3. WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We only process your
personal information when we believe it is
necessary and we have a valid legal reason (i.e.
,
legal basis) to do so under applicable law, like
with your consent, to comply with laws, to
provide you with services to enter into or fulfill
our contractual obligations, to protect your
rights, or to
fulfill
our legitimate business
interests.
If you are
located in Canada, this section applies
to you.
We may process your
information if you have given us specific permission
(i.e.,
express consent) to use your personal information
for a specific purpose, or in situations where your
permission can be inferred (i.e.,
implied consent). You can withdraw
your consent at
any time.
In some exceptional cases,
we may be legally permitted under applicable law to
process your information without your consent,
including, for example:
- If collection is
clearly in the interests of an individual and
consent cannot be obtained in a timely
way
- For investigations and
fraud detection and prevention
- For business
transactions provided certain conditions are
met
- If it is contained in a
witness statement and the collection is
necessary to assess, process, or settle an
insurance claim
- For identifying
injured, ill, or deceased persons and
communicating with next of kin
- If we have reasonable
grounds to believe an individual has been, is,
or may be victim of financial abuse
- If it is reasonable to
expect collection and use with consent would
compromise the availability or the accuracy of
the information and the collection is reasonable
for purposes related to investigating a breach
of an agreement or a contravention of the laws
of Canada or a province
- If disclosure is
required to comply with a subpoena, warrant,
court order, or rules of the court relating to
the production of records
- If it was produced
by an individual in the course of their
employment, business, or profession and the
collection is consistent with the purposes for
which the information was produced
- If the collection
is solely for journalistic, artistic, or
literary purposes
- If the information
is publicly available and is specified by the
regulations
4.
WHEN AND WITH WHOM DO WE SHARE
YOUR PERSONAL
INFORMATION?
In
Short: We may share
information in specific situations described
in this section and/or with the following
third
parties.
Vendors,
Consultants, and Other Third-Party Service
Providers. We may share your data with
third-party vendors, service providers, contractors,
or agents (
"third parties") who
perform services for us or on our behalf and require
access to such information to do that work. We have contracts
in place with our third parties, which are designed
to help safeguard your personal information. This
means that they cannot do anything with your
personal information unless we have instructed them
to do it. They will also not share your personal
information with any
organization
apart
from us. They also commit to protect the data they
hold on our behalf and to retain it for the period
we instruct.
The
third parties we
may share personal information with are as
follows:
- Advertising,
Direct Marketing, and Lead
Generation
Amazon
Mobile Ads
,
Apple
iAd
,
Bing
Ads
,
Facebook Audience
Network
,
Google
AdSense
,
Salesforce Marketing
Cloud
and
Salesforce Sales Cloud
- Allow
Users to Connect to Their Third-Party
Accounts
Amazon
account
,
Discord account
,
Dribbble account
,
Dropbox account
,
Facebook account
,
Foursquare account
,
Github
account
,
Google
account
,
Instagram account
,
LinkedIn account
,
Pinterest account
,
Reddit
account
,
Twitter account
,
WordPress account
,
Yahoo!
account
,
Youtube account
and
Battle.net account
Microsoft Azure
,
Amazon
Web Services (AWS)
and Google
Cloud Platform
- Communicate
and Chat with
Users
SMSAruba
and
SMSFactor
Google
Site Search
,
YouTube video embed
,
MailChimp widget plugin
and
Instagram embed
Amazon
Glacier
- Functionality
and Infrastructure
Optimization
Amazon
Web Services
Facebook Custom Audience
,
Facebook Remarketing
,
Google
Ads Remarketing
,
Google
Analytics Remarketing
,
Salesforce DMP
,
Twitter Remarketing
,
Twitter Tailored
Audiences
and
LinkedIn Website
Retargeting
- Social
Media Sharing and
Advertising
Facebook advertising
,
Facebook social plugins
,
Google
Friend Connect
,
Google+ social plugins
,
Instagram advertising
,
LinkedIn advertising
,
LinkedIn social plugins
,
Twitter advertising
,
Twitter social plugins
and YouTube
social plugins
- User
Account Registration and
Authentication
Facebook Login
,
Google
OAuth 2.0
,
Google
Smart Lock
,
Google
Sign-In
,
Instagram Authentication
,
LinkedIn OAuth 2.0
,
YouTube OAuth 2.0
,
Twitter OAuth
and
Pinterest OAuth 2.0
- User
Commenting and
Forums
Facebook Comments
and Google
Tag Manager
Facebook Analytics
,
Facebook Ads conversion
tracking
,
Google
Ads
,
Google
Analytics
,
Google
Analytics for Firebase
,
Google
Tag Manager
,
Salesforce Analytics
Cloud
,
Twitter Ads conversion
tracking
and Yahoo
Ads conversion
tracking
Google
Play Console
and Google
Website
Optimizer
We also may
need to share your personal information in the
following situations:
- Business
Transfers. We may share or transfer
your information in connection with, or during
negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a
portion of our business to another
company.
