Turing Video Services Privacy Policy

EFFECTIVE DATE: 2023-02-19

In this Privacy Policy (“Policy”), we describe how Turing Video (“Company”) collects, uses, and discloses information that we may collect on behalf of third-party dealers, resellers, partners and distributors who have been authorized by Company to resell SaaS services (“Company Authorized Parties”) to our customers (“Customers”) who deploy our video monitoring technology on their premises (the “Services”), to capture personal information of individuals entering the premises of Customers (“you”). 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 including our enterprise customers (“Enterprise Customers”) or Company Authorized Dealers.

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 on Behalf of Third Parties

The Services permit Enterprise Customers and Company Authorized Dealers to collect certain Personal Information from you for their own purposes (“Enterprise Customer Personal Information” or “Company Authorized Dealer Personal Information”). We collect this Enterprise Customer Personal Information and Company Authorized Dealer Personal Information only on behalf of each Enterprise Customer or Company Authorized Dealer. The collection, use and disclosure of your Enterprise Customer Personal Information or Company Authorized Dealer Personal Information will be governed by the applicable Enterprise Customer’s or Company Authorized Dealer’s policies, including its privacy policy. Each Enterprise Customer and Company Authorized Dealer is responsible for all its activity in connection with the Services, including obtaining all necessary consents or approvals from or by you, and providing all necessary notices to you. The Enterprise Customer Personal Information and Company Authorized Dealer Personal Information that we collect depends on the particular Services and the particular Enterprise Customer or Company Authorized Dealer. For example, the Services enable you to, with your consent, provide Enterprise Customer Personal Information or Company Authorized Dealer, including biometric and health information, to verify your identity, prevent against fraud and/or to provide other services to our Enterprise Customers or Company Authorized Dealers, including facilitating access at locations that use the Services, including, if applicable, if your employer or a commercial establishment uses the Services for COVID-19 access screening. We collect your biometric information through the video and thermal imaging functions in the applicable hardware, in each case when you stand within the field of view of the applicable hardware.

• 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.
• Geographic information such as whether you have entered into a facility of an Enterprise Customer and your location while on premises.
• Biometric information such as faceprints (and facial mapping and scans of digitized images).
• Sensory information such as photos, videos or audio recordings of your environment.
• Health information such as body temperature recordings.
• Demographic information such as sex, gender, race, ethnicity, age, and religion.
• Advertising information such as your purchasing history.
• Vehicle information such as license plate numbers, vehicle color, vehicle make, and vehicle model.
• Inferences drawn from other Personal Information collected such as information reflecting user attributes or behavior (e.g., to assess risk of COVID-19).

We store the Personal Information that we receive from third parties, including Enterprise Customers and Company Authorized Dealers, 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:

• Analyzing and Improving Services and our Business. To better understand how users access and use our 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.
• 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.

III. How We Disclose Personal Information

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

• Enterprise Customers. We share your Enterprise Customer Personal Information only with the particular Enterprise Customer(s) on whose behalf we collected your Enterprise Customer Personal Information.
• Company Authorized Dealers. We share your Company Authorized Dealer Personal Information only with the particular Company Authorized Dealer(s) on whose behalf we collected your Company Authorized Dealer Personal Information.
• 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.
• 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 Services, (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.

IV. Our Purposes for Sharing Personal Information

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

• Operating Services and Providing Related Support. To provide and operate our Services and provide troubleshooting and technical support.
• 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.
• 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. 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 Services. 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. We do not sell your Personally Identifiable Information as defined under this law.

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 Virginia consumers 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: To opt out of our sale of your personal data for monetary compensation, please email support@turingvideo.com. A “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration.

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 collected on behalf of our Enterprise Customers or Company Authorized Dealers 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 collected on behalf of our Enterprise Customers or Company Authorized Dealers to third parties in exchange for monetary compensation.

VI. 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.

VII. Children

We do not knowingly collect or sell Personal Information of consumers under 16 years of age as of the date of this Privacy Policy.

VIII. 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.

IX. Contact Us

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