Privacy and Cookies Policy

Effective Date: January 15, 2019
Last Updated: October 8, 2019

The Terms of Service of Turn Vision contains this privacy policy (‘Privacy Policy’) by reference. For this document, Turn Vision, Inc. (a Delaware corporation) will be referred to as “Turn Vision,” “us” and “we.”

PURPOSE OF THIS PRIVACY POLICY

The objective of this Privacy Policy is to explain how we may gather and use personal data that we collect while you use our website http://www.turn.vision (“Site”) and other Turn Vision products including; the cloud-based Turn Vision Academy platform http://www.turnvision.academy (the “Platform”), and our physical and online class instructional products (the “Services“), and enlightens you on why and how we use your Personal Information and how to exercise your rights in accessing and controlling the use of your personal information.

APPLICATION OF THIS PRIVACY POLICY

By using our Site and Services, you concede that you have correctly read and understood this Privacy Policy.

We are obligated to explain our role and responsibility for Personal Information to users residing in the EU and UK.

  • The EU privacy law defines us as the “data controller” when you use the Site or/and the Services as an individual entity. 
  • If you use the Platform or the Services under an employer or potential employer who has an Enterprise Agreement with us, your employer or potential employer remains your data controller for the Personal Information you may be required to provide by virtue of that agreement. The Personal Information you provide will be processed in accordance with the terms of that Enterprise Agreement. In this case, the EU law defines us as a “data controller” under the privacy law; this means that we process your Personal Information in the Service of your employer or potential employer and do so at their direction. All questions about specific privacy practices concerning the use of any Turn Vision product through your employer or potential employer should be addressed to them (your employer or potential employer).
  • Turn Vision becomes the data controller only if your employer or potential employer enters an Enterprise Agreement that does not designate them (your employer or potential employer) as the data controller of your Personal Information in connection with your use of the Platform or any other Services.

By accessing and using the Site or the Services, you agree to Turn Vision gathering and retaining data affiliated to the provision of the Site and the Services within the specifications of this Privacy Policy, and as a non-EU resident you consent to all privacy or terms related altercations contained in this Privacy Policy being regulated by the New York State law and the refereeing of all altercations that come up as a result of using a Turn Vision product is in accordance with the Terms of Service.

CATEGORIES OF PERSONAL INFORMATION TURN VISION COLLECTS

All information about an individual that serves as a means of identifying that individual is regarded as Personal Information. Data with unspecified or undesignated identity isn’t a constituent of Personal Information. The following are data items about you that we may collect, use, store, transfer, and treat as Personal Information (some only qualify as Personal Information when combined with personal identity tags):

Identity Data: This category consists of the information we use to identify you, communicate with you, and certify you as an authentic use of our product(s). They also serve as a means of logging your transactions and activities. Identity data consists of your name (first, last, and maiden), title, marital status, DOB, log in details, and SSN necessary for documenting.

Contact Data: This data is required to make contact with you, it consists of billing address, email, telephone number and mobile phone number.

Technical Data: This consists of technical details of the devices you access our Site and Services with; IP address, login data, browser type and version, time zone and location, browser types and versions, and operating system.

Usage Data: This consists of information relating to how you use/navigate our Site and Services.

Transaction Data: Consists of all data regarding previous Service registrations and enrollments. 

Financial Data: Payment information is usually gathered and processed by our payment partners, but on rare occasions, we may collect this data.

Assessment Data: This consists of information on your proficiency in specific technology-related fields and your score on our abilities and learning needs tests.

Profile Data: This consists of personal data like age, gender, and educational qualification, it also includes interests and preferences, and other technical details like browsing history and feedback/survey responses.

Marketing and Communications Data: This consists of your inclinations and receptiveness when our third-party partners or we direct marketing at you. It also includes your preferences in communication.

