Privacy policy

Effective as of: June 15, 2021

Welcome to Turn. We build technology-enabled systems that produce reusable products that are trackable and can be linked back to our factories to be washed and reused. To do that, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you use any of our apps, use our websites, buy merchandise from us, or take part in live events and promotions (the "Services").

You should also read our Terms of Service which set out the contract between you and Turn.

1. Who decides how your information is used?

Turn is the data controller responsible for making decisions about how we use your personal information. If you have any questions or comments on this policy, you can:

Email us at Assistant@turnsystems.com

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you or your household ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service:

When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the in-app username you choose to use on our Services, and internal account IDs that we assign to your account.

You must have an account with a supported external single sign-on service to use our Services. As such, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Turn Services.

If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.

If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.

Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.

We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for our Services, while you are not directly interacting with the Services), including how you move around and events that occur during use.

We also collect and use your app actions, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the Services for you.

We also use the information above to show in-app sponsored locations that are in your vicinity as part of the experience.

We further use the information above in order to provide technical and customer support to you.

You also give us Personal Data when you make a purchase through us, subscribe to our publications, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, date of birth (as needed to verify eligibility), and email address. We use that information to fulfil those Services to you and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, and preferences and your in-app purchases to understand who is using our Services and how.

Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.

Using your internal account ID in order to attribute to your account any user content (such as local points of interest) that you elect to submit to Turn through the Services.

Using your email address and device information in order to share updates and news about the Services with you either within the app or by email. You can unsubscribe from these at any time in your device settings or in-app settings.

To offer new or additional features for our Services.

To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.

We will only use your Personal Data to do the following if we have your consent:

If you elect to turn on background activity tracking in our Services we will collect your Personal Data as you use the Services as well as in the background when you do not have the Services open on your device. You can change your mind and turn off background activity tracking at any time in your device settings or in-app settings.

Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.

We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

While you may disable the usage of cookies through your browser settings, Turn currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as described below:

Information Shared with Our Service Providers. We engage external service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:

run, operate and maintain our mobile apps through third party platform and software tools;

perform content moderation and crash analytics;

run email and mobile messaging campaigns;

perform marketing analytics;

administer live events, competitions, sweepstakes and promotions, including registering players, managing check-in and attendance, verifying eligibility and prize fulfilment;

provide technical and customer support; and

process payments for live events ticketing or other purchases.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third Party Service in accordance with their own privacy policy. Such an external service provider does not share your financial information, like credit card number, with Turn, but it may share limited information with us related to your purchase, like your zip or postal code.

Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

4. How your Personal Data is transferred

Turn operates its Services across the globe. Your Personal Data will very likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA by ensuring that at least one of the following safeguards is implemented:

The country that your Personal Data is transferred to is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data as the EEA.

We use specific contracts approved by the European Commission which give Personal Data the same protection as it has in Europe when we engage with service providers.

Where we engage with service providers in the USA, they are part of the EU-US Privacy Shield, which requires them to provide the same protection of your Personal Data as it has in the EEA.

5. How we keep your Personal Data safe

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

7. Your rights and choices

You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at:

For all Services at Assistant@turnsystems.com.

You can:

Request access to the Personal Data we hold on you by emailing Assistant@turnsystems.com.

Delete or correct your Personal Data. The easiest way to update your account information is via your in-app settings. You can also submit a customer support request through our website.

Object to us processing your Personal Data. Some of the Personal Data we hold is necessary for us to provide the Services to you and fulfill the promises we make to you in the Terms of Service.

Ask us to stop using your Personal Data, including for marketing and promotional purposes (but be aware that sometimes we need to use your Personal Data in order for you to use the Services).

Have your Personal Data transferred to another organization (where it is technically feasible).

Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first. However, if you're based in the EEA and believe that we have not complied with data protection laws, you can complain to our regulator, the UK Information Commissioner’s Office, or with your local supervisory authority.

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days.

8. Children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not collect Personal Data from them. We define “children” as follows:

Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.

Residents of the Republic of Korea, anyone under 14 years old.

Residents of other regions: anyone under 13 years old

Turn Resources contains information on the age requirement for each of our Apps.

Verifiable parental consent is required for the collection, use, or disclosure of a child's Personal Data. Turn will not collect, use, or disclose any Personal Data from a child if their parent or guardian does not provide such consent. We may ask a Child to provide a Parent’s email address in order to request this consent, and the Parent’s email address will be deleted if consent is not provided within a reasonable time.

Once verified, a parent can consent to their child accessing the Service. For user account creation, Turn will collect the in-app username the Child chooses to use on our Services, internal account IDs that we assign to the Child’s account, and, with the parent’s permission, the Child’s personal email address. We need that information to authenticate the Child’s account, to make sure the Child is eligible and able to receive the Services, and so that the Child receives the correct version of the Services. As the Child accesses and uses the Service, Turn will also collect and use the Child’s device location and other Personal Data listed in this Privacy Policy for the purpose of operating and providing the Service to the Child, as described in this Privacy Policy. If we need to collect additional information for other purposes we will first seek your permission.

Parents have the right to review their Child’s Personal Data; to have their Child’s Personal Data deleted; and to refuse further collection, use, and/or disclosure of their Child’s Personal Data by notifying us. As a parent, you understand that Turn has a legitimate interest in providing your Child’s Personal Data collected via the Services to external providers for the sole purpose of administering or providing the Services, as described in Paragraph 3 of this Privacy Policy.

If we learn that we have collected Personal Data of a Child, and we do not have parental consent, we will take steps to delete such information from our files as soon as possible.

If you have questions about our privacy practices for Children, please contact us at Assistant@turnsystems.com or 77 O’rorke rd. Penrose, Auckland 1061.

9. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

10. Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.

11. Disclosures Specific to California Residents

California law requires that we make certain disclosures about your data. We do not sell your Personal Data. The information listed in Section 2 falls under the following California Consumer Privacy Act (CCPA) categories: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information.