associations.
Privacy Guidelines: Turn Advertising Technology
Overview of Turn Advertising Technology
Turn advertising technology collects and uses data to help make online advertising more relevant, and for ad delivery and reporting purposes. This plays an important role in keeping content on the Internet and within mobile apps largely free, dynamic, and vibrant by improving the relevancy of advertisements displayed throughout the Internet.
Here’s how it works: Turn advertising technology collects data that is not personally identifiable information (non-PII) about the websites and apps that a browser or device interacts with, and the advertisements a browser or app displays. This information may include non-PII browser or device-specific identifiers (such as mobile device advertising identifiers, IP address or your browser’s user agent string) and non-PII demographic and interest information provided by third parties. An individual may encounter Turn advertising technology when:
Turn or a business partner purchases online advertisements on a website that the individual visits or an app that the individual uses.
A Turn business partner places one of Turn’s web beacons on a website that the individual visits or uses.
An individual interacts with an app from which Turn collects data.
Turn advertising technology also offers data management services to business partners via Turn’s data management platform (DMP). The Turn DMP enables Turn’s business partners to collect, store, and analyze non-PII about their audiences. Turn’s business partners may use the DMP and Turn’s data collection tools to develop and name custom data segments. Turn does not exercise control over the manner in which its business partners label their custom data segments in the DMP, but as applicable, Turn contractually requires that its business partners using the DMP adhere to self-regulatory codes offered by the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), and/or certain other industry standards. Turn also contractually prohibits its business partners using the DMP from bringing PII or sensitive non-PII audience data into the DMP.
What Information Does Turn Advertising Technology Collect?
Turn advertising technology collects and uses only non-PII, including: information about the device and IP address used to access the Internet; the browser or application used; which, and how many, business partner web pages have been viewed by a browser or application; search terms entered on business partner websites; referring and exit pages; the date and time an advertisement was viewed; location data; browser or device-specific identifiers (such as mobile device advertising identifiers or your browser’s user agent string); and other similar information. In certain instances, Turn may collect and match this non-PII across devices, browsers, or applications for the purposes of identifying devices and providing more relevant advertising. Turn also obtains non-PII from third party data vendors that receive such non-PII pursuant to their own privacy policies. Turn does not collect PII via its advertising technology.
The Turn ID and ID Syncing
Turn associates the non-PII that it collects about a browser or device with a randomly-generated pseudonymous identifier known as a Turn ID, which itself is non-PII. Turn uses ID Syncing (described below) to associate Turn IDs with identifiers and data from business partners and other industry participants in an effort to display relevant advertisements on a wider range of websites, apps, and content. As part of this process, Turn may populate a Turn cookie with a new or existing Turn ID.
ID Syncing (also known as cookie syncing or cookie matching) is a common and useful industry practice that enables advertisers to use data to coordinate an advertising campaign across multiple publishing platforms and advertising service providers.
As an example, suppose an individual uses a web browser to visit a merchant’s website and then leaves the website. The merchant wants to advertise relevant products to that visitor after she leaves the website. To do so, the merchant stores a cookie on the visitor’s browser with an ID (say “123”) and associates the ID with information about what the visitor shopped for on the merchant’s website. If the merchant wanted to use that information to advertise on other websites, the merchant could buy advertising through an online advertising exchange or marketplace. In order to buy appropriate advertising, the merchant would need to match the ID “123” with the ID that the exchange has assigned to the same visitor (for example, exchange ID “XYZ”). Using ID Syncing, the merchant can know that its ID 123 is associated with the same browser or device as the marketplace ID XYZ, and the merchant may be able to show more relevant advertisements to the visitor.
How Is the Collected Information Used?
Turn uses the non-PII it collects to identify the audience most likely to respond to a particular ad, to serve those ads, and to analyze trends. This helps support the online advertising ecosystem, app and website developers, and consumers by supporting content and delivering more effective advertisements. Turn may also share this information with its affiliates and business partners.
Turn advertising technology enables Turn’s business partners to use advertising segments to deliver relevant advertising tailored to consumers’ interests. An advertising segment is defined by non-PII attributes, which often includes combinations of information such as geography, age range, gender, activities, and/or interests.
Turn customers may use non-sensitive health-related segments to help deliver tailored advertising. For example, Turn customers may deliver tailored advertising regarding healthy living because a browser previously visited websites that are focused on health-related topics such as yoga and healthy eating. Review a list of health-related segments that are made available to Turn’s business partners by third-party data providers.