AGGREGATED AND ANONYMIZED, NON-IDENTIFIABLE DATA

We often utilize this type of data (statistical and demographic) to help us analyze and understand user trends in various areas such as skills, jobs, and the general workforce. This collected data is analyzed by our unstructured machine learning algorithms to understand user behavior and provide user-specific personalization and recommendations for an improved experience in our Site and Service. Aggregated and non-identifiable data is also used for marketing, collecting useful information about our user base, and improving the content and operations of the Site and Services.

Aggregated and anonymized data is not considered as Personal Information because though they may be collected from Personal Information, it still protects your identity. In cases where our combination of Personal Information with anonymized data directly or indirectly reveals your identity, we handle this new data structure as Personal Information and use it within the terms of this Privacy Policy.

Turn Vision has the right to apply aggregate or anonymous data for purposes not limited only to those indicated above. We reserve the right to share such anonymous information with our partners and third-party service providers, except Personal Information, which can only be used within the specifications of this Privacy Policy. 

FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION

Your failure to provide requested Personal Information which we are required by law or terms of the contract with you or your employer or potential employer, it may limit our ability to perform under said contract and stop us from providing access to or use of the Services. If we are already bound to you by a contract, we may have no other choice but to cancel your access to the Services with an advance notification of our course of action. 

HOW TURN VISION COLLECTS YOUR INFORMATION

Direct Interaction

We collect your Personal Information when you perform any of the following actions:

  • Sign up on the Site or register to use the Services
  • Use any of the Services or third-party Sites to apply for a Class, Course, Workshop, or any other Services the Site offers.
  • Take part in our events such as surveys, promotions, and competitions.
  • Reach out to us through any of our accounts on different social media platforms like Instagram, Facebook, Twitter, LinkedIn, etc.
  • Posting Personal Information on the Site or Services through chat rooms, comments, blog posts, etc.
  • Interacting with us through our personnel like customer care, marketing, and sales teams; or communicating with us through the submission of queries concerning our products and inquests for more information from us such as marketing content and newsletters and
  • Partake in any of our events or programs by signing up for them online or in person. These events and programs can be directly run by us our third-party partners.

Automated Technologies or Interactions

We utilize cookies, server logs, and other automated technologies in collecting anonymous technical data such as browsing actions and behavior when you use our Site or Services. Further information on the use of cookies is provided below.

COOKIES, AUTOMATIC DATA COLLECTION, AND RELATED TECHNOLOGIES

Turn Vision, and our third-party Service providers such as advertisers and analytics providers use cookies and other related technologies to collect and save data like preferences, web traffic, IP address, browser and device type, background or back-linked websites, operating system and usage statistics when you use our Sites and Services. More Personal Information about you may also be obtained from public sources and third parties.

Cookies are a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. Cookies were designed to be a reliable mechanism for websites to remember stateful information or to record the user’s browsing activity. Most of the cookies we use are only valid during the duration of your visit and expire as soon as you exit your browser. The cookies that last longer perform the following functions: 1). Remember when next you use our Site or Services 2). Grant you access to secured areas of the Site, help us provide you with the Service you requested, and enable you to navigate 3). Performance cookies are used to collect statistical and anonymous data on how you use our Site and Services; this information is used to better your user experience 4). Functionality cookies allow us to save your preferences, such as language, region, and username 5). Enable you to watch a video or make a comment and give you an all-round smooth user experience.

Third-party vendors such as Google and we use first and third-party cookies to place you in an ideal “market segment” by gathering information about the websites you visit through our advertisement partners or during your organic web sessions. Turn Vision and our third-party vendors use this information to deliver relevant adverts to you when you visit our Site and other websites. All this information is then combined by our third-party vendors with data obtained from other websites to learn more about your interests. You can opt-out of this automatic system of information by third-party ad services and learn more about how internet-based advertising works by visiting the opt-out page for the self-regulatory principles for online advertising here

We also employ Google Analytics Advertising Features such as Google Analytics Re-marketing to advertise on various websites, Demographics and AdWords and AdSense integrations to obtain information about our Site traffic through advertising cookies and anonymous identifiers. We do not orchestrate the combination of Personal Information with non-personally identifiable information, which has previously been collected through a Google advertising product. Google may display ads on other websites that you visit based on information collected from your past visits to our Site. You may opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on found and Google Analytics for Display Advertising and customize Google Display Network ads by using ad setting and the opt-out add-on on https://tools.google.com/dlpage/gaoptout/ and https://www.google.com/settings/u/0/ads?hl=en respectively.

