Privacy Policy

Updated and Effective as of November 30, 2016.

We want you to understand what we do with your data.

Our goal is to deliver industry-leading tools to allow users to experiment with targeted and personalized marketing that allows users to display, test, and optimize the content that matters most to people, so users can maximize the power of their online marketing.  To this end, we collect and use information you share with us on our website (www.turnclick.com).  We share and use your information only with your consent, as explained in this Privacy Policy. This Privacy Policy applies to the website you are about to view and other affiliated websites operated by TurnClick, Inc., a Delaware Corporation (“Company”).

The mere act of visiting our websites, even without reading the subject legal documents, will be viewed as assent to the terms contained in the Privacy Policy and Terms of Use Agreement.  Company may modify this Privacy Policy from time to time, and if we change it materially, we will make those changes available for your review through our websites, apps, or other services, or by other means so that you may consider the changes before you continue to use Company’s services.  If you object to any of the changes, you may close your accounts with us and cease using the Company websites, which will result in Company completely wiping your information from the Company database.  For as long as you continue to use Company’s websites or maintain your accounts with us, your continued use will constitute consent to the policy changes.

WHAT INFORMATION WE COLLECT AND USE

2.1. Automatically Collected Information.

2.1.1. Cookies.

All of Company’s websites use cookies and similar technologies, including mobile device identifiers that automatically collect information when you visit Company’s websites.  Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow), which enable the site’s or service provider’s systems to recognize your browser.  Every time you load a Company website, your browser sends a cookie back to the server to notify the website of your previous activity. This allows Company to recognize the state of your session on the website and to record your browsing activity and history.  Company uses this information to understand and save your preferences for future visits and to compile aggregate, anonymous data about site traffic and site interaction so that we can provide better site experiences and tools in the future.  Company also uses cookies and similar technologies to store passwords and forms you have previously entered to facilitate future use.

You can control cookies through your browser settings and other tools.  Disabling cookies may impair the quality of your experience on our websites.  Unless you disable cookies on your own device, by visiting any of Company’s websites, you consent to the placement of cookies and beacons, and similar technologies in your browser in accordance with this Privacy Policy.

2.1.2. Web Beacons.

Company’s website pages may contain electronic images known as web beacons - also referred to as single-pixel gifs.  These permit Company to count users who have visited its pages and to collect other related website statistics - (e.g., recording the popularity of certain website content and verifying system and server integrity). Web beacons are not used to access your personal information on Company’s websites; they are solely used to compile aggregated statistics concerning the use of the Company’s websites. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.  Company tracks the pages on Company’s websites that our users visit in order to determine which areas and sites are the most popular.  This data is used to deliver customized content and advertising within the website to customers whose behavior indicates they are interested in a particular subject area.

2.1.3. Device and Network Information.

We collect information from the devices and networks that you use to access Company websites.  When you visit or leave Company by clicking a hyperlink or view a plugin on a third-party site, we automatically receive the URL of the site from which you came or the one to which you are directed.  Also, advertisers receive the URL of the page that you are on when you click on any ad that may appear on Company’s site.  We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Company using a mobile device), the name of your ISP or your mobile carrier, installed mobile SDK version, IDs of the variations the Visitor has seen, Customer’s account number, a string identifying the conversion goal, the elements of the Customer Properties tested (e.g. the page URL for Customer Sites) and other event data; and the date and time of the visit. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information.

2.1.4.  E-mail addresses

Whenever a Company website offers a link for you to send e-mail messages to the Company or for you to submit a support ticket, your e-mail address is collected, so that the Company may reply to your inquiry.  Company tracks the pages on this website that our users visit in order to determine which areas of the site are the most popular.  This data is used to deliver customized content and advertising within the website to customers whose behavior indicates they are interested in a particular subject area.

2.1.5.  Third Party Sites

When you use your Company account to sign in to third party sites or to access third party services.  (e.g. use plugins for Facebook, Google +, and Twitter), both Company and those third party sites may collect information and use it to recommend content specifically tailored to you.

2.1.6.  Other

Because Company is constantly innovating and developing ways to improve its services, we may create new ways to collect and use information.  We often introduce new features, some of which may result in the collection of new information.  Furthermore, new partnerships or corporate acquisitions may result in new features, and these may potentially result in collection of new types of information.

2.2.  User Shared Information.

In addition to automatically collected information, some of our other websites ask users to share additional information.  We collect information when you visit a Company website, use our mobile applications, or interact with any advertising on Company websites. At www.turnclick.com, the website users can access limited features of the website without disclosing personal information by logging on anonymously. In order to access the entire website and store information for more than thirty days, users must register for an account, which will provide the registrant with full access to the website, including the ability to save and use proxy sites. If users choose to register, Company will collect personal information, including e-mail address, zip code or other location information, and any additional information you wish to share.

2.3.  Service and support information

With respect to Company’s sites, when you contact us for support or assistance, we will collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our Terms of Service or this Privacy Policy.  We also use this information to track potential problems and trends and customize our support responses to better serve you.

2.4. Polls and Surveys

Polls and Surveys may be conducted by Company websites or by third parties on Company’s websites. Some third parties may target advertisements to you based on your answers in the poll. Company or third parties develop new programs or products based on the information you share in the surveys. We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will be used only for the purpose of delivering the promised incentives and verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

HOW WE SHARE USER INFORMATION WITH THIRD PARTIES

3.1  Personal Information is Not Generally Shared

Company does not rent, sell, or otherwise disclose personal information that you have not posted publicly or in response to a survey, except as described in this privacy policy.  We will not disclose personal information that is not published to your profile without your consent or to carry out your instructions (for example, to process payment information) or unless Company has a good faith belief that disclosure is permitted by law or is reasonably necessary in compliance with this Privacy Policy.

