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.
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.
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.
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.
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.
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.
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.
© Tuurnt, Inc.