28 June 2021
In terms of your contractual relationship with Turn.io we obtain Personal Information (“PI”) as defined by the Data Protection Legislation about you (hereinafter referred to as “you/your/ client”), as our client and potentially the PI of your clients/end users. We want you to understand who you are sharing your PI with, what kind of information we are collecting and how we use it.
PI does not include any anonymous, de-identified, or statistical information – provided that it cannot be linked back to you.
This policy is effective from 28 June 2021
Turn.io may also collect other information through your interaction with and use of Turn.io offerings, including:
We use this information to:
Who are you sharing your information with?
Turn.io uses and shares the PI it collects (unless otherwise restricted by applicable law):
Turn.io uses and shares the PI in good faith and as it believes to be necessary or appropriate:
Turn.io does not sell or rent your PI to third parties for any purpose.
Turn.io may use, transfer and disclose other information, which is not PI, that Turn.io collects for any purpose, such as statistical information about visitors to Turn.io websites, except where applicable law requires otherwise.
Your information is processed in accordance with the Data Processing Addendum (“DPA”) attached to the Customer Contract and as agreed to by you. Should we share your information with any additional third parties or affiliates, this shall only be as agreed in terms of the DPA.
Another Person’s Information
If you share any PI with Turn.io that relates to another person (“Data Subject”) you warrant and undertake to and in favour of Turn.io that:
You indemnify, defend and hold Turn.io harmless from and against any and all claims, demands, causes of action, liabilities, losses, damages, judgments, settlements, fines, penalties, awards, costs, expenses and fees (including legal costs and fees on an indemnity basis) that may be sustained, suffered or secured against or incurred by Turn.io arising out of or resulting from:
For What Period Does Turn.io Retain Personal Information
The time periods for which Turn.io keeps your PI may vary according to the use or purpose attached to the PI. Turn.io will keep your PI (i) only for as long as it is required to fulfil the purpose for which the PI was collected or for which it is to be processed or (ii) until you withdraw your consent. However, where Turn.io is required by applicable law to retain your PI longer or where your PI is required for Turn.io to assert or defend against legal claims, Turn.io will retain your PI until the end of the relevant retention period or until the claims in question have been settled.
At the end of the retention period, Turn.io will delete your PI in a manner designed to ensure that it cannot be reconstructed or read.
How do we store and secure your Personal Information?
We use reasonable technical and organisational safeguards that are designed to protect your PI from unauthorised or unlawful processing, accidental loss, misuse, unauthorised access, disclosure, alteration and destruction. We store and secure your information in accordance with our Data Storage and Security Measures Policy and DPA.
However, despite our efforts, no security controls are 100% effective and we cannot guarantee the security of your PI. In the event that your PI is acquired, or is reasonably believed to have been acquired, by an unauthorised person and applicable law requires notification, we will give you notice promptly. We will determine the scope of the breach and investigate and restore the integrity of the data system.
How Turn.io transfers PI it collects internationally
Turn.io collects and shares information globally.
Cookies will be used to save your email address and name so the next time you visit your Account from the same device we will have a record and will remember your email address and name to make your experience faster and simpler.
You can manage your communication preferences on your account.
What are your Data Protection Rights?
For natural persons who reside in the European Union, you can request that Turn.io restricts its processing of your PI (i) if you contest the accuracy of the PI and then for a period enabling Turn.io to verify the accuracy of your PI; (ii) if there is no legal basis for Turn.io to process your PI and you oppose Turn.io’s erasure of such PI; (iii) if Turn.io no longer needs your PI for the purposes of processing same but you claim that you require Turn.io to retain such information in order to claim or exercise legal rights or to defend against third party claims; or (iv) if you object to the processing of your PI, for as long as it is required to review as to whether Turn.io has a prevailing interest or legal obligation in processing your PI. If you request a copy of your PI, to the extent that Turn.io can comply with such request, it will provide you with that information in a machine-readable form.
Turn.io’s Contact Details