California Privacy Rights
California Consumer Privacy Act (CCPA) Notice
Effective Date: 05/01/2025
This California Privacy Rights Notice ("Notice") supplements the information contained in our Privacy Policy and applies solely to California residents. We adopt this Notice to comply with the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, "CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.
Overview of California Privacy Rights
California law grants residents specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Your Rights and How to Exercise Them
1. Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that we disclose certain information to you about our collection and use of your personal information up to the past 12 months. Once we receive and verify your request, we will disclose to you:
- The categories of personal information we've collected about you
- The sources from which we collected that information
- Our business or commercial purpose for collecting, selling, or sharing that information
- The categories of third parties with whom we share that information
- The specific pieces of personal information we collected about you
2. Right to Request Deletion
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete your personal information from our records, unless an exception applies, within 5-10 business days.
3. Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate personal information that we maintain about you. We will use commercially reasonable efforts to correct your personal information based on the information we have on file.
4. Right to Opt-Out of Sale or Sharing of Personal Information
If we share your personal information, you have the right to opt-out of the sharing of your personal information here. Turn does not currently sell your personal information as defined by the CCPA. However, our website does use tools that may "share" certain personal information for cross-context behavioral advertising under the CCPA definition.
5. Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to limit our use or disclosure of certain sensitive personal information. Turn does not currently collect or process sensitive personal information for purposes that would trigger this right under the CCPA.
6. Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
Personal Information We Collect
In the past 12 months, we may have collected the following categories of personal information:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name | YES |
| Personal information categories listed in the California Customer Records statute | Name, address, telephone number, credit card number, debit card number | YES |
| Commercial information | Records of products or services purchased, obtained, or considered | YES |
| Internet or other electronic network activity information | Browsing history, search history, information on interaction with website, application, or advertisement | YES |
| Geolocation data | Physical location | YES |
| Sensory data | Audio, electronic, visual information from customer service interactions | YES |
| Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, behavior | YES |
We obtain the categories of personal information listed above from the following sources:
- Directly from you when you provide it to us
- Indirectly from you (e.g., from observing your actions on our website)
- From third-party service providers
How We Use Your Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill the reason for which you provided the information
- To provide you with information, products, or services that you request from us
- To improve our website and present its contents to you
- For testing, research, analysis, and product development
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- As described to you when collecting your personal information
Disclosure of Personal Information
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers
- Commercial information
- Internet activity information
- Geolocation data
We disclose your personal information to the following categories of third parties:
- Service providers who help us operate our business
- Payment processors
- Marketing and analytics partners
- Delivery and logistics providers
Sales or Sharing of Personal Information
In the preceding 12 months, we have not sold your personal information as defined under the CCPA.
In the preceding 12 months, we have shared certain personal information (such as identifiers and internet activity information) with advertising partners for cross-context behavioral advertising purposes. You can opt out of this sharing by clicking the "Do Not Sell or Share My Personal Information" link on the footer of our homepage or by contacting us directly.
How to Exercise Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Emailing us at: [email protected]
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.
Response Timeline and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to a total of 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. If we deny your request, we will explain why.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Changes to This California Privacy Rights Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the effective date.
Contact Information
If you have any questions or comments about this notice or how we handle your personal information, please contact us at:
Email: [email protected]
Website: turn.me