We also use these similar technologies in addition to cookies:

  • Pixel GIF/web beacons: small image files that may be placed by third parties on the Site or Services or us, or within the body of our newsletters so third parties or we can understand which parts of the Site and Services are visited or whether particular content is of interest. A Web beacon is a small graphic image that third parties or we place on Site or Services or i the body of our newsletters that is used to identify what parts of Sites or Services are visited and what content is of interest.
  • Flash cookies: Although we do not serve Flash cookies, Adobe Flash Player may be used by third parties that place advertisements on the Site when these ads are served with content related to flash. It is impossible to block or limit flash cookies using your browser setting. However, you can visit the Adobe website for more information on how to do this at http://www.adobe.com/products/flashplayer/security.

Disabling Cookies

By default, most computers and some browsers are set to accept cookies automatically, you can change the settings to have your browser notify you each time a cookie is set or block and delete them from your browser. It is essential to understand that disabling cookies may result in Site and Services not functioning correctly, and this may hinder you from taking full advantage of Site and Services. Useful information about cookies and how to block cookies on different browsers can be found on www.allaboutcookies.org.

Below are instructions on how to customize cookie settings and disable cookies on the most common browsers:

Microsoft Internet Explorer:

  • Access the menu bar, choose “Tools” then “Internet Options.”
  • Click on the “Privacy” tab
  • Select the settings the suit you Access the menu bar, choose “Tools” then “Internet Options.”
  • Click on the “Privacy” tab

Google Chrome:

  • Access the menu bar, select “Chrome” then “Preferences.”
  • Find the “Settings” page, scroll down, and select “Advanced.”
  • Under “Privacy and Security,” click “Content settings” then “Cookies.”
  • Select the appropriate settings that suit you.

Safari:

  • Access the menu bar, then choose “Chrome” and select “Preferences.”
  • From “Preferences” box, choose the “Privacy” tab found in the menu bar
  • Choose the appropriate settings from the “Website tracking” menu
  • Click on “Manage Website Data” and make your preferred selections

Mozilla Fox:

  • Access the menu bar, then select “Firefox” and choose “Preferences.”
  • Click “Privacy” tab on the menu bar
  • Click on the appropriate settings in the “Tracking” menu
  • Click on “remove individual cookies” and make the preferred selections

PURPOSES FOR WHICH TURN VISION USES YOUR INFORMATION

For your convenience, we have outlined the different ways in which we use your Personal Information and the legitimate bases and legal bases on which we require them when appropriate.

Please note that depending on the specific reason for the use of your Personal Information, we may process your Personal Information for more than one lawful purpose. Do not hesitate to contact us for more information about the specific legal grounds we require to process your Personal Information.

  Purpose/Activity

  Type of Data

  Lawful Basis for Processing

  For identifying you with your account and enabling you register to use the Services.

  •  Identity Data
  • Contact Data
  • Assessment of Data

  We have required (i) to give you access to the Services, (ii) for the execution of a contract with you, and (ii) for our lawful business interest in being able to offer the Services to you.

  For managing and processing of payments, fees, and charges for the Services.

  • Identity Data
  • Contact Data Identity Data
  • Financial Data

We are required for our lawful business interest to obtain our pay for providing you with the Service.

  For facilitating and delivering the Services.

  •  Identity Data
  • Contact Data
  • Assessment of Data

Required (i) to perform a contract with you, (ii) for our lawful business interest in providing the Services to you, and (iii) to make for an excellent customer experience to you in the duration of the Services.