- When we
use Google Maps Platform APIs. We
may share your information with certain Google
Maps Platform APIs (e.g.
,
Google Maps API, Places API).
We obtain
and store on your device (
"cache"
)
your location
for six (6) months
.
You may revoke your consent anytime by
contacting us at the contact details provided at
the end of this document.
- Affiliates. We
may share your information with our affiliates,
in which case we will require those affiliates
to honor
this privacy notice. Affiliates include our
parent company and any subsidiaries, joint
venture partners, or other companies that we
control or that are under common control with
us.
- Business
Partners. We may share your
information with our business partners to offer
you certain products, services, or
promotions.
- Offer
Wall. Our application(s) may
display a third-party hosted "offer
wall."
Such an offer wall allows third-party
advertisers to offer virtual currency,
gifts, or other items to users in return for
the acceptance and completion of an
advertisement offer. Such an offer wall may
appear in our application(s) and be
displayed to you based on certain data, such
as your geographic area or demographic
information. When you click on an offer
wall, you will be brought to an external
website belonging to other persons and will
leave our application(s). A unique
identifier, such as your user ID, will be
shared with the offer wall provider in order
to prevent fraud and properly credit your
account with the relevant reward.
5. WHAT IS OUR
STANCE ON THIRD-PARTY
WEBSITES?
In
Short: We are not
responsible for the safety of any
information that you share with third
parties that we may link to or who advertise
on our Services, but are not affiliated
with, our Services.
The Services
, including
our offer wall,
may link to third-party websites, online
services, or mobile applications and/or contain
advertisements from third parties that are not
affiliated with us and which may link to other
websites, services, or applications.
Accordingly, we do not make any guarantee
regarding any such third parties, and we will
not be liable for any loss or damage caused by
the use of such third-party websites, services,
or applications. The inclusion of a link towards
a third-party website, service, or application
does not imply an endorsement by us. We cannot
guarantee the safety and privacy of data you
provide to any third parties. Any data collected
by third parties is not covered by this privacy
notice. We are not responsible for the content
or privacy and security practices and policies
of any third parties, including other websites,
services, or applications that may be linked to
or from the Services. You should review the
policies of such third parties and contact them
directly to respond to your questions.
6.
DO WE USE COOKIES AND OTHER
TRACKING
TECHNOLOGIES?
In
Short: We may use
cookies and other tracking technologies
to collect and store your
information.
We may use
cookies and similar tracking technologies
(like web beacons and pixels) to access or
store information. Specific information
about how we use such technologies and how
you can refuse certain cookies is set out in
our Cookie Notice
.
7.
HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
In
Short: If you
choose to register or log in to our
Services using a social media account,
we may have access to certain
information about
you.
Our Services
offer you the ability to register and log in
using your third-party social media account
details (like your Facebook or Twitter
logins). Where you choose to do this, we
will receive certain profile information
about you from your social media provider.
The profile information we receive may vary
depending on the social media provider
concerned, but will often include your name,
email address, friends list, and profile
picture, as well as other information you
choose to make public on such a social media
platform.
If you log in
using Facebook, we may also request access
to other permissions related to your
account, such as your friends, check-ins,
and likes, and you may choose to grant or
deny us access to each individual
permission.
We will use
the information we receive only for the
purposes that are described in this privacy
notice or that are otherwise made clear to
you on the relevant Services. Please note
that we do not control, and are not
responsible for, other uses of your personal
information by your third-party social media
provider. We recommend that you review their
privacy notice to understand how they
collect, use, and share your personal
information, and how you can set your
privacy preferences on their sites and
apps.
8.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep
your information for as long as
necessary to
fulfill
the purposes outlined in this
privacy notice unless otherwise required
by law.
We will only
keep your personal information for as long
as it is necessary for the purposes set out
in this privacy notice, unless a longer
retention period is required or permitted by
law (such as tax, accounting, or other legal
requirements).