Cross-App and Cross-Device Advertising, Ad Delivery, and Reporting
Turn may collect and use the information and the data segments described above for cross-app advertising, i.e., advertising across browsers and apps on a single device, as well as cross-device advertising, i.e., advertising across multiple devices. Turn also collects and uses cross-app and cross-device information for ad delivery and reporting purposes. As described elsewhere in these privacy guidelines, Turn does not collect PII via its advertising technology, including across apps and devices.
Turn uses certain techniques to enable its advertising technology to serve meaningful advertising content on behalf of its customers and business partners across apps and devices, including cookie and ID Syncing and similar practices.
Market Research Surveys
Turn may serve ads that invite you to participate in market research surveys. These surveys allow you to share your opinions, if you wish to do so. The surveys collect the same types of Non-PII Turn collects when serving ads in addition to any survey responses. Turn uses this information to better understand market research trends and help ascertain the effectiveness ads delivered by Turn’s technology.
Data Retention for Turn Advertising Technology
Turn removes non-PII associated with a Turn ID from its ad-decisioning database if more than 30 days have passed since it has seen any activity associated with the Turn ID, or has delivered advertising to a computer or device associated with the Turn ID. However, if the same non-PII is associated with both an active and inactive Turn ID, the non-PII will only be deleted from the inactive Turn ID and will not be deleted from the set of information associated with the active Turn ID. Turn may retain this and other data it collects in other formats for as long as necessary for reasonable and legitimate business purposes including fraud prevention, audit and legal compliance, and billing disputes.
Non-PII associated with a Turn ID may be stored in the Turn DMP indefinitely. This information may be used to create advertising segments but will only be used to deliver tailored advertising to active Turn IDs.
Third-Party Links and Websites
Privacy Guidelines: Turn.com and Turn’s Customers
Information Collected from Website Visitors and Turn’s Customers
Turn collects personally identifiable information (PII) through www.turn.com—including, for example, an individual’s first and last name, physical address, telephone number, or email address—only when an individual chooses to provide it to Turn. Individuals may choose to send Turn their PII in an email or by completing an online form on Turn’s website for the purpose of receiving more information about Turn’s products and services. Turn will use any collected information to contact the individual in accordance with the individual’s stated preferences. Turn also collects PII from Turn customers, including, for example, email addresses, telephone numbers, and billing details in the ordinary course of business. Turn uses this information for its business purposes, such as to maintain customer accounts, billing, password management, and to service other customer needs.
The data Turn collects about website visitors is subject to the data security, integrity, and transfer practices described elsewhere in the Turn privacy guidelines.
Links on Turn.com to Third Party Websites
Data Retention for Turn.com and Turn’s Customers
Turn stores PII as long as relevant for record keeping, business, and compliance purposes. The information that Turn stores may be deleted as space requires or in the normal course of business. To opt-out of receiving more information about Turn’s products and services, you may send an email to email@example.com.
Privacy Guidelines: Turn.com, Turn's Customers and Turn Advertising Technology
For more information about cookies, visit http://www.allaboutcookies.org/cookies. If Internet browser settings are used to “clear” or delete cookies, this may inadvertently delete cookies that have been set by websites to honor an “opt-out” status (including the Turn opt-out cookie).
If you delete Turn cookies from your browser, that action only deletes the cookies in your browser and does not send any information to Turn. The next time Turn is provided the opportunity to set cookies in your browser or app (usually when Turn places an ad), it will do so. The Turn ID associated with one or more of the Turn cookies may or may not be different than the Turn ID associated with previously deleted Turn cookies.
If you delete Turn cookies from your browser, that action also has no impact on the non-PII previously collected and stored by Turn. Turn will retain the information as described in the Data Retention for Turn Advertising Technology section. If Turn is able to associate one Turn ID with other Turn IDs (for example, through the receipt and use of a separate identifier, such as a mobile device advertising identifier, browser’s IP address and user agent string, and/or ID syncing), Turn may transfer the non-PII associated with one Turn ID to the other Turn IDs.
Turn also uses web beacons, in combination with cookies, to analyze usage patterns on its website and through Turn advertising technology. The use of web beacons (which are also referred to as tags or pixels) allows Turn to record that a particular device, browser, or application has visited a particular webpage, along with additional non-PII that the website may choose to include with the beacon. For more information about web beacons, visit http://www.allaboutcookies.org/faqs/beacons.html.
Turn has implemented reasonable security measures to protect the information in its care, both during transmission and once Turn receives 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 entirely secure, however. Therefore, while Turn strives to use commercially reasonable means to protect information, Turn cannot guarantee its absolute security.
Turn processes information in a way that is compatible with, and relevant to, the purpose for which it was collected. To the extent necessary for those purposes, Turn takes reasonable steps to ensure that any information in its care is accurate, complete, current, and reliable for its intended use.