  For managing our relationship and interactions with you

  •  Identity data
  • Contact Data
  • Profile Data
  • Usage Data

We have required (i) to perform a contract with you, (ii) for our lawful business interest in providing the Services to you, and (iii) to make for an excellent customer experience to you in the duration of the Services experience during the duration of the Services.

Keeping you updated about changes made to our Services, schedules for the Services, requirements for the Services, and any other technical requirements.

  • Identity Data
  • Contact Data
  • Profile Data

Required (i) to perform a contract with you, (ii) for our lawful business interest in providing the Services to you, and (iii) to make for an excellent customer experience to you in the duration of the Services.

Giving you feedback on your participation and performance in the Services.

  •  Identity data
  • Contact data
  • Profiles Data
  • Usage Data
  • Assessment data

Required (i) to perform a contract with you, (ii) for our lawful business interest in providing the Services to you, and (iii) to make for an excellent customer experience to you in the duration of the Services.

For the review and grading of your coursework and certifying your completion of the needed Services.

  • Identity data
  • Contact data
  • Assessment data

Required (i) to perform a contract with you, (ii) for our lawful business interest in providing the Services to you, and (iii) to make for an excellent customer experience to you in the duration of the Services.

  Updating you when any changes are made to this policy.

  • Identity data
  • Contact data

Required for us to comply with our legal obligations relating to data privacy laws

  Requesting a review or survey from you.

  •  Identity data
  • Contact data
  • Marketing and communications data

Required for our lawful business interests (i) to keep our records updated, (ii) to understand customers in terms of usage and rating of our services, (iii) to make for an excellent customer experience to you in the duration of the Services.

And (iv) to ensure we consistently make improvements in our Services to meet the needs of our clients and students.

For providing you with our Site and its content and enhancing the user experience.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data

It is required for our lawful business interests in providing the Site and Services to you and optimizing the Site and Services to meet your needs and demands best.

For improvement of the functionality of the Site or Services and provision of customer related service.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data

Required (i) to perform a contract with you and (ii) for lawful business interests in (a) providing the Services to you, (b) ensuring you have administrative network security and IT services in connection with the Services, (c) to make for an excellent customer experience to you in the duration of the Services, and (d) to ensure we consistently make improvements in our Services to meet the needs of our clients and students.

Administration and protection of the Site and Services ( troubleshooting, data analysis, tests, and system reviews).

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data

Required (i) to perform a contract with you and (ii) for lawful business interests in (a) providing the Services to you, (b) ensuring you have administrative network security and IT services in connection with the Services, (c) to make for an excellent customer experience to you in the duration of the Services, and (d) to ensure we consistently make improvements in our Services to meet the needs of our clients and students.

For communicating with you and providing you information that you request or consent to through regular or electronic mail, text message, or other marketing channels.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data

Required (i) to perform a contract with you and (ii) for our lawful business interests in continuing to develop and offer new and improved Services to you and in continuing to grow our business.

To suggest and recommend other courses and services you may be interested in.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data

It is required for our legitimate business interests to continually improving and developing our Services to you and facilitating the expansion of our business.

To provide you with access to competitions and promos.

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data

We are required for our legitimate business interests in making our Site and Services more attractive to users and for promoting our business. 

For sending with your consent adverts, marketing content about our programs, promotions, and services belonging to us or our affiliates and newsletters we think you may be interested in through email, text message or other marketing channels, and contact you with these services if it is permitted by local law.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data

It is required for our lawful business interests to continually developing and offering new Services to you and in expanding our business.

CHANGE OF PURPOSE

Your Personal Information will only be used for the purpose which we collected it for, with the exception of cases where we have a valid reason to utilize it for another purpose, this purpose must also be within the limits of this Privacy Policy. Contact us at [email protected] if you require more information on the compatibility of the new purpose with the original purpose. On occasions where we need your Personal Information for new and unrelated purposes, you will be notified with an explanation of the legal basis that allows us to do this.