No purpose in this notice will
require us keeping your personal information
for longer than
the
period of time in which users have an
account with us
.
When we have
no ongoing legitimate business need to
process your personal information, we will
either delete or
anonymize
such information, or, if this is not
possible (for example, because your personal
information has been stored in backup
archives), then we will securely store your
personal information and isolate it from any
further processing until deletion is
possible.
9.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We aim to
protect your personal information
through a system of
organizational
and technical security
measures.
We have
implemented appropriate and reasonable
technical and
organizational
security measures designed to protect
the security of any personal information we
process. However, despite our safeguards and
efforts to secure your information, no
electronic transmission over the Internet or
information storage technology can be
guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers,
cybercriminals, or other
unauthorized
third parties will not be able to
defeat our security and improperly collect,
access, steal, or modify your information.
Although we will do our best to protect your
personal information, transmission of
personal information to and from our
Services is at your own risk. You should
only access the Services within a secure
environment.
10.
DO WE COLLECT INFORMATION
FROM
MINORS?
In
Short: We do not
knowingly collect data from or market to
children under 18 years of age.
We do not
knowingly solicit data from or market to
children under 18 years of age. By using the
Services, you represent that you are at
least 18 or that you are the parent or
guardian of such a minor and consent to such
minor dependent’s use of the Services. If we
learn that personal information from users
less than 18 years of age has been
collected, we will deactivate the account
and take reasonable measures to promptly
delete such data from our records. If you
become aware of any data we may have
collected from children under age 18, please
contact us at
wharrison@turexusa.com
.
11.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In
some regions, such as Canada
, you have rights that allow you
greater access to and control over your
personal information.
You
may review, change, or terminate your
account at any time.
In some
regions (like
Canada
), you have certain rights under
applicable data protection laws. These may
include the right (i) to request access and
obtain a copy of your personal information,
(ii) to request rectification or erasure;
(iii) to restrict the processing of your
personal information; (iv) if applicable, to
data portability; and (v) not to be subject
to automated decision-making. In certain
circumstances, you may also have the right
to object to the processing of your personal
information. You can make such a request by
contacting us by using the contact details
provided in the section "
HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?
"
below.
We will
consider and act upon any request in
accordance with applicable data protection
laws.
Withdrawing
your consent: If we are
relying on your consent to process your
personal information,
which may
be express and/or implied consent depending
on the applicable law,
you have the right to withdraw your
consent at any time. You can withdraw your
consent at any time by contacting us by
using the contact details provided in the
section "
HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?
"
below
.
However, please
note that this will not affect the lawfulness of
the processing before its withdrawal nor, when
applicable law allows,
will it affect the processing of your personal
information conducted in reliance on lawful
processing grounds other than consent.
Opting
out of marketing and promotional
communications: You
can unsubscribe from our marketing and
promotional communications at any time by clicking on
the unsubscribe link in the emails that we send,
replying
"STOP" or
"UNSUBSCRIBE"
to
the SMS messages that we send,
or by
contacting us using the details provided in the
section "
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
"
below. You will then be removed from the
marketing lists. However, we may still
communicate with you — for example, to send you
service-related messages that are necessary for
the administration and use of your account, to
respond to service requests, or for other
non-marketing purposes.
Account
Information
If you would at any
time like to review or change the information in
your account or terminate your account, you can:
-
Log in to your account
settings and update your user account.
Upon your request
to terminate your account, we will deactivate or
delete your account and information from our
active databases. However, we may retain some
information in our files to prevent fraud,
troubleshoot problems, assist with any
investigations, enforce our legal terms and/or
comply with applicable legal
requirements.
Cookies
and similar
technologies: Most Web
browsers are set to accept cookies by
default. If you prefer, you can usually
choose to set your browser to remove cookies
and to reject cookies. If you choose to
remove cookies or reject cookies, this could
affect certain features or services of our
Services.
You may also opt
out of interest-based
advertising by
advertisers
on our Services.
If you have questions
or comments about your privacy rights, you may
email us at
info@turexusa.com.
12.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web
browsers and some mobile operating systems
and mobile applications include a
Do-Not-Track (
"DNT"
) feature or setting you can activate
to signal your privacy preference not to
have data about your online browsing
activities monitored and collected. At this
stage no uniform technology standard for
recognizing
and implementing DNT signals has been
finalized
. As such, we do not currently respond
to DNT browser signals or any other
mechanism that automatically communicates
your choice not to be tracked online. If a
standard for online tracking is adopted that
we must follow in the future, we will inform
you about that practice in a revised version
of this privacy notice.
