Website and Mobile App Privacy Policy

EFFECTIVE DATE: 2022-09-13

In this Privacy Policy (“Policy”), we describe how Turing Video (“Company”) collects, uses, and discloses information that we obtain about visitors to our website available at https://turing.ai (the “Site”), mobile application and dealer portal (“you”).

By visiting the Site or mobile application, you agree that information describing or relating to you (“Personal Information”) will be handled as described in this Policy. Your use of our Site or mobile application, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Company Terms of Service are incorporated by reference into this Policy.

Residents of certain states may have additional rights concerning their Personal Information under the laws of those states. If you are a resident of Colorado, Connecticut, Nevada, Utah, or Virginia, please refer to the “Additional Privacy Information for Certain Jurisdictions” section below.

• I. Personal Information We Collect

  We collect Personal Information directly from users, from third parties, and automatically through use of our Site or mobile application.

  The Personal Information we collect does not include:

  • Personal Information we reasonably believe you or a third party have made publicly available;
  • Deidentified or pseudonymous data that cannot be attributed to you and is stored separately from other data that could be used to identify you; and
  • Personal Information covered under other laws such as protected health information, creditworthiness, research, and education.

  • 1. Personal Information We Collect Directly from You

    The Personal Information we collect from you depends on how you use our Site and mobile application, but generally includes the following categories:

    • Contact information such as name, address, email, and phone number.
    • Government identifiers such as Social Security Number and driver’s license number.
    • Unique identifiers such as an account number, individual or member ID.
    • Employment and professional-related information such as company name, organization type, company address, and job title.
    • Credit or debit card information such as your card number, date of expiration, and CVV number.
    • Payment or financial information such as credit or payment card information.
    • General location information such as IP-address-based location information through the use of location tracking information.
    • Advertising information such as your purchasing history.

  • 2. Personal Information We Collect Automatically

    We automatically collect Personal Information about your use of our Site through cookies and other technologies, including:

    • Domain name;
    • Country or region information;
    • Browser type;
    • Pages viewed and activities conducted;
    • Links clicked;
    • IP address;
    • Length of session;
    • Referring URL for the website;
    • Advertising ID;
    • Mobile device ID;
    • Device name and model;
    • Activities within the App;
    • Length of time that you are logged into our App;
    • Location information: With your permission, we will collect location information from your mobile device. You may turn off this feature through the location settings on your mobile device;
    • Language information;
    • Operating system, name and version.

    To the extent permitted by applicable law, we combine this information with other information we collect about you, including your Personal Information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

    We store the Personal Information that we receive from third parties with other Personal Information that we collect. For information about how third parties may use and disclose your Personal Information, including any information you make public, please consult their respective privacy policies. We have no control over how any third party uses or discloses the Personal Information they collect about you.

• II. Our Purposes for Using Personal Information

  We use your Personal Information for the following purposes:

  • Operating Site and Mobile Application and Providing Related Support. To provide and operate our Site and mobile application, communicate with you about your use of the Site and mobile application, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
  • Responding to Inquiries. To respond to your questions, fulfill your orders and requests, and consider your request or application (e.g., if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
  • Analyzing and Improving our Site, our mobile application, and our Business. To better understand how users access and use the Site and mobile application, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
  • Personalizing Experiences. To tailor content we may send or display on the Site and mobile application, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
  • Marketing Communications. To send newsletters, or any other information that you sign up to receive.
  • Market Research and Customer Satisfaction: To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
  • Protecting Our Legal Rights and Preventing Misuse. To protect the Site and mobile application and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Privacy Policy.
  • Complying with Legal Obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
  • Business Transfers. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.
  • Training our Customer Service Representatives and Auditing our Customer Service Practices. We retain our chat sessions for history, training, and audit purposes.
  • Planning and Managing Events. We use the Personal Information that we collect for event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events. Any information you provide about emergency contacts, dietary preferences, or accessibility requirements is used solely for your safety and health purposes.