NOTICE TO JOB APPLICANTS

We collect your Personal Information you voluntarily submit to us when you apply for a job posted on our Site, such information include: name, email address, telephone number, postal address, educational qualifications, employment history, and information contained in your cover letter or LinkedIn profile such as gender, race, ethnicity, veteran status, disability status, and reference information. You reserve the right not to provide us with this last set of information (race, ethnicity, and disability) as we do not request it, and it will not affect your application in any way. If you choose to provide us with such information, we will only use it following the law for diversity and the monitoring of equal opportunity. You have the responsibility to obtain the permission of your referee(s) before submitting their information to us as part of your resume. Turn Vision will use the personal information submitted to us concerning a job application within the limits of this Privacy Policy for the following purposes; to eliminate conflicts of interest and conduct reference and background checks (where permissible by law) to evaluate your qualifications and suitability for a position. All Personal Information you submit during the process of recruitment will become a part of your file and may be used for work-related purposes if you eventually become an employee or contractor.

For applicants residing outside the United States; note that the Personal Information you provide will be sent to, processed and stored in the United States (law requires the Personal Information to be stored in relevant jurisdiction(s) if the job is related to our affiliated entity outside the United States), and you agree to the transfer, processing, and storage of your data in the United States. You also consent to the collection, storage, and processing of this information for your job application if your Personal Information includes details of your race, ethnic origin, and state physical or mental health.

HOW TO OPT OUT OF FUTURE COMMUNICATIONS

If you want to cut all contact without marketing content and other information related to our products and services or no longer wish to be contacted for those purposes even after giving your consent when Personal Information was collected, you can unsubscribe at any time by following the instructions contained in all communications sent to you. Alternatively, you can contact us at [email protected] to unsubscribe at any time.

Option-out of marketing messages does not apply to Personal Information, and we reserve the right to send you specific account and registration-related information concerning your use of the Site and Services if you have signed up for an account with us or registered for a course. Such messages include information related to account management, customer service, and system maintenance. These account-related messages are not affected by your choice to opt-out of marketing communications.

NOTICE TO CALIFORNIA RESIDENTS

We do not in any way give out your Personal Information to third parties who are not our affiliates for their marketing purposes, this only happens when you have opted-in to such an agreement or turned down the opportunity to opt-out of such an opportunity when you were presented with one at the time of your provision of Personal Information.

As a California resident, you have the right to know that Personal Information about your online activities may be collected by third parties over time through different websites when you visit our Site. Please refer to the section titled “Cookies, Automatic Data Collection and Related Technologies” if you require additional information about this.

“Do Not Track” Signals: Some web browsers may transmit a “do not track” request to websites and web services that communicate with the browser. As no law stipulates how we should respond to these requests, our Site, just like most others, may ignore the “do not track” signals.

HOW TURN VISION MAY SHARE YOUR INFORMATION

Vendors and Third-Party Service Providers These organizations (which may include third-party suppliers, agents, subcontractors, and/or other companies in our group) will only use your information to the extent necessary to perform their support functions. Besides, where necessary, we have entered into Data Processing Agreements with these third-party service providers. Certain conditions warrant us to share any information we receive, including your Personal Information with vendors and third-party service providers, including Instructors relating to the provision of the Site and Services. Such conditions include dealings with services providing website and data hosting (e.g., Amazon Web Services and Heroku), services like Sailthru and Salesforce that distribute communications and support or update marketing lists, services like SurveyMonkey that structured feedback on our services, other services that provide periodic IT support services. These organizations may include other third-party subordinates and will only use your information to the extent necessary to carry out their support functions. We have also entered Data Processing Agreements with these third-party providers when necessary.