13.
DO UNITED STATES RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: If you are
a resident of
California
,
Colorado
,
Connecticut
, Utah
or
Virginia
,
you are granted specific rights
regarding access to your personal
information.
What
categories of personal information do we
collect?
We have
collected the following categories of
personal information in the past twelve (12)
months:
Category
|
Examples
|
Collected
|
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online
identifier, Internet
Protocol address, email
address, and account
name
|
NO
|
B.
Personal information as
defined in the California
Customer Records
statute
|
Name,
contact information,
education, employment,
employment history, and
financial
information
|
NO
|
C
. Protected
classification
characteristics under state
or federal law
|
Gender
and date of
birth
|
NO
|
D
. Commercial
information
|
Transaction
information, purchase
history, financial details,
and payment
information
|
NO
|
E
. Biometric
information
|
Fingerprints
and
voiceprints
|
NO
|
F
. Internet or other
similar network activity
|
Browsing
history, search history,
online
behavior
, interest data, and
interactions with our and
other websites,
applications, systems, and
advertisements
|
NO
|
G
. Geolocation data
|
Device
location
|
NO
|
H
. Audio, electronic,
visual, thermal, olfactory,
or similar information
|
Images
and audio, video or call
recordings created in
connection with our business
activities
|
NO
|
I
. Professional or
employment-related
information
|
Business
contact details in order to
provide you our Services at
a business level or job
title, work history, and
professional qualifications
if you apply for a job with
us
|
NO
|
J
. Education
Information
|
Student
records and directory
information
|
NO
|
K
. Inferences drawn
from collected personal
information
|
Inferences
drawn from any of the
collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics
|
NO
|
L. Sensitive
personal Information
|
|
NO
|
We will use and retain
the collected personal information as needed to
provide the Services or for:
- Category B -
As long as the user
has an account with us
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
-
Receiving
help
through
our
customer
support
channels;
-
Participation
in
customer
surveys
or
contests;
and
-
Facilitation
in
the
delivery
of
our
Services
and
to
respond
to
your
inquiries.
How
do
we
use
and
share
your
personal
information?
We
collect
and
share
your
personal
information
through:
-
Targeting
cookies/Marketing
cookies
-
Click
redirects:
Facebook
,
Google
,
Twitter
,
Salesforce
and
LinkedIn
.
-
Social
media
plugins:
Facebook
,
Twitter
and
LinkedIn
.
We
use
social
media
features,
such
as
a
"Like"
button,
and
widgets,
such
as
a
"Share"
button,
in
our
Services.
Such
features
may
process
your
Internet
Protocol
(IP)
address
and
track
which
page
you
are
visiting
on
our
website.
We
may
place
a
cookie
to
enable
the
feature
to
work
correctly.
If
you
are
logged
in
on
a
certain
social
media
platform
and
you
interact
with
a
widget
or
button
belonging
to
that
social
media
platform,
this
information
may
be
recorded
to
your
profile
of
such
social
media
platform.
To
avoid
this,
you
should
log
out
from
that
social
media
platform
before
accessing
or
using
the
Services.
Social
media
features
and
widgets
may
be
hosted
by
a
third
party
or
hosted
directly
on
our
Services.
Your
interactions
with
these
features
are
governed
by
the
privacy
notices
of
the
companies
that
provide
them.
By
clicking
on
one
of
these
buttons,
you
agree
to
the
use
of
this
plugin
and
consequently
the
transfer
of
personal
information
to
the
corresponding
social
media
service.
We
have
no
control
over
the
essence
and
extent
of
these
transmitted
data
or
their
additional
processing.
Will
your
information
be
shared
with
anyone
else?
We
may
use
your
personal
information
for
our
own
business
purposes,
such
as
for
undertaking
internal
research
for
technological
development
and
demonstration.
This
is
not
considered
to
be
"selling"
of
your
personal
information.
