Privacy Policy

This Privacy Policy describes My Turnstyle, Inc.’s data practices regarding information within its scope, including the choices available to you. Unless otherwise stated, information or personal information means information that identifies, relates to, or is reasonably capable of being associated with an individual or household.

This Privacy Policy applies to information we collect where we control the purposes and means of processing, specifically through our websites, apps, emails, or other online services that link to this Privacy Policy (the Service) as well as from other sources described below. Your use of the Service is subject to our Terms of Service.

This Privacy Policy does not apply to:

• The practices of third parties we do not control.
• Information collected in the context of job applications or employment with us.
• Information that has been anonymized or, to the extent permitted by law, deidentified.

See Contact Us for our contact details.

We collect the following categories of information:

• Contact identifiers, including your name, email address, postal address, and phone number.
• Characteristics or demographics, including your age, gender, and country of residence.
• Account credentials, including your username, password, password hints, and other information used for authentication or account access.
• Payment information, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments. This information is processed by our payment processors.
• Content, including any content within messages you send to us (such as feedback, questions, or survey responses).
• Device identifiers, including your device’s IP address.
• Device information, including your device’s operating system and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
• Internet or other network activity, including your browsing history and interactions with the Service, such as the features you use, pages you visit, content you view, time of day you browse, and referring and exiting pages.
• Non-precise location data, such as location inferred from an IP address or generalized to a city or postal code level.
• Inferences, preferences, or other insights we derive from the information described above.

We collect information from the following sources:

• Information you provide through the Service. When you use the Service, you may be asked to provide information to us, such as when you register for an account, make a purchase, sign up for our newsletters, participate in a promotion, respond to surveys, post content, or contact support. Please do not provide any information that we do not request.
• From your device. When you use the Service, we and third parties we work with automatically collect information from your browser or device using cookies and other tracking technologies. See Cookies and Other Technologies.
• Through our business relationship with you. To the extent you engage with us on behalf of another business, we collect information relating to you and that business. This information is not subject to this Privacy Policy except as required by applicable law.
• From third parties. We obtain information from third party sources, including:
  • Third party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.
  • Social media platforms with which you interact. For example, when you engage with our social media channels, we may collect information associated with your profile. We may also receive additional information from the social media platform that you have authorized the platform to disclose to us. If you publicly reference us, we may feature your post in our Service or marketing materials.
  • Public sources, such as data in the public domain.
• Where we generate the information. We generate information based on information we collect from the various sources described above.

This section describes the types of tracking technologies we use to automatically collect information from your browser or device. See Your Privacy Choices to exercise choice around tracking technologies.

• Cookies. Cookies are browser-based text files placed on your browser when you visit a website, open or click on an email, or interact with an advertisement. There are various types of cookies, including session cookies (which expire when you close your browser) and persistent cookies (which remain until a set expiration date or until you manually delete them). Cookies may be first party (served directly by us) or third party (served by third parties we work with).
• Pixels. Pixels (also known as web beacons) are pieces of code embedded in a service. There are various types of pixels, including image pixels (typically one-pixel transparent images) and JavaScript pixels (which execute code). Pixels are often used in conjunction with cookies. When you access a service that contains a pixel, the pixel may allow us or a third party to collect information from your browser or device, or to place or read cookies on your browser.

We use these tracking technologies for various purposes, including to operate our Service, personalize your experience, prevent fraud, improve security, perform measurement and analytics, and provide advertising (including targeted advertising).

We collect and use information for the following purposes:

• To provide services, including operating and maintaining the Service.
• To personalize your experience, including showing you content we believe may be of interest to you.
• To communicate with you, including sending transactional and marketing messages by email, and, where you opt-in, by text or push notification.
• To understand usage and trends, including through surveys you respond to and tracking technologies incorporated into the Service (such as Google Analytics).
• To improve products and services, including training models and algorithms.
• For advertising purposes. We work with various third parties, such as ad agencies, ad networks, publishers, social media platforms, and technology providers, to deliver and measure ads. For example, we place ads on third party websites or platforms that use tracking technologies to serve the ads, measure ad performance, detect ad fraud, limit how often ads are shown, and provide reporting and analytics. If you visit our Service after viewing or interacting with one of our ads on a third party website or platform, tracking technologies on our Service will help us attribute your visit and understand ad effectiveness.
• Some advertising we engage in may be targeted advertising, which is the practice of showing you more relevant or personalized ads based on your activity over time and across non-affiliated services. Targeted advertising often involves us incorporating third party tracking technologies into our Service or disclosing (often hashed) identifiers, such as email addresses or Ad IDs, with third parties. These third parties then match our data with their own (or their partners’ data) to deliver ads to you or similar audiences.
• For security, compliance, and enforcement, including preventing, detecting, investigating, and responding to fraud, misuse, policy or legal violations, or threats to safety.
• At your direction, including where you instruct us to use your information in a specific way or where we notify you and obtain your consent.
• Non-personal information. We may anonymize or deidentify information so it is no longer considered personal information under applicable law. Where we deidentify information, we commit to maintaining and using the deidentified information in deidentified form and not attempt to reidentify it. We may use non-personal information for any purpose permitted by law.

We use artificial intelligence (AI), including machine learning technologies, to support the purposes described above. This includes helping us provide the services, personalize experiences, understand usage and trends, improve products and services, promote security, compliance, and enforcement, and otherwise automate internal processes.

We disclose the information we collect for the purposes described in this Privacy Policy. The categories of persons to whom we disclose information include:

• Service providers. Many of the third parties we work with are service providers that collect and process information on our behalf. Service providers perform services for us, such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing information they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal information for any purpose permitted by law.
• Third party vendors and related parties. Some of the third parties we work with independently control the purposes and means of processing your information. For example, we disclose information to vendors that provide analytics, security, and fraud prevention services to us. We also disclose information to ad networks, technology providers, and other third parties that help provide targeted advertising.
• Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the information in accordance with their own privacy policies.
• Recipients for legal, security, and enforcement purposes. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security, and safety of us, the Service, or anyone else.
• Recipients at your direction or with your consent. We disclose information where you direct us to do so or with notice to you and your consent.
• Non-personal information. We may disclose non-personal information for any purpose permitted by law.

Our Service may link to or be incorporated with websites and online services controlled by third parties. In addition, we may integrate technologies into our Service, including those described in Cookies and Other Technologies, that are controlled by third parties. Except where third parties act as our service providers, they (not us) determine the purposes and means of processing your information.

This section describes the choices available to you regarding your information.

Communications.

To stop receiving marketing emails, follow the unsubscribe instructions near the bottom of such emails, or email us at as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional emails.

Accounts.

If you have an account with us, you can delete your account through your account settings. We will address your request in accordance with our data retention practices.

Browser and Device Controls.

• Cookies and pixels. You may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.
• Third party opt-out tools. Some third parties we work with offer their own opt-out tools related to information collected through cookies and pixels. To opt out of your information being used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of their tools.
• Industry opt-out tools for targeted advertising. Some third parties we work with follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, which offers its own opt-outs tools for targeted advertising. For details, visit https://youradchoices.com/control. We are not responsible for the effectiveness of these tools.

The Service is not directed toward children under 16 years old. If you are a parent or guardian and believe we have collected information from children in violation of applicable law, contact us as set out in the Contact Us section below.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please note that transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

We are based in the U.S. Your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.

The controller responsible under this Privacy Policy is:

My Turnstyle Inc. (“Turnstyle,” “we,” “our,” or “us”)
PO Box 8, New York, NY 10024
support@myturnstyle.com

If you have any questions about our data practices or experience difficulty accessing this Privacy Policy, contact us using the postal or email address above.