Payment Transactions.  All transactions concerning payments are outsourced to a third party called Stripe for safe online credit card payments. You will be providing your debit or credit card payment details directly to Stripe, who process your payment details through a secure server and encrypt your credit/debit card information and authorize payment. We do not have any access to the information you provide to our payment solutions provider, and such information is subject to our service provider’s terms and conditions and privacy policy. Stripe, our third-party service provider, handles the security of the payment solution. For more detailed information about the Service, please contact Stripe.

Events and Partnerships. Occasionally, we have partnerships with other organizations to run events. If you register for such an event indicated on our Site, you may receive emails from those organizations after the event if you either gave your consent to be contacted by marketing communications when we collected your information or where we are otherwise permitted allowed by local law to contact you for marketing purposes. You can always refer to that organization’s privacy policy for clarification on how to opt-out of their communications if you do not want to be contacted by them through email any longer.

Displaying to Other Users. Some of the content you post on the Site may be viewed publicly by other users of the Site, such information includes comments posted on a blog post or chat room. You are advised to be cautious when using public forums and avoid posting sensitive or Personal Information. We cannot be held responsible if any Personal Information you publicly post on the Site or Services is used by third parties.

Social Networking and Other Websites. The Site or Services gives you the chance to post information to social networking platforms, and it is crucial to understand that we will not share such information with social media networks unless you direct the Site or Services to do so. The way the information is used by social networking websites is controlled by their privacy policies, which we do not control.

As Required By Law and Similar Disclosures. We may obtain, store, and share your Personal Information, other account and usage information, and device identifier (such as IP address), and content if we believe doing so is necessary to: adhere to law enforcement requests and legal process (a court order, warrant or subpoena); reply to your requests; implement policies related to our Site or Services, or other applicable policies; or preserve your, our, or others’ rights, property, or safety. Except it is prohibited by law or court order, or unless we conclude at our discretion that notification is inappropriate under the circumstances, we will take all appropriate steps to notify all concerned users of a legal request for information or intended disclosure before disclosure.

Merger, Sale, or Other Asset Transfers. In the event that we are subject to a merger, acquisition, financing due diligence, bankruptcy, reorganization, receivership, sale of company assets, or change of Service to another provider, your information and Personal Information may be sold or transmitted as part of such a transaction as one of the transferred assets as permitted by law and/or contract. We have no control in the way such entities decide to use or disclose such information.

With Your Consent. We may also disclose your Personal Information and other information if you have expressly provided your consent for the disclosure. You retain the right to withdraw consent to disclosures where you had formally given specific consent by emailing us at [email protected].

SECURITY OF YOUR INFORMATION

We have put in place the necessary physical, technical, and administrative steps created to protect your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. We also restrict access to your Personal Information to only those employees, agents, contractors, and other third parties who have an absolute need to access that information in operating our business, including the operation of the Site and Services. These employees, agents, contractors, and other third parties will only process your Personal Information on our instructions and are mandated to comply with a duty of confidentiality.

As stated above, all payment transactions are carried by a Stripe, a third-party solutions service, for secure online credit card payments. Stripe ensures the security of the payment solution.

You have a huge role to play in the safety and security of your information. You are responsible for the confidentiality of any password we give to you or chosen by you to access certain parts of the Site and Services. We task you with not disclosing that password to anyone and urge you to not display sensitive information in areas of the Site, such as the message board. Other users of the Site or Services may view information displayed in public areas.

There is no electronic data transmission or storage of information that can guarantee complete and error-free security; hence, we cannot ensure or guarantee the safety of any Personal Information placed on our Site or Services. Bear in mind that transmission of Personal Information is at your own risk.

CHILDREN’S PRIVACY

Our Site and the Services are not intended for nor directed toward children under the age of 16, and we do not knowingly collect personal information from children under 16 years of age. If you believe that your child under the age of 16 may have provided us with Personal Information without your consent, you may alert us at [email protected] If we learn that we have inadvertently collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child’s account.