Disclosure of Information to Third Parties, Onward Transfer
Turn may share information, including any PII collected via its website, with trusted third parties who provide services for Turn. These third parties are prohibited from using the information Turn provides for purposes other than performing services for Turn. Turn may also share non-PII, including data collected across applications or devices, with business partners. Similarly, Turn may enhance the non-PII collected via its advertising technology with non-PII collected from business partners. Non-PII is information that cannot, on its own, be used to contact or identify any person individually.
If Turn uses your PII for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if Turn discloses it to a third party acting as a controller not previously disclosed to you, Turn will offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt in where sensitive information is involved. Turn remains responsible under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Turn proves that it is not responsible for the event giving rise to the damage.
Turn may be required to disclose information, including any PII collected via its website, to third parties when Turn reasonably believes it is obligated to do so by law (including to meet national security or law enforcement requirements), and 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, Turn may transfer information, including any PII collected via its website, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
Accessing, Updating, or Deleting PII
Subject to applicable law, Turn may recognize an individual’s right to access their PII and allow individuals to request a summary of the PII they have provided to request an update to or deletion of inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the rights of persons other than the individual would be violated. To update or delete any inaccurate PII provided to Turn, send a request to firstname.lastname@example.org. Turn will process the request within a reasonable period of time after receipt.
Information Relating to Children
Turn.com and Turn advertising technology are designed for individuals who are 13 years of age and older. Turn does not knowingly collect PII from anyone under the age of 13 on its website or via its advertising technology. If Turn were made aware that it had received PII from someone under 13, Turn would use reasonable efforts to remove that information from its records.
Questions and Complaints
Turn uses reasonable processes to ensure compliance with these privacy guidelines and periodically verifies that they are accurate. Turn encourages individuals with concerns about its practices to contact Turn at email@example.com. Turn will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
Recourse and Enforcement
Turn has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Turn has further committed to refer unresolved privacy complaints under the U.S.-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, please visit http://www.bbb.org/EU-privacy-shield/bbb-eu-safe-harbor-dispute-resolution/a> for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Changes to Turn Privacy Guidelines
Visit this page periodically to stay aware of any changes to these privacy guidelines, which Turn may update from time to time. If Turn modifies these guidelines, Turn will make the revised privacy guidelines available through turn.com and indicate the date of the latest revision.
Partnerships and Associations
Networking Advertising Initiative
The Network Advertising Initiative (NAI) is a coalition of online advertising companies committed to complying with self-regulatory standards that establish responsible business and data management practices. Turn is a participating member of NAI and is compliant with NAI self-regulatory principles. The NAI offers a tool to express a preference to opt-out of the receipt of tailored advertising, available here.
The Digital Advertising Alliance
The Digital Advertising Alliance (DAA) is a coalition of digital advertising companies that have created a self-regulatory code for online behavioral advertising. Turn complies with the DAA self-regulatory code. The DAA also offers a tool to express a preference to opt out of the receipt of tailored advertising, available here.
The European Interactive Digital Advertising Alliance
The European Interactive Digital Advertising Alliance (eDAA) has been founded by a European industry coalition representing advertisers, the advertising agency sector, the direct marketing sector, the advertising network sector and the media sector. eDAA’s principal purpose is to license the ‘OBA Icon’ to companies involved in tailored advertising across Europe. The OBA Icon is a consumer-facing, interactive symbol that links consumers to an online portal, www.youronlinechoices.eu, where they can find easy-to-understand information on the practice of tailored advertising as well as a mechanism for exercising informed choice – if they wish to do so, consumers may opt out of tailored advertising by some or all member companies.
The Digital Advertising Alliance of Canada
The Canadian Self-Regulatory Program for Online Behavioral Advertising (DAAC) is designed to give consumers a better understanding of, as well as greater control over, the ads that are displayed to them based on their online behavior. The DAAC offers a tool to express a preference to opt out of the receipt of tailored advertising, available here.
The Interactive Advertising Bureau
The Interactive Advertising Bureau (IAB) is comprised of more than 500 leading media and technology companies. On behalf of its members, the IAB is dedicated to the growth of the interactive advertising marketplace, of interactive advertising’s share of total marketing spend, and of its members’ share of total marketing spend. Learn more at www.iab.net.
IAB Europe is the voice of digital business. Its mission is to protect, prove, promote and professionalize Europe's online advertising, media, research and analytics industries. Together with its members – companies and national trade associations – IAB Europe represents over 5,500 organizations. Learn more at www.iabeurope.eu.
The Internet Advertising Bureau (IAB) is the UK trade association for digital advertising, representing most of the UK’s leading brands, media owners and agencies. Learn more at www.iabuk.net.