• III. How We Disclose Personal Information

  We may share the categories of Personal Information with the following parties:

  • Service Providers (Processors). We may disclose Personal Information we collect with our service providers or agents who perform functions on our behalf. These service providers include [IT service providers, help desk, payment processors.
  • Affiliates. We may disclose Personal Information we collect to our affiliates or subsidiaries.
  • Business Customers. Any transactional information collected by our customers through the Company’s Site or mobile application may be available to their customer account administrators or other customer account managers, and may, at the direction of our customers, be shared with third parties as necessary for our customers’ loan origination and management purposes. The Company’s customers may use certain information they collect through our Site or mobile application for marketing or promotional communications, subject to any appropriate or necessary consents and their own privacy policies.
  • Company Users. The username and any information that you post to our Site or mobile application, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and mobile application.
  • Public Authority/Agency. We may disclose Personal Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, and terms of service, (c) to protect the security or integrity of our Site or mobile application, (d) to protect the property, rights, and safety of the Company, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.
  • Third-Party Ad Networks. We may disclose Personal Information to third-party ad network providers, sponsors and/or traffic measurement services. These third parties may use cookies, JavaScript, web beacons (including clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. To exercise your choices about receiving third-party ads, see “What Choices Do I Have Regarding Use of My Personal Information?”
  • Third-Party Analytics Providers. We may disclose Personal Information to marketing analytics service providers such as Google Analytics or Microsoft Bing.

• IV. Our Purposes for Sharing Personal Information

  We may disclose information to the parties listed in Part III above for the following purposes:

  • Operating Site and Providing Related Support. To provide and operate our Site and mobile application, communicate with you about your use of the Site and mobile application, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
  • Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, and third-party advisors, including attorneys and consultants.
  • Marketing. We may disclose your Personal Information to third-party ad networks in order to serve advertisements on our Site, mobile application, and on third-party Site or other media. This enables us and these third parties to target advertisements to you for products and services in which you might be interested.
  • In Response to Legal Process. We may disclose your Personal Information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect You, Us, and Others. We disclose your Personal Information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

  We may share aggregated and/or pseudonymous information from which individual user identities have been removed and that are not reasonably linkable to any individual.

• V. Our Use of Cookies and Other Tracking Technologies

  We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site or mobile application. We may combine this information with other Personal Information we collect from you and our third-party service providers may do so on our behalf. For more information on the types of Personal Information we collect through these technologies, please see the section above titled “The Personal Information We Collect.” For resources and instructions on how to disable tracking technologies, see the section below titled “Tracking and Advertising Choices.”

  Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and mobile application, while others are used to enable a faster log-in process or to allow us to track your activities at our Site. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and mobile application. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site and mobile application.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

  Clear GIFs, Pixel Tags, and other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and mobile application to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

  Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons, to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

  Cross-Device Use. We may use the information that we collect about you (whether directly from our Site, from our mobile applications, through your device(s), or from a third party) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt out of cross-device advertising, you may follow the instructions set forth in the “Third-Party Ad Networks” section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out on each browser or device that you use.

  Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the “Third-Party Ad Network” section.

  Third-Party Links. Our Site and mobile application may contain links to third-party Site. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

• VI. Tracking and Advertising Choices

  If you wish to prevent cookies or third-party advertisers from tracking your activity on our Site or visits across multiple websites, there are tools you can use to disable cookies and opt out of interest-based advertising. Using the resources below does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular Site that you are viewing (i.e., contextually based ads) and as described above. Your opt-out may not be effective if your browser is configured to reject cookies.

  • Browser Solutions for Disabling Cookies: If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and mobile application who disable cookies will be able to browse the Site, but some features may not function.
  • Industry Solutions for Opting Out of Interest-Based Advertising. Notwithstanding the above, visitors to our Site may follow the steps provided by initiatives that educate users on how to set tracking preferences for most online advertising tools. These resources include YourOnlineChoices in the EU (https://www.youronlinechoices.eu), the Network Advertising Initiative (https://thenai.org/about-online-advertising) and the Digital Advertising Alliance (https://digitaladvertisingalliance.org) in the US, the Digital Advertising Alliance of Canada (https://youradchoices.ca/en/learn), the Data Driven Advertising Initiative in Japan (http://www.ddai.info/optout), or other similar services. You can use the Digital Advertising Alliance’s AdChoices opt-out tool (https://youradchoices.com/control) to opt out of the use of your Personal Information by many third-party ad networks for targeted advertising purpose. The Digital Advertising Alliance also offers an application called AppChoices (https://youradchoices.com/appchoices) that helps users to control interest-based advertising on mobile apps.

• VII. Additional Privacy Information for Certain Jurisdictions

  Note that these rights only apply to Personal Information that we collect and process under the terms of this policy. In our capacity as a service provider to other businesses, we may collect or process other Personal Information as reasonably necessary to provide our Site and mobile application. This Personal Information is not subject to the rights outlined below.