We
have
disclosed
the
following
categories
of
personal
information
to
third
parties
for
a
business
or
commercial
purpose
in
the
preceding
twelve
(12)
months:
We
have
sold
or
shared
the
following
categories
of
personal
information
to
third
parties
in
the
preceding
twelve
(12)
months:
The
categories
of
third
parties
to
whom
we
sold
personal
information
are:
-
Advertising,
Direct
Marketing,
and
Lead
Generation
Amazon
Mobile
Ads
,
Apple
iAd
,
Bing
Ads
,
Facebook
Audience
Network
,
Google
AdSense
,
Salesforce
Marketing
Cloud
and
Salesforce
Sales
Cloud
Facebook
Custom
Audience
,
Facebook
Remarketing
,
Google
Ads
Remarketing
,
Google
Analytics
Remarketing
,
Salesforce
DMP
,
Twitter
Remarketing
,
Twitter
Tailored
Audiences
and
LinkedIn
Website
Retargeting
-
Social
Media
Sharing
and
Advertising
Facebook
advertising
,
Facebook
social
plugins
,
Google
Friend
Connect
,
Google+
social
plugins
,
Instagram
advertising
,
LinkedIn
advertising
,
LinkedIn
social
plugins
,
Twitter
advertising
,
Twitter
social
plugins
and
YouTube
social
plugins
Facebook
Analytics
,
Facebook
Ads
conversion
tracking
,
Google
Ads
,
Google
Analytics
,
Google
Analytics
for
Firebase
,
Google
Tag
Manager
,
Salesforce
Analytics
Cloud
,
Twitter
Ads
conversion
tracking
and
Yahoo
Ads
conversion
tracking
The
categories
of
third
parties
to
whom
we
shared
personal
information
with
are:
-
Advertising,
Direct
Marketing,
and
Lead
Generation
Amazon
Mobile
Ads
,
Apple
iAd
,
Bing
Ads
,
Facebook
Audience
Network
,
Google
AdSense
,
Salesforce
Marketing
Cloud
and
Salesforce
Sales
Cloud
Facebook
Custom
Audience
,
Facebook
Remarketing
,
Google
Ads
Remarketing
,
Google
Analytics
Remarketing
,
Salesforce
DMP
,
Twitter
Remarketing
,
Twitter
Tailored
Audiences
and
LinkedIn
Website
Retargeting
-
Social
Media
Sharing
and
Advertising
Facebook
advertising
,
Facebook
social
plugins
,
Google
Friend
Connect
,
Google+
social
plugins
,
Instagram
advertising
,
LinkedIn
advertising
,
LinkedIn
social
plugins
,
Twitter
advertising
,
Twitter
social
plugins
and
YouTube
social
plugins
Facebook
Analytics
,
Facebook
Ads
conversion
tracking
,
Google
Ads
,
Google
Analytics
,
Google
Analytics
for
Firebase
,
Google
Tag
Manager
,
Salesforce
Analytics
Cloud
,
Twitter
Ads
conversion
tracking
and
Yahoo
Ads
conversion
tracking
California
Residents
California
Civil
Code
Section
1798.83,
also
known
as
the
"Shine
The
Light"
law
permits
our
users
who
are
California
residents
to
request
and
obtain
from
us,
once
a
year
and
free
of
charge,
information
about
categories
of
personal
information
(if
any)
we
disclosed
to
third
parties
for
direct
marketing
purposes
and
the
names
and
addresses
of
all
third
parties
with
which
we
shared
personal
information
in
the
immediately
preceding
calendar
year.
If
you
are
a
California
resident
and
would
like
to
make
such
a
request,
please
submit
your
request
in
writing
to
us
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
the
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
Services.
To
request
removal
of
such
data,
please
contact
us
using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and
a
statement
that
you
reside
in
California.
We
will
make
sure
the
data
is
not
publicly
displayed
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.
,
backups,
etc.).
CCPA
Privacy
Notice
This
section
applies
only
to
California
residents.
Under
the
California
Consumer
Privacy
Act
(CCPA),
you
have
the
rights
listed
below.
The
California
Code
of
Regulations
defines
a
"residents"
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
"non-residents."
If
this
definition
of
"resident"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
Your
rights
with
respect
to
your
personal
data
Right
to
request
deletion
of
the
data
—
Request
to
delete
You
can
ask
for
the
deletion
of
your
personal
information.
If
you
ask
us
to
delete
your
personal
information,
we
will
respect
your
request
and
delete
your
personal
information,
subject
to
certain
exceptions
provided
by
law,
such
as
(but
not
limited
to)
the
exercise
by
another
consumer
of
his
or
her
right
to
free
speech,
our
compliance
requirements
resulting
from
a
legal
obligation,
or
any
processing
that
may
be
required
to
protect
against
illegal
activities.
Right
to
be
informed
—
Request
to
know
Depending