Privacy Policy
Effective: January 02,2023
TurnUp, (referred to in this policy as “TurnUP” or “we” or “our”) is committed to maintaining the trust of our customers. Please read this policy (the “Privacy Policy”) carefully to learn more about TurnUp’s privacy practices and policies with respect to Customer Data (defined below) that is collected through the data export interface (“The Admin Panel”), and used through the TurnUp Internet application (the “Web App”). This Privacy Policy applies to “Personal Data,” which is Customer Data that is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection law.
1. TurnUp IS A SERVICE PROVIDER FOR ITS CUSTOMERS
TurnUp customers, and not TurnUp, determine how and why Personal Data submitted to the TurnUp Service is used, either by or at the direction of such customers. With respect to such Personal Data, (1) TurnUp is a “service provider” under the California Consumer Privacy Act (“CCPA”). This Privacy Policy describes how TurnUp processes Personal Data as a Data Processor for the purpose of providing the TurnUp Service to our customers pursuant to the applicable data processing terms with those customers.
As Data Controllers, TurnUp’s customers are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with CCPA, and other laws requiring such disclosures.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy covers the processing of Personal Data that TurnUp performs as a Data Processor for and on behalf of its customers.
3. PERSONAL DATA PROCESSED UNDER THIS POLICY
TurnUp acts as a Data Processor with respect to any Personal Data comprised in the Customer Data. By “Customer Data” we mean the content or information which individuals authorized by a customer submit to the TurnUp Service.
4. USE OF YOUR PERSONAL DATA
TurnUp uses the Personal Data to provide the TurnUp Service to our customers pursuant to the applicable data processing terms with those customers. This will include integration of the TurnUp Service.
5. DISCLOSING YOUR PERSONAL DATA
TurnUp does not disclose your Personal Data to third parties except where permitted or requested by our applicable customer, or where required by law.
No Sale of Personal Data:TurnUp does not sell, rent or lease your Personal Data.
Service Providers:TurnUp may disclose your Personal Data to our contracted service providers so that they can provide TurnUp with services, such as IT, system administration and hosting, and customer support.
TurnUp will, to the extent required by law and the applicable customer contract, obtain assurances before disclosing Personal Data to a subcontractor or third-party agent that the recipient will: (a) use the Personal Data only to assist TurnUp in providing, maintaining or improving the TurnUp Service, (b) provide at least the same level of protection for Personal Data as is required of TurnUp, and (c) notify TurnUp if the recipient is no longer able to provide the required protections. Upon notice, TurnUp will act promptly to endeavor to stop and remediate any unauthorized processing of Personal Data by the recipient. TurnUp will remain liable for onward transfers to its subcontractors and third-party agents.
6. SECURITY OF YOUR PERSONAL DATA
As specified in the data processing terms with the applicable Data Controller, TurnUp takes reasonable and appropriate measures to protect your Personal Data from loss, misuse, and inappropriate access. We use standard, industry-wide best practices such as firewalls, encryption of Customer Data at rest and in transit, and (in certain areas) Secure Socket Layers (“SSL”) to protect your information. However, as effective as encryption technology is, no security system is impenetrable. TurnUp cannot guarantee the security of our databases, nor can we guarantee that information that is supplied won't be intercepted while being transmitted to TurnUp over the Internet.
7. DATA RETENTION
Storage periods depend on the data processing terms with our customers and their choices, type of Personal Data, purposes of its collection and processing, and applicable law.
8. CHILDREN
TurnUp does not direct the TurnUp Service and associated websites to children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us at [email protected].[1] [2]
9. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS[3] [4]
This section provides additional details about the personal information TurnUp collects and receives about California consumers and the rights afforded to such consumers under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information TurnUp has collected over the last 12 months, including the categories of sources, please see PERSONAL DATA PROCESSED UNDER THIS POLICY in Section 3 above. TurnUp collects and receives this information for the business and commercial purposes described in USE OF YOUR PERSONAL DATA in Section 4 above. TurnUp discloses this information as described in DISCLOSING YOUR PERSONAL DATA in Section 5 above. TurnUp does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by sending us an email at [email protected].[5] [6] We will verify your request and may request government identification or other information in order to do so. Consumers can also designate an authorized agent to exercise these rights on their behalf.
10. INTERNATIONAL DATA TRANSFERS
TurnUp is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
12. CHANGES/UPDATES
TurnUp reserves the right to update or modify this Privacy Policy at any time without prior notice. Any updates will be posted on the TurnUp website.