  • 1. Rights of Nevada Consumers

    Under Nevada Revised Statutes Chapter 603A, Nevada residents have the right to opt out of the sale of “Personally Identifiable Information,” which is defined as a natural person’s first name or first initial and last name in combination with their Social Security Number, driver’s license number, identification card number, account number, credit card number, debit card number, in combination with any required security code, access code, or password that would permit access to that person’s financial account.

  • 2. Rights of Virginia Consumers

    Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent that we collect Personal Data subject to applicable Virginia law, the following applies.

    We may share de-identified information about individuals with third parties. We commit to maintaining and using de-identified data without attempting to re-identify a Virginia consumer except as permitted by law.

    Right to Correction: To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

    Right to Deletion: To delete personal data provided by or obtained about you.

    Right of Portability: To obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller or business where the processing is carried out by automated means.

    Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition, so an opt-out mechanism is not required.

    Right to Opt-Out of Significant Profiling: To opt out of the processing of your personal data by us for decisions that produce legal or similarly significant effects concerning you.

    Our Right to Refuse Your Request: We may deny your request if (1) we are not reasonably capable of associating your request with the personal data or it would be unreasonably burdensome for us to associate your request with the personal data; (2) we do not use the personal data to recognize or respond to you specifically or associate the personal data with other personal data about you; and (3) we do not sell the personal data to any third party or otherwise voluntarily disclose the personal data to any third party other than a processor, except as otherwise permitted under Virginia law.

    Right to Appeal: If we decline to take action regarding your request, we will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

  • 3. Rights of Colorado Consumers

    Under the Colorado Privacy Act (“CPA”), Colorado residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CPA, as well as certain rights with respect to our processing of such Personal Data. To the extent that we collect Personal Data subject to applicable Colorado law, the following applies.

    Right to Access: To confirm whether or not we are processing your personal data and to access such personal data.

    Right to Correction: To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

    Right to Deletion: To delete the personal data provided to us by you.

    Right to Data Portability: To obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance, where the processing is carried out by automated means.

    Right to Opt-Out of Sale, Targeted Advertising, and Profiling: A “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. To opt out of our sale of your personal data for monetary compensation, please email support@turingvideo.com.

  • 4. Rights of Connecticut Consumers

    Under the Connecticut Data Privacy Act (“CTDPA”), Connecticut residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CTDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent that we collect Personal Data subject to applicable Connecticut law, the following applies.

    Right to Access: To confirm whether or not we are processing your Personal Data and to access such Personal Data.

    Right to Correction: To correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.

    Right to Deletion: To delete the Personal Data provided to us by you.

    Right to Data Portability: To obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.

    Right to Opt-Out of Sale, Targeted Advertising, and Profiling: To opt out of our sale of your Personal Data for monetary compensation, please email support@turingvideo.com. For purposes of the CTDPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not disclose Personal Data to third parties in exchange for monetary compensation or other valuable consideration.

  • 5. Rights of Utah Consumers

    Under the Utah Consumer Privacy Act (“UCPA”), Utah residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under UCPA, as well as certain rights with respect to our processing of such Personal Data. To the extent that we collect Personal Data subject to applicable Utah law, the following applies.

    Right to Access: To confirm whether or not we are processing your Personal Data and to access such Personal Data.

    Right to Correction: To correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.

    Right to Deletion: To delete the Personal Data provided to us by you.

    Right to Data Portability: To obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.

    Right to Opt-Out of Sale, Targeted Advertising, and Profiling: To opt out of our sale of your Personal Data for monetary compensation, please email support@turingvideo.com. For purposes of UCPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation. We do not disclose Personal Data to third parties in exchange for monetary compensation.

• VIII. Submitting Privacy Rights Requests

  If any of the rights described in the sections above apply to you, you may exercise your rights by any of the following means:

  • Emailing us at support@turingvideo.com

  You must provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or, where necessary, to process your request. If we are unable to adequately verify a request, we will notify the requestor.

  For more information about our privacy practices, you may contact us as set forth in the ‘Contact Us’ section below.

• IX. Children

  Our Site and mobile application are not designed for children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information from our systems. We do not knowingly collect or sell Personal Information of consumers under 16 years of age as of the date of this Privacy Policy.

• X. Changes to this Policy

  This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and/or Application.

• XI. Contact Us

  If you have questions about the privacy aspects of our Site or mobile application or would like to make a complaint, please contact us at support@turingvideo.com