3.2  We May Share Aggregate Information with Third Party Service Providers to Improve Services

We may allow third party service providers access to data about our users’ aggregate browsing habits in order to assist us in better understanding our website visitors.  We prohibit these service providers from using the information collected from you for any purpose other than helping us conduct and improve our business.

3.3  We May Share Information with Company Subsidiaries and Affiliates to Provide Optimal Services

Whenever you create an account on a Company website, the information you share is used to offer you a personalized, relevant experience on that site and could be used on other Company sites that are outside the Company entity that is your data controller (for example, Company may share your information with Company-related entities that may be created to manage Company-affiliated businesses and websites abroad) as necessary to provide optimal services. By agreeing to this privacy policy, you are consenting to this sharing.

3.4  Users Should Be Aware That Their Actions May Make Some Information Available to Third Parties

Company encourages you to review the privacy statements of any websites you choose to visit via hyper-links posted on Company’s websites, so that you can understand how these other websites collect, use, and share your information.  Company is not responsible for the privacy policies or other content on third-party websites accessed through Company’s website.

3.5  We Will Comply with Legal Process and Make Other Required Disclosures

Company may use or disclose personal information, profile information, or information about your activities as a Company user when required by law, subpoena, or other legal process, or if Company has a good faith belief that disclosure is reasonably necessary to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce this Privacy Policy or our Terms of Use; (3) respond effectively to your service inquiries; (4) investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our services; or (5) exercise or protect the rights, property, or safety of Company, our users, or members of the public.

3.6  Information May be Disclosed as a Result of a Change in Control or Sale of Company

We may also disclose your personal information to a third party as part of a sale of the assets of Company, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which Company transfers or sells Company’s assets will have the right to continue to use the personal and other information that you provided to Company’s websites in the manner set out in the Privacy Policy.

TARGET ADS

Company does not currently, and does not intend to, share personally identifiable information with any third-party advertiser or ad network. Company may, in the future, choose to target ads to Members both on and off Company websites through a variety of ad networks and ad exchanges, using:

If Company does participate in this type of targeted advertising, Company will still not be sharing personally identifiable information with any third party advertiser or ad network.

CONSENT

When you register on a Company website, you acknowledge that information you provide in your profile may be seen by Company members; you expressly and voluntarily accept the Terms of Use and agree that any information Company collects may be used as described in this Privacy Policy and Company’s Terms of Use.  Supplying information to us, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part.  You have the right to withdraw or modify your consent to Company’s collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the Terms of Use, by changing your settings, changing your profile, closing your account, or ceasing to use Company’s websites.

COMPANY COMMUNICATIONS

Company may communicate with you using e-mail, text messaging, and other ways available to us regarding Company service and security issues.  Our communications may also contain promotional messages and information directly or on behalf of third parties.  These messages will be sent to you based on your profile information and messaging preferences.  You may change your email and contact preferences at any time by signing into your account and changing your e-mail settings.  You can also opt out of promotional messages by sending a request to Company through http://help.turnclick.com/.  Please be aware that you cannot opt out of receiving service messages from Company.

YOUR RIGHTS TO ACCESS, CORRECT, OR DELETE INFORMATION; CLOSING YOUR ACCOUNTS

You can access and control some of the information that we collect and process about you.  For example, you may: (1) access, modify, correct, or delete your personal information controlled by Company regarding your profile by going to the “Account Settings” page on any of Company’s websites; (2) modify payment settings and e-mail notification settings; and/or (3) close your account. You can also contact us at privacy@turnclick.com to find out about what, if any, account information we possess that is not visible on your profile or readily accessible to you. If you close your account, your information will generally be removed from the Service within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information within 30 days of account closure, except as noted below.

DATA RETENTION

While you maintain an account on a Company website, we will retain any personal information you have provided.  Notwithstanding Section 7 above, Company may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between users, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Use. In addition, if law enforcement requests it, we may retain personal information for a limited, additional period of time. Company may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with Section 7, above.

USER OBLIGATIONS

If a user violates any of these guidelines or the guidelines detailed in our Terms of Use or elsewhere, Company reserves the right to restrict, suspend, or terminate the user’s account at the sole discretion of Company.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently and carefully. If there is any change, we will provide notice to users by posting the newly modified privacy policy on our website with an updated “last modified” date.  If the changes are significant, we will, in addition, post a notice on our websites for 30 days and contact registered users either through the Company websites, or by some other means, such as email. Please review changes carefully. Your continued use of Company’s websites after notice of the changed terms or practices will constitute agreement to these changes. If you object to any of the changes to our terms and you no longer wish to use Company’s websites or services, you may close your accounts and cease to browse Company. Unless stated otherwise, Company’s current Privacy Policy will apply to all information that Company has collected about you and your account.

CALIFORNIA’S SHINE THE LIGHT LAW

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits any users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.  Company currently does not share any personal information with third parties for their direct marketing purposes.

SECURITY AND RECOURSE

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your personal information on Company is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the Company websites. We also offer secure https access to the website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to Company. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Company users are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.

Company has designated Salar Salahshoor as the individual who will oversee compliance with privacy requirements.  He can be contacted at the address below regarding any privacy policy issues.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, please contact us online or by physical mail at:

TurnClick, Inc.
Attn: Privacy Policy Issues
privacy@turnclick.com
1241 5th St, Suite 305
Santa Monica, CA 90401