Our Sites and Services are intended for use by individuals above the age of 16, and we do not intentionally collect personal information of children below 16 years of age. Kindly alert us at [email protected] if you suspect that your child below 16 years has provided us with Personal Information without your consent. If we confirm your suspicion to be accurate, we will immediately delete all such information and terminate the child’s account.

EXTERNAL LINKS

The Site or Services may occasionally contain links to external websites. Clicking on those links or allowing those connections takes you out of our boundaries, and your data may be subject to collection by third parties. We are in no way accountable for the content of such third parties and their privacy policies; neither do we have any control over them. You are advised to carefully go through the privacy policy of any third-party website you visit.

DATA TRANSFERS TO THE UNITED STATES

The Site and the Services are located and controlled in the United States. For users located outside the United States, kindly note that the information we collect about you, including Personal Information, will be sent to, processed, and stored in the United States.

DATA RETENTION

We store your Personal Information only for as long as necessary to achieve the purposes we collected it for, including those required to satisfy any legal, accounting, or reporting obligations.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements

We determine the optimal retention period for personal information by considering the amount, nature and sensitivity of the Personal Information, we also consider the potential risk of harm faced in the event of unauthorized use or disclosure of Personal Information, why we process your Personal Information and if we can achieve those purposes by other ways and the necessary legal requirements.

Information concerning retention periods for different areas of your Personal Information may be sent on request by emailing us at [email protected]

YOUR LEGAL RIGHTS

Based on the provisions by General Data Protection Regulation 2016/679 (the GDPR), data subjects situated in the EU have the right under certain occasions to:

  • Be presented with a copy of your Personal Information in our possession
  • Request a correction of your Personal Information in our possession
  • Request that we limit the processing of your Personal Information (for example, while we verify or investigate your concerns over this information )
  • Request for a halt in further processing of your Personal Information, including the right to decline marketing
  • Request that the Personal Information you have provided to us be sent to a third party
  • Withdraw consent: if the basis of the processing of your Personal Information is based upon consent, you retain the right to withdraw that consent without impairment at any given time.
  • Request that we delete any of your Personal Information in our possession

To exercise any of the above-listed rights, please email us at [email protected].

You are not required to pay a fee to access your Personal Information or to exercise any of those stated rights. We, however, have the right to demand a fee if we believe your request is excessive, baseless, or repetitive. We may also turn down your request in these circumstances.

In responding to any of the requests outlined above, we may ask for specific information from you to confirm your identity and ensure you have the right to access your Personal Information or any other right. This is a security measure put in place to ensure that your Personal Information is not shared with any person who is not authorized to receive it. To hasten our response time, we may contact you for further information related to your request.

We typically aim to respond to all legitimate requests within 30 days. Sometimes we may require more than 30 days if your request is complicated or if you have made numerous requests. You will be notified and kept updated if that is the case.

If we do not resolve your concern to satisfaction, you may you may contact your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index en.html), they can provide additional information concerning your rights and our obligations with respect to your Personal Information, as well as deal with any complaints you have about our processing of your Personal Information.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

It is mandatory that the Personal Information we have about you is correct and up to date. We ask that you keep us informed if you make any changes to your Personal Information in the course of our relationship. You may bring to date, change, or delete any information that you have sent to us through your use of the Site or Services by sending an email to  [email protected].

You can seek clarification about unsubscribing from email or other communications by sending an email to  [email protected].

You may share suggestions and tips on how to improve this Privacy Policy by sending an email to [email protected].

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

Periodically, we may review or update our Privacy Policy, and you will be notified of such changes by posting updates to the Privacy Policy on this web page. The date of the last revision of this Privacy is identified at the top of the page.

CONTACT INFORMATION

For further questions about this Privacy Policy or Turn Vision’s privacy practices, please contact us with the information below:

Turn Vision, Inc.
2035 Sunset Lake Road
Suite B-2
19702
Newark, Delaware
United States
[email protected]